# CRANBERRY PIPELINE CORP (WV) — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

12026021NOA_Closure Letter_07022026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Closure%20Letter_07022026_(25-330072).pdf

12026021NOA_Closure Letter_07022026_(25-330072)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Closure%20Letter_07022026_(25-330072)_text.pdf

12026021NOA_Notice of Amendment_02242026_(25-330072).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026021NOA/12026021NOA_Notice%20of%20Amendment_02242026_(25-330072).pdf

12026021NOA_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

12026021NOA_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

12026021NOA_Notice of Amendment_02242026_(25-330072)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: bgray@dgoc.com
February 24, 2026
Bradley Gray
Executive VP/COO
Cranberry Pipeline Corporation
1800 Corporate Drive
Birmingham, AL 35242
CPF 1-2026-021-NOA
Dear Mr. Gray:
From August 12 through 14, 2025, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
Cranberry Pipeline Corporation’s (CPC)1 Heizer Creek Storage and Maxton underground natural
gas storage facilities (UNGSF) in Putnam and Raleigh Counties, West Virginia.
As a result of the inspection, PHMSA has identified an apparent inadequacy found within CPC’s
plans or procedures. The alleged inadequacy and proposed revision is described below:
1. § 192.12 Underground natural gas storage facilities.
Underground natural gas storage facilities (UNGSFs), as defined in § 192.3,
are not subject to any requirements of this part aside from this section.
(a) . . .
(c) Procedural manuals. Each operator of a UNGSF must prepare and
follow for each facility one or more manuals of written procedures for
conducting operations, maintenance, and emergency preparedness and
response activities under paragraphs (a) and (b) of this section. Each operator
must keep records necessary to administer such procedures and review and
update these manuals at intervals not exceeding 15 months, but at least once
each calendar year. Each operator must keep the appropriate parts of these
manuals accessible at locations where UNGSF work is being performed. Each
operator must have written procedures in place before commencing
operations or beginning an activity not yet implemented.
1 CPC is a subsidiary of Diversified Midstream LLC.



CPF 1-2026-021-NOA
CPC’s written procedures for conducting operations and maintenance activities were inadequate
to ensure safe operation of a pipeline facility in accordance with section 192.12(c). Specifically,
CPC failed to have procedures describing how it monitors for the presence of annular gas at 14
wells without an annulus monitoring port, as required by section 9.3.2 in API RP 1171 (1st edition).
Section 9.3.2 states that “[t]he operator shall monitor for presence of annular gas by measuring
and recording annular pressure and/or annular gas flow. The operator shall evaluate each annular
gas occurrence that exceeds operator- or regulatory-defined threshold levels determined from well
integrity evaluation and from risk assessment.”
During the inspection, CPC identified that monitoring of annulus pressure or flow was addressed
in the following documents:
• Document No. PR-A-05, Storage Integrity Management Plan, Rev-1 (02/01/2025). Section
8.3.4 stated that CPC “shall monitor for presence of annular gas by measuring and
recording annular pressure and/or annular gas flow. [CPC] should test wellhead seals when
annulus pressure is detected and where injectable packing and/or test ports are present.”
• Document No. PR-A-11, O&M Procedure, UNGSF Annular Pressure Recording, section
8, Rev-1 (02/01/2025). Section 8.2.3 stated that “[i]f annular pressure cannot be obtained,
note the reason pressure cannot be obtained (ex. no valve, valve left open, inaccessible,
inoperable, etc.) and skip to 8.4.” Section 8.4.1 stated that “[i]f there is no annular valve
and/or the annulus is open, visually, and audibly check for gas flow from the annulus.”
However, 14 of the 16 inspected wells did not have annulus valves and piping extensions to
monitor the annulus pressure or flow. During the inspection, CPC stated that it conducts a wellhead
ground-level leakage survey with a calibrated gas detection instrument at these locations.
However, there was no procedure to detail this monitoring practice or specify the operator-defined
investigation/remediation gas concentration threshold at the 14 wells without an annulus
monitoring port.
Therefore, CPC’s written procedures for conducting operations and maintenance activities were
inadequate to ensure safe operation of a pipeline facility in accordance with section 192.12(c).
PHMSA proposes that CPC amend its procedures to include leakage surveys as a method to
monitor for the presence of annular gas at each well, and define investigation/remediation gas
concentration thresholds.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part
of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. Be advised that all material you submit
in response to this enforcement action is subject to being made publicly available. If you believe
Page 2 of 3



CPF 1-2026-021-NOA
that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §
552(b), along with the complete original document you must provide a second copy of the
document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under 49 CFR § 190.211. If you do not respond within 30
days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in
this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged
in this Notice without further notice to you and to issue an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting
this Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Cranberry Pipeline Corporation maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment (preparation/
revision of plans, procedures) and submit the total to the Director, Eastern Region, Office of
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 1-2026-021-NOA and, for each document you submit,
please provide a copy in electronic format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
Page 3 of 3

12026021NOA_Closure Letter_07022026_(25-330072)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, New Jersey 08628
609.771.7800
VIA ELECTRONIC MAIL TO: bgray@dgoc.com
July 2, 2026
Bradley Gray
Executive VP/COO
Cranberry Pipeline Corporation
1800 Corporate Drive
Birmingham, AL 35242
RE: CPF 1-2026-021-NOA
Dear Mr. Gray:
From August 12 through 14, 2025, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted
an inspection of Cranberry Pipeline Corporation’s (CPC) Heizer Creek Storage and Maxton
underground natural gas storage facilities (UNGSF) procedures in Putnam and Raleigh Counties,
West Virginia. As a result of the inspection, CPC was issued a Notice of Amendment on February
24, 2026, which proposed amendment of your procedures.
CPC submitted its amended procedures on March 26, 2026 and supplemented its response on May
26, 2026 . My staff has reviewed the amended procedures, and it appears that the inadequacies
outlined in this Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Shawn Bailey, VP Midstream Operations (Compliance), CPC, jsbailey@dgoc.com
Billy Culbertson, Compliance Manager, CPC, bculbertson@dgoc.com
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