{"operation":"document","citation":"CPF 12026021NOA","title":"CRANBERRY PIPELINE CORP (WV) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-02-24","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026021noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026021noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026021noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026021NOA","body":"Notice of Amendment involving CRANBERRY PIPELINE CORP (WV). PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2026-02-24 and is reported as closed as of 2026-07-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026021NOA_Closure Letter_07022026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Closure%20Letter_07022026_(25-330072).pdf\n\n12026021NOA_Closure Letter_07022026_(25-330072)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Closure%20Letter_07022026_(25-330072)_text.pdf\n\n12026021NOA_Notice of Amendment_02242026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Notice%20of%20Amendment_02242026_(25-330072).pdf\n\n12026021NOA_Notice of Amendment_02242026_(25-330072)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Notice%20of%20Amendment_02242026_(25-330072)_text.pdf\n\n12026021NOA_Operator Response to Notice_03242026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Operator%20Response%20to%20Notice_03242026_(25-330072).pdf\n\n12026021NOA_Notice of Amendment_02242026_(25-330072)_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\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: bgray@dgoc.com\nFebruary 24, 2026\nBradley Gray\nExecutive VP/COO\nCranberry Pipeline Corporation\n1800 Corporate Drive\nBirmingham, AL 35242\nCPF 1-2026-021-NOA\nDear Mr. Gray:\nFrom August 12 through 14, 2025, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nCranberry Pipeline Corporation’s (CPC)1 Heizer Creek Storage and Maxton underground natural\ngas storage facilities (UNGSF) in Putnam and Raleigh Counties, West Virginia.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within CPC’s\nplans or procedures. The alleged inadequacy and proposed revision is described below:\n1. § 192.12 Underground natural gas storage facilities.\nUnderground natural gas storage facilities (UNGSFs), as defined in § 192.3,\nare not subject to any requirements of this part aside from this section.\n(a) . . .\n(c) Procedural manuals. Each operator of a UNGSF must prepare and\nfollow for each facility one or more manuals of written procedures for\nconducting operations, maintenance, and emergency preparedness and\nresponse activities under paragraphs (a) and (b) of this section. Each operator\nmust keep records necessary to administer such procedures and review and\nupdate these manuals at intervals not exceeding 15 months, but at least once\neach calendar year. Each operator must keep the appropriate parts of these\nmanuals accessible at locations where UNGSF work is being performed. Each\noperator must have written procedures in place before commencing\noperations or beginning an activity not yet implemented.\n1 CPC is a subsidiary of Diversified Midstream LLC.\n\n\n\nCPF 1-2026-021-NOA\nCPC’s written procedures for conducting operations and maintenance activities were inadequate\nto ensure safe operation of a pipeline facility in accordance with section 192.12(c). Specifically,\nCPC failed to have procedures describing how it monitors for the presence of annular gas at 14\nwells without an annulus monitoring port, as required by section 9.3.2 in API RP 1171 (1st edition).\nSection 9.3.2 states that “[t]he operator shall monitor for presence of annular gas by measuring\nand recording annular pressure and/or annular gas flow. The operator shall evaluate each annular\ngas occurrence that exceeds operator- or regulatory-defined threshold levels determined from well\nintegrity evaluation and from risk assessment.”\nDuring the inspection, CPC identified that monitoring of annulus pressure or flow was addressed\nin the following documents:\n• Document No. PR-A-05, Storage Integrity Management Plan, Rev-1 (02/01/2025). Section\n8.3.4 stated that CPC “shall monitor for presence of annular gas by measuring and\nrecording annular pressure and/or annular gas flow. [CPC] should test wellhead seals when\nannulus pressure is detected and where injectable packing and/or test ports are present.”\n• Document No. PR-A-11, O&M Procedure, UNGSF Annular Pressure Recording, section\n8, Rev-1 (02/01/2025). Section 8.2.3 stated that “[i]f annular pressure cannot be obtained,\nnote the reason pressure cannot be obtained (ex. no valve, valve left open, inaccessible,\ninoperable, etc.) and skip to 8.4.” Section 8.4.1 stated that “[i]f there is no annular valve\nand/or the annulus is open, visually, and audibly check for gas flow from the annulus.”\nHowever, 14 of the 16 inspected wells did not have annulus valves and piping extensions to\nmonitor the annulus pressure or flow. During the inspection, CPC stated that it conducts a wellhead\nground-level leakage survey with a calibrated gas detection instrument at these locations.\nHowever, there was no procedure to detail this monitoring practice or specify the operator-defined\ninvestigation/remediation gas concentration threshold at the 14 wells without an annulus\nmonitoring port.\nTherefore, CPC’s written procedures for conducting operations and maintenance activities were\ninadequate to ensure safe operation of a pipeline facility in accordance with section 192.12(c).\nPHMSA proposes that CPC amend its procedures to include leakage surveys as a method to\nmonitor for the presence of annular gas at each well, and define investigation/remediation gas\nconcentration thresholds.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof 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 submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nPage 2 of 3\n\n\n\nCPF 1-2026-021-NOA\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 49 CFR § 190.211. If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting\nthis Notice, 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 Cranberry Pipeline Corporation maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/\nrevision of plans, procedures) and submit the total to the Director, Eastern Region, Office of\nPipeline Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2026-021-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nPage 3 of 3\n\n12026021NOA_Closure Letter_07022026_(25-330072)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, New Jersey 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: bgray@dgoc.com\nJuly 2, 2026\nBradley Gray\nExecutive VP/COO\nCranberry Pipeline Corporation\n1800 Corporate Drive\nBirmingham, AL 35242\nRE: CPF 1-2026-021-NOA\nDear Mr. Gray:\nFrom August 12 through 14, 2025, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted\nan inspection of Cranberry Pipeline Corporation’s (CPC) Heizer Creek Storage and Maxton\nunderground natural gas storage facilities (UNGSF) procedures in Putnam and Raleigh Counties,\nWest Virginia. As a result of the inspection, CPC was issued a Notice of Amendment on February\n24, 2026, which proposed amendment of your procedures.\nCPC submitted its amended procedures on March 26, 2026 and supplemented its response on May\n26, 2026 . My staff has reviewed the amended procedures, and it appears that the inadequacies\noutlined in this Notice of Amendment have been corrected.\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, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Shawn Bailey, VP Midstream Operations (Compliance), CPC, jsbailey@dgoc.com\nBilly Culbertson, Compliance Manager, CPC, bculbertson@dgoc.com","truncated":false,"body_characters":9925}