{"operation":"document","citation":"CPF 12024047WL","title":"EGYPTIAN GAS STORAGE CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-06-07","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024047wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024047wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024047wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024047WL","body":"Warning Letter involving EGYPTIAN GAS STORAGE CORP. PHMSA's enforcement data identifies the cited regulation as 192.12(b)(1). The case was opened on 2024-06-07 and is reported as closed as of 2024-06-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024047WL_Warning Letter_06072024_(23-266213).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024047WL/12024047WL_Warning%20Letter_06072024_(23-266213).pdf\n\n12024047WL_Warning Letter_06072024_(23-266213)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024047WL/12024047WL_Warning%20Letter_06072024_(23-266213)_text.pdf\n\n12024047WL_Warning Letter_06072024_(23-266213)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: Robinson@RobinsonEngineering.net\nJune 7, 2024\nMr. Charles Robinson\nPresident\nEgyptian Gas Storage Corp\n1410 North Cullen Avenue\nEvansville, Indiana 47715\nCPF 1-2024-047-WL\nDear Mr. Robinson:\nFrom December 12 – 14, 2023, inspectors from the Illinois Department of Natural Resources\nacting as a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted an on-site\ninspection of Egyptian Gas Storage Corp’s (EGSC) Mills underground natural gas storage facility\nin Gallatin County, Illinois.\nAs a result of the inspection, 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.\nEgyptian failed to meet the provisions of API RP 1171, Section 6. Specifically, Egyptian failed to\nmaintain records of on-site safety meetings conducted during well workover activities as required\nby API RP 1171, Section 6.11.2.\n\n\n\nAPI RP1171, Section 6.11.2 requires operators to retain records for certain well workover\nactivities, including those for environmental, health, and safety considerations related to on-site\nsafety meetings.\nDuring the inspection, Egyptian provided to PHMSA copies of its safety manual and a record for\nwell workover activities for Holland-Willis #2 at its Mills storage field. The safety manual\naddressed jobsite safety inspections in Section 4, including a checklist for items to be covered,\nwhich included safety meetings. However, there were no records provided or discussed during the\ninspection that provided any details of jobsite safety meetings, including the specific well\nworkover documentation at Holland-Willis #2.\nTherefore, Egyptian failed to meet the provisions of API RP 1171, Section 6 by failing to maintain\nrecords of its on-site safety meetings as required by API RP1171, Section 6.11.2.\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\nEgyptian Gas Storage Corp being subject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2024-047-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\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":5857}