{"operation":"document","citation":"CPF 320171005M","title":"PINE PRAIRIE ENERGY CENTER LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-05","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(4), 192.605(b)(8), 192.605(c)(1), 192.605(c)(2), 192.605(c)(4), 192.616(c), 192.711(b)(2), 192.911(c), 192.911(k), 192.917(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320171005M","body":"Notice of Amendment involving PINE PRAIRIE ENERGY CENTER LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(4),  192.605(b)(8),  192.605(c)(1),  192.605(c)(2),  192.605(c)(4),  192.616(c),  192.711(b)(2),  192.911(c),  192.911(k),  192.917(b). The case was opened on 2017-04-05 and is reported as closed as of 2018-03-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320171005M_Closure Letter_03022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171005M/320171005M_Closure%20Letter_03022018.pdf\n\n320171005M_Closure Letter_03022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171005M/320171005M_Closure%20Letter_03022018_text.pdf\n\n320171005M_Notice of Amendment_04052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171005M/320171005M_Notice%20of%20Amendment_04052017.pdf\n\n320171005M_Notice of Amendment_04052017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171005M/320171005M_Notice%20of%20Amendment_04052017_text.pdf\n\n320171005M_Operator Response to Notice_05082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171005M/320171005M_Operator%20Response%20to%20Notice_05082017.pdf\n\n320171005M_Notice of Amendment_04052017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 5, 2017\nMr. Dean Gore\nVice President Environmental and Regulatory Compliance\nPAA Natural Gas Storage, LLC\n333 Clay Street\nSuite 1600\nHouston, TX, 77002\nCPF 3-2017-1005M\nDear Mr. Gore:\nOn September 19-23 and October 18, 2016, representatives of the Michigan Public Service\nCommission (MIPSC), acting as an interstate agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nPAA Natural Gas Storage, LLC’s procedures for Operation and Maintenance and Integrity\nManagement at the Bluewater Columbus Compressor Station in Columbus, Michigan.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPAA Natural Gas Storage, LLC (PAA) plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and Subpart M of this part.\n\n\n\n§192.616 Public Awareness\n(c) The operator must follow the general program recommendations, including\nbaseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why compliance\nwith all or certain provisions of the recommended practice is not practicable and\nnot necessary for safety.\nPAA’s procedures did not include all the baseline and supplemental requirements of API\nRP 1162. Specifically, PAA’s procedures did not include the requirement to deliver site\nspecific information to residents near storage facilities.\n2. §192.605(b)(1) – See above\n§192.711 Transmission lines: General requirements for repair procedures.\n(b) Permanent repairs. An operator must make permanent repairs on its pipeline\nsystem according to the following:\n(2) Integrity management repairs: When an operator discovers a condition on a\npipeline covered under Subpart O - Gas Transmission Pipeline Integrity\nManagement, the operator must remediate the condition as prescribed by §\n192.933(d).\nPAA did not have StrongBack® composite wraps listed in the operations and maintenance\n(O&M) manual as a company approved repair method. PAA used a StrongBack®\ncomposite wrap on October 5, 2010 to make an integrity management repair. PAA’s\nO&M procedure 192.711, Section 4.1.4 stated, \"Approved repair methods include: ... An\napproved pipe wrap system such as PermaWrapTM or Clock Spring®.\" PAA staff\nindicated that StrongBack® was specified for the Bluewater ILI (inline inspection)\nanomaly repair in 2010; however, they were unable to provide documentation that it had\nbeen reviewed and approved as the other repair methods listed in the O&M manual.\nAdditionally, PAA’s O&M manual did not include procedures on how to repair dents with\nmetal loss that are immediate repair conditions per §192.933(d)(1)(ii). PAA’s O&M\n192.711 Section 4.4 only addressed dents with stress concentration, but not dents with\nmetal loss.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n2\n\n\n\n(4) Gathering of data needed for reporting incidents under Part 191 of this chapter in\na timely and effective manner.\nPAA’s procedures for gathering data for reporting incidents did not include the Part 191\nreporting criterion for gas loss (i.e. three million cubic feet or more) in Section 6.05(c)\nSection 1.9 of the O&M manual. Additionally, Section 4.5 contained Michigan Intrastate\nreporting thresholds which do not pertain to this facility and the address for MIPSC office\nwas incorrect.\n4. §192.605(b) – See Above\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedure when deficiencies are found.\nPAA’s procedures for periodically reviewing the work done by operator personnel did not\ndefine how often this would be performed, nor did the procedures describe how the\nperiodic review would be documented.\n5. §192.605 Procedural manual for operations, maintenance, and emergencies\n(c) Abnormal operation. For transmission lines, the manual required by paragraph\n(a) of this section must include procedures for the following to provide safety when\noperating design limits have been exceeded:\n(1) Responding to, investigating, and correcting the cause of:\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating\nlimits;\n(iii) Loss of communications;\n(iv) Operation of any safety device; and,\n(v) Any other foreseeable malfunction of a component, deviation from normal\noperation, or personnel error which may result in a hazard to persons or\nproperty.\nPAA’s O&M manual for abnormal operations did not include procedures to respond,\ninvestigate and correct the cause of an unintended valve closure, malfunction of pipeline\ncomponents, and personnel error.\n3\n\n\n\n6. §192.605(c) – See above\n(2) Checking variations from normal operation after abnormal operation has ended\nat sufficient critical locations in the system to determine continued integrity and\nsafe operation.\nPAA’s O&M manual for abnormal operations did not include procedures to check\nvariations from normal operation after abnormal operation has ended at sufficient critical\nlocations in the system to determine continued integrity and safe operation. The procedure\ndid not define how PAA would determine the critical locations and when the checks would\nbe done.\n7. §192.605(c) – See above\n(4) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking corrective\naction where deficiencies are found.\nPAA’s procedures for periodically reviewing the response of operating personnel to\ndetermine the effectiveness of the procedures does not refer to the correct form to\ndocument this task. PAA’s O&M manual, section 605(c) 1.9 refers to the Plains Incident\nInvestigation Form, rather than the Abnormal Operations Report, Form 218.\n8. §192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see §\n192.907) and evolves into a more detailed and comprehensive integrity management\nprogram, as information is gained and incorporated into the program. An operator\nmust make continual improvements to its program. The initial program framework\nand subsequent program must, at minimum, contain the following elements. (When\nindicated, refer to ASME/ANSI B31.8S (incorporated by reference, see § 192.7) for\nmore detailed information on the listed element.)\n(c) An identification of threats to each covered pipeline segment, which must include\ndata integration and a risk assessment. An operator must use the threat identification\nand risk assessment to prioritize covered segments for assessment (§ 192.917) and to\nevaluate the merits of additional preventive and mitigative measures (§ 192.935) for\neach covered segment.\n§192.917 How does an operator identify potential threats to pipeline integrity and use\nthe threat identification in its integrity program?\n(b) Data gathering and integration. To identify and evaluate the potential threats to\na covered pipeline segment, an operator must gather and integrate existing data\n4\n\n\n\nand information on the entire pipeline that could be relevant to the covered\nsegment. In performing this data gathering and integration, an operator must\nfollow the requirements in ASME/ANSI B31.8S, section 4. At a minimum, an\noperator must gather and evaluate the set of data specified in Appendix A to\nASME/ANSI B31.8S, and consider both on the covered segment and similar non-\ncovered segments, past incident history, corrosion control records, continuing\nsurveillance records, patrolling records, maintenance history, internal inspection\nrecords and all other conditions specific to each pipeline.\nPAA’s procedures for integrity management did not include the data elements listed in\nASME B31.8S Appendix A.6.2 for equipment threats. Additionally, the procedures did\nnot describe how PAA would document the data gathering and integration.\n9. §192.911 (See Above)\n(k) A management of change process as outlined in ASME/ANSI B31.8S, section 11.\nPAA’s procedures for management of change did not include requirements for\ndocumenting minor changes within the integrity management plan. AMSE B31.8S\nSection 11(a) states that, “These procedures should be flexible enough to accommodate\nboth major and minor changes, and must be understood by the personnel that use them.”.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 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 §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\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin [number of days] days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed\nin your amended procedures, this enforcement action will be closed.\n5\n\n\n\nIt is requested (not mandated) that PAA Natural Gas Storage, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2017-1005M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n6\n\n\n\nResponse Options for Pipeline Operators in Enforcement Proceedings\nThe provisions of 49 C.F.R. Part 190, Subpart B (§§ 190.201–190.243) govern response\noptions to enforcement actions initiated by a Regional Director, Pipeline and Hazardous\nMaterials Safety Administration (PHMSA). You are advised to consult Subpart B for further\ninformation regarding your rights and responsibilities in such proceedings.\nBe advised that all material submitted by a respondent in response to an enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you\nbelieve 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).\nI. Procedures for Responding to a NOTICE OF PROBABLE VIOLATION:\nWithin 30 days of receipt of a Notice of Probable Violation, the respondent shall\nrespond directly to the Regional Director who issued the Notice in the following way:\na. When the Notice contains a PROPOSED CIVIL PENALTY*-- you have 4\nOptions\n1. 2. You may decide NOT to contest the allegations.\nIf you are not contesting any violations alleged in the Notice, pay the\nproposed civil penalty according to the details outlined in Paragraph\nIX below and advise the Regional Director of the payment in\nwriting. This authorizes PHMSA to issue an order making findings\nof violation and upon confirmation that the payment has been\nreceived PHMSA will close the case (subject to any outstanding\ncompliance order). Payment terms are outlined below;\nYou may decide to CONTEST the allegations with an EXPLANATION\nIf you are not contesting any violations alleged in the Notice but\nwish to submit written explanations, information, including the effect\nof the proposed civil penalty on your ability to continue in business,\nor other materials you believe warrant mitigation of the civil penalty,\nyou may submit such materials. This authorizes PHMSA to make\nfindings and to issue a Final Order. PHMSA will consider your\nsubmission in deciding whether to reduce or eliminate the penalty\namount proposed in the Notice. Under 49 United States Code, §\n60122, you are subject to a civil penalty not to exceed $205,638 per\nviolation per day the violation persists up to a maximum of\n$2,056,380 for a related series of violations. For violations\noccurring prior to August 1, 2016, the maximum civil penalty may\nnot exceed $200,000 per violation per day, with a maximum penalty\n7\n\n\n\n3. 4. not to exceed $2,000,000 for a related series of violations. Refer to\n49 C.F.R. § 190.225 for assessment considerations upon which civil\npenalties are based;\nYou may CONTEST the allegations and elect NOT to have a hearing\nIf you are contesting one or more of the items in the Notice but are\nnot requesting an oral hearing, submit a written response to the\nallegations and/or seek elimination or mitigation of the proposed\ncivil penalty; or\nYou may CONTEST the allegations and ask FOR A HEARING\nRequest a hearing as described in Paragraph III below to contest the\nallegations and/or proposed assessment of a civil penalty.\nb. When the Notice contains a PROPOSED COMPLIANCE ORDER*-- you\nhave 4 Options\n1. 2. 3. 4. You may decide NOT to contest the allegations\nIf you are not contesting the proposed compliance order and the\nalleged violations associated with it, notify the Regional Director\nthat you intend to take the actions in the proposed compliance order;\nYou may decide to CONTEST the allegations with an EXPLANATION\nIf you are not contesting the compliance order but wish to submit\nwritten explanations, information, or other materials you believe\nwarrant modification of the proposed compliance order in whole or\nin part, or you seek clarification of the terms of the proposed\ncompliance order, you may submit such materials. This authorizes\nPHMSA to make findings and issue a compliance order;\nYou may CONTEST the allegations and elect NOT to have a hearing\nIf you are contesting the proposed compliance order but are not\nrequesting an oral hearing, submit written explanations, information,\nor other materials in answer to the allegations in the Notice and\nstating your reasons for objecting to the proposed compliance order\nitems in whole or in part; or\nYou may CONTEST the allegations and ask FOR A HEARING\nRequest a hearing as described in Paragraph III below to contest the\nallegations and/or proposed compliance order items.\n8\n\n\n\nII. III. c. When the Notice contains a WARNING ITEM --\nNo written response is required. The respondent is warned that if it does\nnot take appropriate action to correct these items, enforcement action will\nbe taken if a subsequent inspection reveals a violation.\n* Failure of the respondent to respond to the Notice within 30 days of receipt\nconstitutes a waiver of the right to contest the allegations in the Notice and\nauthorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin the Notice without further notice to the respondent and to issue a Final Order.\nProcedures for Responding to a NOTICE OF AMENDMENT*--\nWithin 30 days of receipt of a Notice of Amendment, the respondent shall respond to\nthe Regional Director who issued the Notice in the following way:\na. b. c. d. If you are not contesting the Notice, notify the Regional Director of your\nplans to address the inadequacies identified in the Notice and/or submit\ncopies of your amended procedures;\nIf you are not contesting the Notice but wish to submit written explanations,\ninformation, or other materials you believe warrant modification of the\nNotice of Amendment in whole or in part, or you seek clarification of the\nterms of the Notice of Amendment, you may submit such materials. This\nauthorizes PHMSA to make findings and issue an Order Directing\nAmendment;\nIf you are contesting the Notice of Amendment but are not requesting an oral\nhearing, submit written explanations, information, or other materials in\nanswer to the allegations in the Notice and stating your reasons for objecting\nto the Notice of Amendment items in whole or in part; or\nRequest a hearing as described below to contest the allegations in the Notice.\n* Failure of the respondent to respond to the Notice within 30 days of receipt\nconstitutes a waiver of the right to contest the allegations in the Notice and\nauthorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin the Notice without further notice to the respondent and to issue a Final Order.\nProcedure for Requesting a Hearing\nA request for a hearing must be in writing and accompanied by a statement of the\nissues that the respondent intends to raise at the hearing. The issues may relate to the\nregulatory requirement or factual basis for the allegations, to the proposed compliance\n9\n\n\n\norder, or to the proposed civil penalty amount. Refer to 49 C.F.R. § 190.225 for\nassessment considerations upon which civil penalties are based. A respondent's failure\nto specify an issue may result in waiver of the right to raise that issue at the hearing.\nThe respondent's request must also indicate whether or not respondent will be\nrepresented by counsel at the hearing. Failure to request a hearing in writing within 30\ndays of receipt of a Notice waives the right to a hearing. In addition, if the amount of\nthe proposed civil penalty or the proposed corrective action is less than $25,000, the\nhearing will be held by telephone, unless the respondent submits a written request for\nan in-person hearing. Complete hearing procedures can be found at 49 C.F.R. §\n190.211.\nIV. Extensions of Time\nAn extension of time to prepare an appropriate response to a Notice may be granted, at\nthe agency's discretion, following submittal of a written request to the Regional\nDirector. The request must indicate the amount of time needed and the reasons for the\nextension. The request must be submitted within 30 days of receipt of the Notice.\nV. Case File\nCase file documents are available to the respondent of enforcement proceedings per 49\nC.F.R. § 190.209. Documents in the case file are provided upon request, if prepared.\nVI. Freedom of Information Act\nAny material provided to PHMSA by the respondent, and materials prepared by\nPHMSA including the Notice and any order issued in this case, may be considered\npublic information and subject to disclosure under the Freedom of Information Act\n(FOIA). If you believe the information you are providing is security sensitive,\nprivileged, confidential or may cause your company competitive disadvantages, please\nclearly identify the material and provide justification why you believe the documents,\nor portions of a document, qualify for confidential treatment under 5 U.S.C. 552(b). If\nwe receive a request for your material, we will notify you if PHMSA, after reviewing\nthe materials and your provided justification, determines that withholding the materials\ndoes not meet any exemption provided under the FOIA. You may appeal the agency's\ndecision to release material under the FOIA at that time. Your appeal will stay the\nrelease of those materials until a final decision is made.\nVII. The Rights of Small Entities to Enforcement Fairness and Policy Against\nRetaliation\n10\n\n\n\nThe Department of Transportation has a policy regarding the rights of small entities to\nregulatory enforcement fairness and an explicit policy against retaliation for exercising\nthese rights. Our objective is to ensure a fair regulatory enforcement environment. The\nUS Small Business Administration provides standards for small business classifications\nfor Pipeline Transportation in the North American Industry Classification System\nCodes (NAICS). If you are a small business and would like PHMSA to consider your\nclassification as such in this enforcement action, please respond accordingly.\nMoreover, if you feel you have been treated unfairly or unprofessionally, you may\ncontact the PHMSA Office of Chief Counsel. You also have the right to contact the\nSmall Business Administration’s National Ombudsman at 1-888-REGFAIR or\nwww.sba.gov/ombudsman regarding the fairness of the compliance and enforcement\nactivities of this agency.\nThe Department of Transportation strictly forbids retaliatory acts by its employees. As\nsuch, you should feel confident that you will not be penalized for expressing your\nconcerns about compliance and enforcement activities.\nVIII. Small Business Regulatory Enforcement Fairness Act Information\nThe Small Business and Agricultural Regulatory Enforcement Ombudsman and 10\nRegional Fairness Boards were established to receive comments from small businesses\nabout federal agency enforcement actions. The Ombudsman will annually evaluate the\nenforcement activities and rate each agency's responsiveness to small business. If you\nwish to comment on the enforcement actions of the Pipeline and Hazardous Materials\nSafety Administration, call 1-888-REG-FAIR (1-888-734-3247) or go to\nhttp://www.sba.gov/ombudsman/dsp_faq.html.\nIX. Payment Instructions\nCivil Penalty Payments of Less Than $10,000\nPayment of a civil penalty of less than $10,000 proposed or assessed, under Subpart B\nof Part 190 of the Pipeline Safety Regulations can be made by certified check, money\norder or wire transfer. Payment by certified check or money order (containing the CPF\nNumber for this case) should be made payable to the \"Department of Transportation\"\nand should be sent to:\nFederal Aviation Administration\nMike Monroney Aeronautical Center\nFinancial Operations Division (AMK-325) P.O. Box 269039\nOklahoma City, OK 73125-4915\nWire transfer payments of less than $10,000 may be made through the Federal Reserve\nCommunications System (Fedwire) to the account of the U.S. Treasury. Detailed\n11\n\n\n\ninstructions are provided below. Questions concerning wire transfer should be directed\nto the Financial Operations Division at (405) 954-8845, or at the above address.\nCivil Penalty Payments of $10,000 or more\nPayment of a civil penalty of $10,000 or more proposed or assessed under Subpart B\nof Part 190 of the Pipeline Safety Regulations must be made wire transfer (49 C.F.R. §\n89.21 (b)(3)), through the Federal Reserve Communications System (Fedwire) to the\naccount of the U.S. Treasury. Detailed instructions are provided below. Questions\nconcerning wire transfers should be directed to the Financial Operations Division at\n(405) 954-8845, or at the above address.\n12\n\n\n\nINSTRUCTIONS FOR ELECTRONIC FUND TRANSFERS\n(1) RECEIVER ABA NO.\n021030004\n(2) TYPE/SUB-TYPE\n(Provided by sending bank)\n(3) SENDING BANK ABA NO.\n(Provided by sending bank)\n(4) SENDING BANK REF NO.\n(Provided by sending bank)\n(5) AMOUNT (6) SENDING BANK NAME\n(Provided by sending bank)\n(7) RECEIVER NAME\nTREAS NYC\n(8) PRODUCT CODE\n(Normally CTR, or as provided by sending bank)\n(9) BENEFICIAL (BNF) =\nAGENCY LOCATION CODE\n69140001\n(10) REASONS FOR PAYMENT\nExample: PHMSA - CPF # / Ticket Number/Pipeline\nAssessment number\nINSTRUCTIONS: You, as sender of the wire transfer, must provide the sending bank with\nthe information for blocks (1), (5), (7), (9), and (10). The information provided in Blocks (1),\n(7), and (9) are constant and remain the same for all wire transfers to the Pipeline and\nHazardous Materials Safety Administration, Department of Transportation.\nBlock #1 - RECEIVER ABA NO. - \"021030004\". Ensure the sending bank enters this 9-digit\nidentification number; it represents the routing symbol for the U.S. Treasury at the Federal\nReserve Bank in New York.\nBlock #5 - AMOUNT - You as the sender provide the amount of the transfer. Please be sure\nthe transfer amount is punctuated with commas and a decimal point. EXAMPLE: $10,000.00\nBlock #7 - RECEIVER NAME - \"TREAS NYC\". Ensure the sending bank enters this\nabbreviation. It must be used for all wire transfers to the Treasury Department.\nBlock #9 - BENEFICIAL - AGENCY LOCATION CODE - \"69140001\". Ensure the sending\nbank enters this information. This is the Agency Location Code for the Pipeline and\nHazardous Materials Safety Administration, Department of Transportation.\nBlock #10 - REASON FOR PAYMENT - “AC-payment for PHMSA Case # / To ensure\nyour wire transfer is credited properly, enter the case number/ticket number or Pipeline\nAssessment number, and country.”\nNOTE: A wire transfer must comply with the format and instructions or the Department\ncannot accept the wire transfer. You as the sender can assist this process by notifying the\nFinancial Operations Division (405) 954-8845 at the time you send the wire transfer.\n13\n\n320171005M_Closure Letter_03022018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 2, 2018\nMr. Dan Krueger\nPresident\nBluewater Gas Storage, LLC\n231 W. Michigan St.\nMilwaukee, WI 53203\nCPF 3-2017-1005M\nDear Mr. Krueger:\nOn September 19-23 and October 18, 2016, a representative of the Michigan Public Service\nCommission (MIPSC), acting as an interstate agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted\nan on-site pipeline safety inspection of procedures at the Bluewater Columbus Compressor\nStation in Columbus, Michigan. As a result of the inspection the operator, PAA Natural Gas\nStorage, LLC, was issued a Notice of Amendment on April 5, 2017, which proposed\namendment of the procedures.\nPAA Natural Gas Storage, LLC submitted its amended procedures on May 8, 2017. On June\n30, 2017, PAA Natural Gas Storage, LLC sold this asset to Bluewater Gas Storage LLC.\nTherefore, Bluewater Gas Storage, LLC submitted an amended response on February 21, 2018.\nMy staff reviewed the amended response, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected. Regarding integrity management procedures, the\nMIPSC will follow up sometime after April 1, 2018.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: PAA Natural Gas Storage, LLC","truncated":false,"body_characters":29133}