{"operation":"document","citation":"CPF 12024046NOA","title":"CITIZENS GAS UTIL DIST — 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-12024046noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024046noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024046noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024046NOA","body":"Notice of Amendment involving CITIZENS GAS UTIL DIST. 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 2024-06-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024046NOA_Closure Letter_06142024_(23-263996).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024046NOA/12024046NOA_Closure%20Letter_06142024_(23-263996).pdf\n\n12024046NOA_Closure Letter_06142024_(23-263996)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024046NOA/12024046NOA_Closure%20Letter_06142024_(23-263996)_text.pdf\n\n12024046NOA_Notice of Amendment_05072024_(23-263996).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024046NOA/12024046NOA_Notice%20of%20Amendment_05072024_(23-263996).pdf\n\n12024046NOA_Notice of Amendment_05072024_(23-263996)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024046NOA/12024046NOA_Notice%20of%20Amendment_05072024_(23-263996)_text.pdf\n\n12024046NOA_Notice of Amendment_05072024_(23-263996)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 7, 2024\nMr. Greg Bell\nGeneral Manager\nCitizens Gas Util Dist\nHighway 27, South\nPO BOX 320\nHelenwood, Tennessee 37755\nCPF 1-2024-046-NOA\nDear Mr. Bell:\nFrom October 23 Through October 27, 2023 of the onsite inspection, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected Citizens Gas Util Dist (Citizens) procedures for Indian\nCreek Underground Natural Gas Storage in Morgan County, Tennessee.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within\nCitizens’ 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.\nCitizens’ construction procedures required by § 192.12(b)(1) were inadequate. Specifically,\nCitizens failed to have procedures that ensure that ground waters and other possible producing\nhorizons are properly sealed to ensure there is no migration of gas, oil or brine water to other zones\n\n\n\npursuant to API RP 1171, Sections 11.2.1 (Section 11.2.1) and 6.7.1 (Section 6.7.1).\nSection 11.2.1 states in part “The operator shall develop and follow procedures for the\nconstruction, operation, and maintenance of natural gas storage wells and reservoirs to establish\nand maintain functional integrity.” Section 6.7.1 states “The operator shall design a well\nabandonment for long-term isolation of the storage zone in order to prevent fluid flow between the\nstorage zone and any other penetrated zone and the surface.”\nDuring the inspection, PHMSA reviewed Citizens’ records and procedures on the Plug and\nAbandonment of wells 695 and 696. Citizens lacked a procedure addressing Section 6.7.1.\nCitizens did provide records that showed the that the primary production piping was cemented\nfrom bottom to surface inside the piping to plug the well. However, there was no evidence\nprovided, such as Gamma Ray/Neutron logs run, to determine possible zones that would produce\noil, gas, or water. Similarly, there were no Casing Inspection Logs to ensure the well piping\nintegrity or a Cement Bond Log to determine if the cement on the outside of the production piping\nwas adequate.\nTherefore, Citizens’ written procedures required by § 192.12(b)(1) pursuant to meeting the\nrequirements of API 1171 Section 6.7.1 were inadequate. Citizens must revise its procedures to\naddress how it will comply with Section 6.7.1.\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\nIt is requested (not mandated) that Citizens Gas Util Dist 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 1-2024-046-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\n\n12024046NOA_Closure Letter_06142024_(23-263996)_text.pdf\n\nVIA EMAIL TO: citgasb@highland.net\nJune 14, 2024\nMr. Greg Bell\nGeneral Manager\nCitizens Gas Util Dist\nHighway 27, South\nPO BOX 320\nHelenwood, Tennessee 37755\nCPF 1-2024-046-NOA\nDear Mr. Bell:\nFrom October, 23, 2023, to October 27, 2023, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\ninspected Citizens’ Gas Util Dist. (Citizens) procedures for Indian Creek Underground Natural\nGas Storage in Morgan County, Tennessee. As a result of the inspection, Citizens was issued a\nNotice of Amendment on April 30, 2024, which proposed amendment of your procedures.\nCitizens submitted its amended procedures on June 12, 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: Chris Pierce <cpierce@citizensgastn.com>","truncated":false,"body_characters":7642}