{"operation":"document","citation":"CPF 120071003M","title":"PORTLAND NATURAL GAS TRANSMISSION SYSTEM — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-03-21","effective_on":null,"summary":"CLOSED notice of amendment citing 192.907(a), 192.911.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120071003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120071003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120071003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120071003M","body":"Notice of Amendment involving PORTLAND NATURAL GAS TRANSMISSION SYSTEM. PHMSA's enforcement data identifies the cited regulations as 192.907(a),  192.911. The case was opened on 2007-03-21 and is reported as closed as of 2007-10-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120071003M_Notice Letter_03212007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120071003M/120071003M_Notice%20Letter_03212007.pdf\n\n120071003M_Notice Letter_03212007.pdf\n\n@\nU.S, Deportment\nof Tronsporlotion\nPipeline ond\nHozqrdour l qteriol3 Sofdy\nAdminl$rotlon\n409 3rd Street. SW Suite 300\nWashington, DC 20024\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch2l,2007\nMr. James Baggs\nVice President Field Operations & Engineering\nTransCanada Pipeline Company\n4501 Street SW\nCalgary, Alberta, Canada T2P 5H1\ncPF 1-2007-1003M\nDear Mr. Baggs:\nOn June 6-8 and June 20-22,2006 representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) and the State of Washington as interstate agent, pursuant to\nChapter 601 of 49 United States Code inspected TransCanada's procedures for integrity\nmanagement in Calgary, Alberta, Canada.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTransCanada's plans or procedures, as described below:\n1. SCCDA Data Gathering & Evaluation\n$192.911 What are the elements of an integrity management program?\n\n\n\n(d) A direct assessment plan, if applicable, meeting the requirements of\n$192.923, and depending on the threat assessed, of $$192.925' 192.927 ' or\n192.929.\n$192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17,2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity manag€ment program that\ncontains all the elements described in CFR:192.911 and that addresses the risks\non each covered transmission pipeline segment. The initial integrity management\nprogram must consist, at a minimum, of a framework that describes the process\nfor implementing each program element, how relevant decisions will be made\nand by whom, a time line for completing the work to implement the program\nelement, and how information gained from experience will be continuously\nincorporated into the program. The framework wilt evolve into a more detailed\nand comprehensive program. An operator must make continual improvements\nto the program.\n$192.929 What are the requirements for using Direct Assessment for Stress\nCorrosion Cracking (SCCDA)?\n(b) General Requirements. An operator using direct assessment as an integrity\nass€ssment method to address stress corrosion cracking in a covered pipeline\nsegment must have a plan that provides, at minimunr\" for -\n(l) Data gathering and integration. An operator's plan must provide for a\nsystematic process to collect and evaluate data for all covered segrnents to\nidentify whether the conditions for SCC are present end to prioritize the\ncovered segments for assessment. This process must include gathering and\nevaluating data related to SCC at all sites an operator excavates during the\nconduct of its pipeline operations where the criteria in ASME/AF{SI B31-8S'\nAppendix A3.3 indicate the potential for SCC. This data includes at\nminimum, the data specified in ASME/ANSI B31.8S' Appendix 43-\ne Item 1A: $192.907(a), $r92.9r1(d) and 5192J29\nNo SCC assessments have been performed on HCAs. TransCanada has identified\nSCC as a threat of concem and has included SCCDA as a necessary assessment\nmethod in the baseline assessment plan. An SCCDA framework does not exist\nalthough TransCanada was able to provide a presentation and discuss the details\nof its planned approach. As described in 192.901\n,\nan integrity management\nframework, including an SCCDA framework plan, is required to describe how an\noperator addresses each element of an integrity management pfogram, and their\nplans for how they intend to improve these processes to reach a fully-developed\nintegrity management program as would be required prior to implementation of\nSCCDA activities.\n)Continual Evaluation and Assessment\n\n\n\n3.\n$192.911 What are the elements of an integrity management program?\n(f) A process for continual evaluation and assessment meeting the requirements\nof $192.937.\n5192J37 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(b) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure the integrity of each covered segment. The periodic evaluation\nmust be based on a data integration and risk assessment of the entire pipeline\nasspecified in $192.917. For plastic transmission pipelines, the periodic\nevaluation is based on the threat analysis specified in f92.917(d). For all other\ntransmission pipelines, the evaluation must consider the past and present\nintegrity assessment results, data integration and risk assessment information\n($f92.9f4, and decisions about remediation ($192.933) and additional\npreventive and mitigative actions ($192.935). An operator must use the results\nfrom this evaluation to identify the threats specific to each covered segment and\nthe risk represented by these threats.\no Item 2A: $192.911(f) and $192.937(b)\nTransCanada has not defined proc€dure and process requirements, including\nresponsibilities, required steps, and documentation requirements for the conduct\nofperiodic evaluation and assessment that are based on data integration and risk\nassessment of the entire pipeline as required by 192.937@). TransCanada's\ncontinual evaluation and assessment program does not include key program steps\nto address:\na. past and present assessment results,\nb. data integration and risk assessment information,\nc. decisions about remediation, and\nd. additional preventive and mitigative actions\nThe IMP process for conduct of periodic evaluation and assessment lacks the\ndetail expected for a mature developed integrity management program. A mature\nprogram must include complete, well-documented, and effectively implemented\nprocesses for all implemented integrity management program elements. Complete\ndocumentation for periodic evaluation conducted in early 2006 to re-establish the\nbaseline assessment plan was not available for review.\nPreventive and Mitigative Measures\n$192.911 What are the elements of an integrity management program?\n(h) Provisions meeting the requirements of $192.935 for adding preventive and\nmitigative measures to protect the high consequence area.\n$192.935 What additional preventive and mitigative measures must an operator\ntake?\n(a) General Requirements. An operator must take additional measures beyond\nthose already required by Part 192 to prevent a pipeline failure and to mitigate\n\n\n\nthe consequences of a pipeline failure in a high consequence area. An operator\nmust base the additional measures on the threats the operator has identified to\neach pipeline segment. (see $192.917.) An operator must conduct, in accordance\nwith one of the risk assessment approaches in ASME/ANSI 831.85, Section 5' a\nrisk analysis of its pipeline to identify additional measures to protect the high\nconsequence area and enhance public safety. Such additional measures include'\nbut are not timited to, installing Automatic Shut-off Valves or Remote Control\nValves, installing computerized monitoring and leak detection systems' replacing\npipe segments with pipe of heavier wall thickness, providing additional training\nto personnel on response procedures, conducting drills with local emergency\nresponders and implementing additional inspection and maintenance programs.\n(b) Third Parfy Damage and Outside Force Damage.\ni. Third party damage. An operator must Qnhance its damage\nprevention program' as required under $192.614 of this part, with\nrespect to a covered segment to prevent and minimize the\nconsequenc€s of a release due to third party damage. Enhanced\nmeasures to an existing damage prevention program include, at a\nminimum-\nii. Using qualified personnel (see $192.915) for work an operator is\nconducting that could adversely affect the integrity of a covered\nsegment, such as marking locating, and direct supervision of known\nexcavation work.\niii. coltecting in a central database information that is location specific\non excavation damage that occurs in covered and non covered\nsegments in the transmission system and the root cause analysis to\nsupport identification of targeted additional preventative and\nmitigative measures in the high consequence areas. This information\nmust include recognized damage that is not required to be reported as\nan incident under Part 191.\niv. Participating in one-call systems in locations where covered segments\nare present.\nv. Monitoring of excavations conducted on covered pipeline segments by\npipeline personnel. Ifan operator linds physical evidence of\nencroachment involving excavation that the operator did not monitor\nnear a covered segment' an operator must either excavate the area\nnear the encroachment or conduct an above ground survey using\nmethods defined in NACE RP-0502-2002 (ibr, see $192.7). An\noperator must excavate, and remediate, in accordance with\nANSIiASME B3l8.S and $192.933 any indication of coating holidays\nor discontinuity warranting direct examination.\nvi. Outside force damage. If an operafor deterrnines that outside force\n(e.g.\" earth movementt floods, unstable suspension bridge) is a threat\nto the integrity of a covered segmentr the operator must take measures\nto minimize the consequences to the covered segm€nt from outside\nforce damage. These measures include, but are not limited to,\nincreasing the frequency of aerialr foot or other methods of patrols'\n\n\n\n4.\nadding external protection, reducing external stress, and relocating\nthe line.\nr Item 3.{: $192.911(h) and $r92.935(a)\nTransCanada has not defined procedure and process requirements, including\nresponsibilities, required steps, and the elements required for documentation for\nthe identification of additional preventive and mitigative measures based on both\nthe identified threats to each pipeline segment and the risk analysis as required by\nt92.935.\nr Item 3B: $192.911(h) and $192.935(a)\nTransCanada procedure TED-INT-MIT does not include decision making criteria\nfor conduct of preventive and mitigative measures analyses and does not specify\nthe expected analysis documentation requirernents.\no Item 3C: $r92.9rr(h) and $r92.935(b)\nTransCanada indicated that it had identified the need to conduct more frequent\naerial patrols due to the threat of outside force damage, its P&M Measures\nprocess, and proximity to high population areas. However, TransCanada was\nunable to show how its P&M Measures process resulted in this decision. Note: the\nissue ofthe effectiveness ofa single person conducting aerial patrols was brought\nto the attention of GTN's Compliance Coordinator during the last 2 WUTC\ninspections. This concern has not been resolved and was brought to the attention\nof TransCanada for investieation.\nManagement of Change\n$f92.9f 1 What are the elements of an integrity management program?\n(k) A management of change process as outlined in ASME/ANSI 831.85,\nSection 11.\nItem 4A: $192.91r(k)\nTransCanada Process for documenting BAP changes does not include provisions\nfor the analysis of the implications of changes. This concern was addressed during\nthe inspection as IMP Section 9.7.1 was updated to require that changes be\nmanaged in accordance with IMP Chapter 15 for Management of Change. IMP\nSection 15.4.6 requires that MOCs under go a technical review and impact\nanalysis of any proposed change.\nItem 48: S192.91r(k)\n\n\n\nTransCanada referred to IMP Section 15.4.2 for process step to address new\ninformation. IMP Section 5.5.2 also requires that data be updated within one year.\nIMP Secfion 5.5.2 indicates that TransCanada has identified appropriate sources\nofinformation and has acquired/collected data, or has developed plans to acquire\nadditional data to address data gaps. All data collected is to be integrated into the\nTransCanada ORION database. New information or data received will be\nincorporated into the integrity management program within one year of its\nintegration/documentation. IMP Section 15.4.2 states that employees are trained\nto recognize potential changes or factors that should prompt a change requiring\nthe use of the MOC process. Details of TransCanada IMP program requirements\nand responsibilities are lacking and have not been defined that address how new\ninformation is incorporated into the risk assessment in a timely and effective\nmanner.\nResnonse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. g 60108(a) and 49 C.F.R . 5 190.237. Enclosed as\npan 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\nbeing made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S,C. 552(b), along with the complete original\ndocument you must provide a second copy of the document with the portions you believe\nqualify for confidential treatment redacted and an explanation of why you believe the\nredacied information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do\nnot respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to\ncontesi the allegations in this Notice and authorizes the Associate Administrator for Pipeline\nSafety to find facts as alleged in this Notice without further notice to you and to issue a Final\nOrder.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. $ 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within one hundred twenty (120) days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action will\nbe closed.\nIn correspondence concerning this matter, please refer to CPF 1-2007-1003M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\n\n\n\nSincerely,\nAru-/,E//6J/f\nMark F. Wendorff\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":14703}