{"operation":"document","citation":"CPF 12025007WL","title":"ENBRIDGE GAS OHIO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-23","effective_on":null,"summary":"CLOSED warning letter citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025007wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025007wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025007wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025007WL","body":"Warning Letter involving ENBRIDGE GAS OHIO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2025-05-23 and is reported as closed as of 2025-05-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025007WL_Operator Response to Notice_06192025_(24-303764).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025007WL/12025007WL_Operator%20Response%20to%20Notice_06192025_(24-303764).pdf\n\n12025007WL_Warning Letter_05232025_(24-303764).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025007WL/12025007WL_Warning%20Letter_05232025_(24-303764).pdf\n\n12025007WL_Warning Letter_05232025_(24-303764)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025007WL/12025007WL_Warning%20Letter_05232025_(24-303764)_text.pdf\n\n12025007WL_Warning Letter_05232025_(24-303764)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL: michele.harradence@enbridge.com\nMay 23, 2025\nMs. Michele Harradence\nPresident and Chief Executive Officer\nEnbridge Gas Ohio\n500 Consumers Road\n1201 East 55th Street\nCleveland, Ohio 44103\nCPF 1-2025-007-WL\nDear Ms. Harradence:\nOn May 23, 2024, and from June 11 to June 13, 2024, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected Enbridge Gas Ohio’s (EGO) Stark-Summit Underground Natural Gas\nStorage in Stark, Ohio.\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(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\n\n\n\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nEGO failed to follow its manual of written procedures for conducting activities under § 192.12(b).1\nSpecifically, EGO failed to follow its Storage Integrity Management Plan (SIMP), Section 33.5.6\nWell Closure, during the plug and abandon of Well 1707 Serbian Church #3 which was performed\nin April and May 2023.\nEGO’s SIMP, Section 33.5.6 required that EGO correct deviations which may threaten isolation\nobjectives of the plug. It also required EGO to determine the location of groundwater and\nhydrocarbon bearing zones penetrated by the well, determine the condition of the well’s casing\nand cement through those zones, and prevent communication between those zones from the\nplugging operation.\nPrior to the plug & abandon of this well, the annulus between the 3.5-inch production casing and\nthe 5.5-inch intermediate casing had a pressure of 300 psi and gas sample analysis from 3/21/2023\nconfirmed it to be storage gas.\nDuring the inspection, the Daily Well Work Report pertaining to Well 1707 was reviewed. After\nthe installation of plug #1 and plug #2, the report noted on 4/19/2023 that the annulus had a\nconsistent pressure of 5 psi. EGO stated no annulus gas pressure was detected once plug #3 was\ninstalled from depth of 968 feet to 1311 feet. This information indicates that annulus gas pressure\nof 5 psi may be due to failure of plug #1 and plug #2 to achieve isolation from the storage\nformation. Failure of the plugs was not corrected prior to installation of plug #3 thereby allowing\nthe possibility of storage gas communication with formations below plug #3.\nAdditionally, EGO’s Gas Storage – Project Checklist, Project Type: Plug and Abandonment,\nsection 6.7.2 Storage Zone Isolation required checking the following:\nDoes the workplan include the condition of the well’s casing and cement across those zones,\n(utilizing available well and log records), to prevent communication between any of those\nduring and after plugging the well.\nEGO stated a cement bond log of well 1707 was not done, thereby not utilizing log records in\ndetermining the condition of the well’s cement across groundwater and hydrocarbon bearing\nzones.\nTherefore, EGO failed to follow its SIMP, Section 33.5.6 Well Closure.\n1 §192.12 Underground natural gas storage facilities.\n(a) . . .\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) . . .\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an aquifer reservoir for natural gas storage and was\nconstructed on or before July 18, 2017, must meet the provisions of API RP 1171 (incorporated by\nreference, see §192.7), sections 8, 9, 10, and 11, and paragraph (c) of this section, by January 18, 2018, and must\nmeet all provisions of paragraph (d) of this section by March 13, 2021.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6,\n2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,\nup to a maximum of $2,391,142 for a related series of violations. For violation occurring on or\nafter May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134\nper violation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\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\n• We advise you to correct the items) identified in this letter. Failure to do so will result in\nEnbridge Gas Ohio 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 1-2025-007-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":7960}