{"operation":"document","citation":"CPF 12024041NOA","title":"NORTHWEST NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-05-07","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024041noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024041noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024041noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024041NOA","body":"Notice of Amendment involving NORTHWEST NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2024-05-07 and is reported as closed as of 2024-08-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024041NOA_Closure Letter_08202024_(23-264007).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Closure%20Letter_08202024_(23-264007).pdf\n\n12024041NOA_Closure Letter_08202024_(23-264007)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Closure%20Letter_08202024_(23-264007)_text.pdf\n\n12024041NOA_Notice of Amendment (Amended)_06272024_(23-264007).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Notice%20of%20Amendment%20(Amended)_06272024_(23-264007).pdf\n\n12024041NOA_Notice of Amendment (Amended)_06272024_(23-264007)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Notice%20of%20Amendment%20(Amended)_06272024_(23-264007)_text.pdf\n\n12024041NOA_Notice of Amendment_05072024_(23-264007).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Notice%20of%20Amendment_05072024_(23-264007).pdf\n\n12024041NOA_Notice of Amendment_05072024_(23-264007)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Notice%20of%20Amendment_05072024_(23-264007)_text.pdf\n\n12024041NOA_Operator Response to Notice (Supplemental)_07272024_(23-264007).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Operator%20Response%20to%20Notice%20(Supplemental)_07272024_(23-264007).pdf\n\n12024041NOA_Operator Response to Notice_05162024_(23-264007).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024041NOA/12024041NOA_Operator%20Response%20to%20Notice_05162024_(23-264007).pdf\n\n12024041NOA_Notice of Amendment_05072024_(23-264007)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 7, 2024\nMr. Joseph Karney\nVice President, Engineering & Utility Operations\nNorthwest Natural Gas Company\n250 SW Taylor Street\nPortland, Oregon 97204\nCPF 1-2024-041-NOA\nDear Mr. Karney:\nFrom August 7 to August 11, 2023 of the onsite inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected Northwest Natural Gas Co.’s (Northwest) Mist Underground Natural Gas\nStorage in Columbia County, Oregon.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within\nNorthwest’s plans or procedures. The item inspected and the inadequacy is described below:\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.\nNorthwest’s written construction procedures for underground natural gas storage were inadequate\nto assure safe operation of a pipeline facility. Specifically, Northwest failed to develop and follow\na construction procedure for the reuse of tubing during reworking of tubing and packer wells\npursuant to American Petroleum Institute Recommended Practice 1171 (2015) (API RP 1171),\nSections 6.3.6 and 11.2.11\n.\n\n\n\nAPI RP 1171, Section 6.3.6 - Handling requires that “[c]asing shall be stored, transported, lifted\nand installed as specified by the manufacturer and in accordance with API 5C1.” Section 7 of API\nRP 5C1 includes guidance related to the inspection of used tubing.\nAPI RP 1171, Section 11.2.1 - Construction, Operation, and Maintenance Procedures requires in\npart that operators “… develop and follow procedures for the construction, operation, and\nmaintenance of natural gas storage wells and reservoirs to establish and maintain functional\nintegrity.”\nDuring the inspection, PHMSAs determined that well 13b-23-65 had been reworked. PHMSA\nreviewed records and procedures regarding the removal and reinstallation of tubing on the well\nand found that the procedures did not require the inspection or replacement of the original tubing\nduring reworking tubing and packer wells.\nTherefore, Northwest’s written procedures required by § 192.12(b)(1) pursuant to meeting the\nprovisions of API RP Sections 6.3.6 and 11.2.1 were inadequate. Northwest must revise its\nprocedures to address the deficiency outlined above.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Northwest Natural Gas maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\n\n\n\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2024-041-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n1 API RP 1171 Section 11.2.1 - Construction, Operation, and Maintenance Procedures\nThe operator shall develop and follow procedures for the construction, operation, and maintenance of natural gas\nstorage wells and reservoirs to establish and maintain functional integrity. When practicable, the operator’s procedures\nshould incorporate applicable industry recommended practices that promote personal and process safety, resource\nconservation, environmental stewardship, mechanical integrity, and reliable performance.\nProcedures shall be in place prior to the development of a new storage facility. The procedures should address the\nminimum requirements for construction including drilling and other well entry work, reservoir integrity monitoring\nand management, O&M, emergency response, control room communications and responses, personnel safety, safety\nmanagement systems, and site-specific procedures determined to be necessary by the operator.\nPrograms should integrate storage well and reservoir elements so that procedures and programs work together to\npromote the functional integrity of the storage facility.\nThe operator should integrate natural gas storage procedures with regulatory-required procedures covering pipeline\nfacilities where possible rather than creating storage-specific documents. The operator might already have in place\nprocedures for operation and maintenance, emergency response, integrity management, control room\ncommunications, qualification of personnel, management of change (MOC), and other procedures covering pipeline\nfacilities. Specific operations related to natural gas storage wells and reservoirs requiring procedures include but are\nnot limited to drilling, well workover, and reservoir integrity monitoring and management programs.\nA procedure should be written in clear language with enough detail to allow a person with appropriate training and\nexperience to follow the procedure and achieve the desired objectives on a consistent basis.\n\n12024041NOA_Notice of Amendment (Amended)_06272024_(23-264007)_text.pdf\n\nAMENDED NOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 27, 2024\nMr. Joseph Karney\nVice President, Engineering & Utility Operations\nNorthwest Natural Gas Company\n250 SW Taylor Street\nPortland, Oregon 97204\nCPF 1-2024-041-NOA\nDear Mr. Karney:\nFrom August 7 to August 11, 2023 of the onsite inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected Northwest Natural Gas Co.’s (Northwest) Mist Underground Natural Gas\nStorage in Columbia County, Oregon.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within\nNorthwest’s plans or procedures. This Amended Notice replaces the Notice that was previously\nissued on May 7, 2024. The item inspected and the inadequacy is described below:\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.\nNorthwest’s written construction procedures for underground natural gas storage were inadequate\nto assure safe operation of a pipeline facility. Specifically, Northwest failed to develop and follow\na construction procedure for the reuse of tubing during reworking of tubing and packer wells\npursuant to American Petroleum Institute Recommended Practice 1171 (2015) (API RP 1171),\n\n\n\nSections 6.3.6 and 11.2.1.\n1\nAPI RP 1171, Section 6.3.6 - Handling requires that “[c]asing shall be stored, transported, lifted\nand installed as specified by the manufacturer and in accordance with API 5C1.” Section 7 of API\nRP 5C1 includes guidance related to the inspection of used tubing.\nAPI RP 1171, Section 11.2.1 - Construction, Operation, and Maintenance Procedures requires in\npart that operators “… develop and follow procedures for the construction, operation, and\nmaintenance of natural gas storage wells and reservoirs to establish and maintain functional\nintegrity.”\nDuring the inspection, PHMSA determined that well 13bc-34-75 had been reworked. In\nNorthwest's October 3, 2023 response to PHMSA’s verbal exit briefing report, Northwest stated:\nNW Natural would like to provide clarification on its previous response.\nRegarding well 13bc-34-75, the 2023 workover operations did not include\ninstallation of new tubing. The existing 7” 23# K-55 SMAX was ran back into\nthe hole at which each connection was made up in accordance with the\nmanufacturer recommended optimal make up torque.\nPHMSA reviewed records and procedures regarding the removal and reinstallation of tubing on\nthe well and found that the procedures did not require the inspection or replacement of the original\ntubing during reworking tubing and packer wells.\nTherefore, Northwest’s written procedures required by § 192.12(b)(1) pursuant to meeting the\nprovisions of API RP Sections 6.3.6 and 11.2.1 were inadequate. Northwest must revise its\nprocedures to address the deficiency outlined above.\nResponse to this Notice\nThis amended Notice is issued in accordance with 49 U.S.C. § 60108(a) and 49 C.F.R. §\n190.206. Any response you may have submitted to the original Notice is no longer applicable.\nYou must respond as set forth below.\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings. Please refer to this document and note the response options. Be advised\nthat all material you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. § 552(b), along with the complete original document you must provide\na second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\n\n\n\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Northwest Natural Gas maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2024-041-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n1 API RP 1171 Section 11.2.1 - Construction, Operation, and Maintenance Procedures\nThe operator shall develop and follow procedures for the construction, operation, and maintenance of natural gas\nstorage wells and reservoirs to establish and maintain functional integrity. When practicable, the operator’s procedures\nshould incorporate applicable industry recommended practices that promote personal and process safety, resource\nconservation, environmental stewardship, mechanical integrity, and reliable performance.\nProcedures shall be in place prior to the development of a new storage facility. The procedures should address the\nminimum requirements for construction including drilling and other well entry work, reservoir integrity monitoring\nand management, O&M, emergency response, control room communications and responses, personnel safety, safety\nmanagement systems, and site-specific procedures determined to be necessary by the operator.\nPrograms should integrate storage well and reservoir elements so that procedures and programs work together to\npromote the functional integrity of the storage facility.\nThe operator should integrate natural gas storage procedures with regulatory-required procedures covering pipeline\nfacilities where possible rather than creating storage-specific documents. The operator might already have in place\nprocedures for operation and maintenance, emergency response, integrity management, control room\ncommunications, qualification of personnel, management of change (MOC), and other procedures covering pipeline\n\n\n\nfacilities. Specific operations related to natural gas storage wells and reservoirs requiring procedures include but are\nnot limited to drilling, well workover, and reservoir integrity monitoring and management programs.\nA procedure should be written in clear language with enough detail to allow a person with appropriate training and\nexperience to follow the procedure and achieve the desired objectives on a consistent basis.\n\n12024041NOA_Closure Letter_08202024_(23-264007)_text.pdf\n\nVia Email Only: Joseph.Karney@nwnatural.com\nAugust 20, 2024\nMr. Joseph Karney\nVice President, Engineering & Utility Operations\nNorthwest Natural Gas Company\n250 SW Taylor Street\nPortland, Oregon 97204\nCPF 1-2024-041-NOA\nDear Mr. Karney:\nOn August 7 to August 11, 2023, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Northwest Natural Gas Co.’s (Northwest) procedures in\nColumbia County, Oregon. As a result of the inspection, Northwest was issued a Notice of\nAmendment on May 7, 2024, and an Amended Notice on June 27, 2024, which proposed\namendment of your procedures.\nNorthwest submitted its amended procedures on July 24, 2024. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Ryan Truair ryan.truair@nwnatural.com","truncated":false,"body_characters":18407}