{"operation":"document","citation":"CPF 12024044NOA","title":"GRAMA RIDGE STORAGE AND TRANSPORTATION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-04-30","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024044noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024044noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024044noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024044NOA","body":"Notice of Amendment involving GRAMA RIDGE STORAGE AND TRANSPORTATION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2024-04-30 and is reported as closed as of 2024-06-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024044NOA_Closure Letter_06112024_(23-264022).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024044NOA/12024044NOA_Closure%20Letter_06112024_(23-264022).pdf\n\n12024044NOA_Closure Letter_06112024_(23-264022)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024044NOA/12024044NOA_Closure%20Letter_06112024_(23-264022)_text.pdf\n\n12024044NOA_Notice of Amendment_04302024_(23-264022).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024044NOA/12024044NOA_Notice%20of%20Amendment_04302024_(23-264022).pdf\n\n12024044NOA_Notice of Amendment_04302024_(23-264022)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024044NOA/12024044NOA_Notice%20of%20Amendment_04302024_(23-264022)_text.pdf\n\n12024044NOA_Operator Response to Notice_05282024_(23-264022).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024044NOA/12024044NOA_Operator%20Response%20to%20Notice_05282024_(23-264022).pdf\n\n12024044NOA_Notice of Amendment_04302024_(23-264022)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: paul.bieniawski@enstorinc.com\nApril 30, 2024\nPaul Bieniawski\nChief Executive Officer\nGrama Ridge Storage and Transportation, LLC\na subsidiary of Enstor Gas, LLC\n10375 Richmond Avenue Suite 1900\nHouston, TX, 77042\nCPF 1-2024-044-NOA\nDear Mr. Bieniawski:\nFrom December, 4th, 2023 to December 7th, 2023, and on February 20th, 2024, a representative of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601\nof 49 United States Code (U.S.C.) inspected Grama Ridge Storage & Transportation, LLC’s\n(Grama Ridge) procedures for Grama Ridge Storage Facility in Eunice, New Mexico.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within Grama\nRidges’ plans or procedures. The item inspected and the inadequacy is described below:\n1. §192.12 Underground natural gas storage facilities.\n(a) ….\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n\n\n\nGrama Ridge’s written procedures for conducting operations and maintenance activities were\ninadequate to ensure safe operation of a pipeline facility. Specifically, GRS’s 1302-Wellhead\nSafety Inspections (Valve Testing Procedure) failed to require that the wing valve (wellhead\nisolation valve) be tested for isolation pursuant to American Petroleum Institute Recommended\nPractice 1171 (API RP 1171) (2015), Section 9.3.2 — Well Integrity Monitoring (Section 9.3.2).\nAPI RP 1171, Section 9.3.2 states in part that “[t]he Operator shall test the operation of the master\nvalve and wellhead pipeline isolation valve at least annually for proper function and ability to\nisolate the well.”\nDuring the inspection, PHMSA reviewed the Valve Testing Procedure and determined that the\nprocedure was inadequate. On page 2 of 3 of the procedure under “Test Procedure,” bullet 8 from\nthe top states “For reservoirs, fully function test all isolation valves and verify proper isolation of\nwell.” The procedure is not specific and did not discuss which valves were to be tested for isolation\ntesting as required by API RP 1171, Section 9.3.2. Upon discussions and review of records, it was\nfound that the downstream pipeline valve was being isolation tested and not the wing valve of the\nwellhead.\nTherefore, Gramma Ridge’s written procedures required by § 192.12(c) pursuant to meeting the\nrequirements of Section 9.3.2 were inadequate to ensure public safety. Gramma Ridge must revise\nits procedures 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.\n\n\n\nP.P.\nIt is requested (not mandated) that Grama Ridge Storage & Transportation, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 1-2024-044-NOA and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n12024044NOA_Closure Letter_06112024_(23-264022)_text.pdf\n\nVIA EMAIL TO: paul.bieniawski@enstorinc.com\nJune 11, 2024\nPaul Bieniawski\nChief Executive Officer\nGrama Ridge Storage and Transportation, LLC\na subsidiary of Enstor Gas, LLC\n10375 Richmond Avenue Suite 1900\nHouston, TX, 77042\nCPF 1-2024-044-NOA\nDear Mr. Bieniawski:\nFrom December, 4, 2023, to December 7, 2023, and on February 20, 2024, a representative from\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601\nof 49 United States Code, conducted an on-site pipeline safety inspection of Grama Ridge\nStorage & Transportation, LLC’s (Grama Ridge) procedures for Grama Ridge Storage Facility in\nEunice, New Mexico. As a result of the inspection, Grama Ridge was issued a Notice of\nAmendment on April 30, 2024, which proposed amendment of your procedures.\nGrama Ridge submitted its amended procedures on May 28, 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: Todd Cash < Todd.Cash@enstorinc.com >","truncated":false,"body_characters":8310}