{"operation":"document","citation":"CPF 12024022WL","title":"NORTHERN ILLINOIS GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-04-04","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024022wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024022wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024022wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024022WL","body":"Warning Letter involving NORTHERN ILLINOIS GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2024-04-04 and is reported as closed as of 2024-04-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024022WL_Operator Response to Notice_07222024_(23-266225).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024022WL/12024022WL_Operator%20Response%20to%20Notice_07222024_(23-266225).pdf\n\n12024022WL_Warning Letter_04042024_(23-266225).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024022WL/12024022WL_Warning%20Letter_04042024_(23-266225).pdf\n\n12024022WL_Warning Letter_04042024_(23-266225)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024022WL/12024022WL_Warning%20Letter_04042024_(23-266225)_text.pdf\n\n12024022WL_Warning Letter_04042024_(23-266225)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 4, 2024\nMr. Melvin Williams\nSenior Vice President & President Nicor Gas\nNorthern Illinois Gas Co\nP.O. BOX 190, Rt. 59 & I-88\nAurora, Illinois, 60507\nCPF 1-2024-022-WL\nDear Mr. Williams:\nFrom May 23 – 25, 2023, inspectors from the Illinois Department of Natural Resources (IL DNR),\nacting as an agent of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Northern Illinois Gas Co’s\n(Northern Illinois) Troy Grove underground natural gas storage facility in LaSalle County, Illinois.\nAs a result of the inspected, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed after July\n18, 2017, must meet all provisions of API RP 1171 (incorporated by\nreference, see § 192.7), and paragraphs (c) and (d) of this section, prior\nto commencing operations.\nNorthern Illinois failed to meet the provisions of API RP 1171, Section 6. Specifically, Northern\nIllinois failed to test the tubing-casing annulus for a well completed with tubing and packer as\nrequired by API RP 1171, Section 6.9.1.\n\n\n\nPursuant to API RP1171 Section 6.9.1, a well that has had its existing production casing modified\nfrom its previous condition during workover activities shall be tested to demonstrate mechanical\nintegrity and suitability for the designed operating conditions prior to commissioning. For a well\ncompleted with tubing and packer, the tubing-casing annulus shall be tested.\nDuring the inspection, PHMSA representatives reviewed documentation for Northern Illinois’\nwell workover program for multiple wells at the Troy UNGS facility, including Weldon #7.\nNorthern Illinois provided information for the well workover program for the Weldon #7. This\ninformation indicated that, following the installation of tubing and packer, a pressure test would\nbe conducted to 800 psi. Northern Illinois was unable to provide further documentation showing\nthat this pressure test was performed for Weldon #7. Northern Illinois provided pressure test\ndocumentation for other wells on which workovers were performed.\nTherefore, Northern Illinois failed to meet the provisions of API RP 1171, Section 6 by failing to\ndemonstrate that it had confirmed the mechanical integrity of the workover on Weldon #7 pursuant\nto API RP 1171, Section 6.9.1.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related\nseries of violations. For violation occurring on or after January 6, 2023 and before December 28,\n2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,\nup to a maximum of $2,576,627 for a related series of violations. For violation occurring on or\nafter March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142\nper violation per day the violation persists, up to a maximum of $2,391,142 for a related series of\nviolations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the\nmaximum penalty may not exceed $225,134 per violation per day the violation persists, up to a\nmaximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nNorthern Illinois Gas Co being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2024-022-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6367}