{"operation":"document","citation":"CPF 12025023NOA","title":"LOUISVILLE GAS & ELECTRIC CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-01","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025023noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025023noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025023noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025023NOA","body":"Notice of Amendment involving LOUISVILLE GAS & ELECTRIC CO. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2025-07-01 and is reported as closed as of 2025-09-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025023NOA_Closure Letter_09192025_(24-296374).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025023NOA/12025023NOA_Closure%20Letter_09192025_(24-296374).pdf\n\n12025023NOA_Closure Letter_09192025_(24-296374)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025023NOA/12025023NOA_Closure%20Letter_09192025_(24-296374)_text.pdf\n\n12025023NOA_Notice of Amendment_07012025_(24-296374).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025023NOA/12025023NOA_Notice%20of%20Amendment_07012025_(24-296374).pdf\n\n12025023NOA_Notice of Amendment_07012025_(24-296374)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025023NOA/12025023NOA_Notice%20of%20Amendment_07012025_(24-296374)_text.pdf\n\n12025023NOA_Operator Response to Notice_07292025_(24-296374).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025023NOA/12025023NOA_Operator%20Response%20to%20Notice_07292025_(24-296374).pdf\n\n12025023NOA_Notice of Amendment_07012025_(24-296374)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: John.Crockett@lge-ku.com\nJuly 1, 2025\nMr. John R. Crockett III\nPresident and CEO\nLouisville Gas & Electric Company\n220 West Main Street\nLouisville, Kentucky 40202\nCPF 1-2025-023-NOA\nDear Mr. Crockett:\nFrom September 24 through September 26, 2024 and from October 1 through October 2, 2024, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant\nto Chapter 601 of 49 United States Code (U.S.C.) inspected Louisville Gas & Electric Company’s\n(LG&E) underground natural gas storage facility procedures for the Magnolia Upper Storage Field\nin Larue County, Kentucky.\nAs a result of the inspection, PHMSA has identified apparent inadequacies found within LG&E’s\nplans or procedures. The items inspected and the alleged inadequacies and proposed revisions are\ndescribed 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\nLG&E’s written procedures for conducting operations and maintenance activities were inadequate\nto provide for safe operation of a pipeline facility in accordance with section 192.12(c).\nSpecifically, LG&E’s Management of Change (MOC) process failed to include a training\nrequirement for underground storage operating personnel prior to the implementation of\nprocedural changes as required by section 11.12.2 in American Petroleum Institute’s\nRecommended Practice 1171 (2015) (API RP 1171), which is incorporated by reference in section\n192.12(b).\nSection 11.12.2 states that “[w]henever changes are made to the operating procedures specified in\n11.3, operating personnel shall be notified and trained as necessary in the changes and training\ndocumented before operating storage wells and reservoirs.”\nDuring the inspection, PHMSA reviewed LG&E’s Gas Approved Operating Policies MOC\n(GAOP-MOC-001) (01/01/2024). Section 6.6. in GAOP-MOC-001 required that all affected\nparties be notified of procedural changes before implementation. However, the section 6.6\nrequirement to train personnel prior to implementation applied only to gas controllers and not to\nunderground storage operating personnel.\nTherefore, LG&E’s written procedures for conducting operations and maintenance activities were\ninadequate to provide for safe operation of a pipeline facility in accordance with section 192.12(c).\nLG&E must revise its procedures to address the inadequacy outlined above.\n2. § 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.\nLG&E’s written procedures for conducting operations and maintenance activities were inadequate\nto provide for safe operation of a pipeline facility in accordance with section 192.12(c).\nSpecifically, LG&E’s Gas Operation, Maintenance, and Inspection Manual Monitoring Gas\nStorage Wells Annular Areas (GOMI-SO-MA-004) (01/01/2024), section 10.2.3, failed to\nadequately define the annular gas occurrence threshold level that triggers an evaluation for wells\nwithout annular ports as required by section 9.3.2 in API RP 1171, which is incorporated by\nreference in section 192.12(b).\n\n\n\nSection 9.3.2 states, in part, that “[t]he operator shall evaluate each annular gas occurrence that\nexceeds operator- or regulatory-defined threshold levels determined from well integrity evaluation\nand from risk assessment.”\nDuring the inspection, PHMSA reviewed LG&E’s GOMI-SO-MA-004, sections 10.2.3 and\n10.2.4. For wells without annular ports, LG&E stated it will evaluate the annular leakage if it\n“creates an unsafe work area,” but it failed to include quantifiable criteria to define that phrase.\nSection 9.3.2 in API RP 1171 requires that operators establish a quantitative threshold level\ndetermined from a well integrity evaluation and from risk assessment. In addition, LG&E failed\nto provide details about the required investigation and remediation referenced in section 10.2.4.\nTherefore, LG&E’s written procedures for conducting operations and maintenance activities were\ninadequate to provide for safe operation of a pipeline facility in accordance with section 192.12(c).\nLG&E must revise its procedures to address the inadequacies outlined above.\nResponse to this Notice\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(b), along with the complete original document you must provide a second copy of the\ndocument 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 section 190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your plans\nor procedures are found inadequate as alleged in this Notice, you may be ordered to amend your\nplans or procedures to correct the inadequacies (49 CFR. § 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 Louisville Gas & Electric 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.\n\n\n\nIn correspondence concerning this matter, please refer to CPF 1-2025-023-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\n12025023NOA_Closure Letter_09192025_(24-296374)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: John.Crockett@lge-ku.com\nSeptember 19, 2025\nMr. John Crockett\nPresident and CEO\nLouisville Gas & Electric Co\n820 W. Broadway, PO Box 32030\nLouisville, Kentucky 40202\nRE: CPF 1-2025-023-NOA\nDear Mr. Crockett:\nFrom September 24, 2024 to September 26, 2024 and from October 1, 2024 to October 2, 2024, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant\nto Chapter 601 of 49 United States Code (U.S.C.) inspected Louisville Gas & Electric’s (LG&E)\nprocedures for Magnolia Upper Storage Field in Larue County, Kentucky. As a result of the\ninspection, LG&E was issued a Notice of Amendment on July 1, 2025, which proposed\namendment of your procedures.\nLG&E submitted its amended procedures on July 29, 2025. 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","truncated":false,"body_characters":10478}