# PORTLAND NATURAL GAS TRANSMISSION SYSTEM — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 192.907(a), 192.911.
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- **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.

Official case documents:

120071003M_Notice Letter_03212007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120071003M/120071003M_Notice%20Letter_03212007.pdf

120071003M_Notice Letter_03212007.pdf

@
U.S, Deportment
of Tronsporlotion
Pipeline ond
Hozqrdour l qteriol3 Sofdy
Adminl$rotlon
409 3rd Street. SW Suite 300
Washington, DC 20024
NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March2l,2007
Mr. James Baggs
Vice President Field Operations & Engineering
TransCanada Pipeline Company
4501 Street SW
Calgary, Alberta, Canada T2P 5H1
cPF 1-2007-1003M
Dear Mr. Baggs:
On June 6-8 and June 20-22,2006 representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) and the State of Washington as interstate agent, pursuant to
Chapter 601 of 49 United States Code inspected TransCanada's procedures for integrity
management in Calgary, Alberta, Canada.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
TransCanada's plans or procedures, as described below:
1. SCCDA Data Gathering & Evaluation
$192.911 What are the elements of an integrity management program?



(d) A direct assessment plan, if applicable, meeting the requirements of
$192.923, and depending on the threat assessed, of $$192.925' 192.927 ' or
192.929.
$192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17,2004, an operator of a covered pipeline
segment must develop and follow a written integrity manag€ment program that
contains all the elements described in CFR:192.911 and that addresses the risks
on each covered transmission pipeline segment. The initial integrity management
program must consist, at a minimum, of a framework that describes the process
for implementing each program element, how relevant decisions will be made
and by whom, a time line for completing the work to implement the program
element, and how information gained from experience will be continuously
incorporated into the program. The framework wilt evolve into a more detailed
and comprehensive program. An operator must make continual improvements
to the program.
$192.929 What are the requirements for using Direct Assessment for Stress
Corrosion Cracking (SCCDA)?
(b) General Requirements. An operator using direct assessment as an integrity
ass€ssment method to address stress corrosion cracking in a covered pipeline
segment must have a plan that provides, at minimunr" for -
(l) Data gathering and integration. An operator's plan must provide for a
systematic process to collect and evaluate data for all covered segrnents to
identify whether the conditions for SCC are present end to prioritize the
covered segments for assessment. This process must include gathering and
evaluating data related to SCC at all sites an operator excavates during the
conduct of its pipeline operations where the criteria in ASME/AF{SI B31-8S'
Appendix A3.3 indicate the potential for SCC. This data includes at
minimum, the data specified in ASME/ANSI B31.8S' Appendix 43-
e Item 1A: $192.907(a), $r92.9r1(d) and 5192J29
No SCC assessments have been performed on HCAs. TransCanada has identified
SCC as a threat of concem and has included SCCDA as a necessary assessment
method in the baseline assessment plan. An SCCDA framework does not exist
although TransCanada was able to provide a presentation and discuss the details
of its planned approach. As described in 192.901
,
an integrity management
framework, including an SCCDA framework plan, is required to describe how an
operator addresses each element of an integrity management pfogram, and their
plans for how they intend to improve these processes to reach a fully-developed
integrity management program as would be required prior to implementation of
SCCDA activities.
)Continual Evaluation and Assessment



3.
$192.911 What are the elements of an integrity management program?
(f) A process for continual evaluation and assessment meeting the requirements
of $192.937.
5192J37 What is a continual process of evaluation and assessment to maintain a
pipeline's integrity?
(b) Evaluation. An operator must conduct a periodic evaluation as frequently as
needed to assure the integrity of each covered segment. The periodic evaluation
must be based on a data integration and risk assessment of the entire pipeline
asspecified in $192.917. For plastic transmission pipelines, the periodic
evaluation is based on the threat analysis specified in f92.917(d). For all other
transmission pipelines, the evaluation must consider the past and present
integrity assessment results, data integration and risk assessment information
($f92.9f4, and decisions about remediation ($192.933) and additional
preventive and mitigative actions ($192.935). An operator must use the results
from this evaluation to identify the threats specific to each covered segment and
the risk represented by these threats.
o Item 2A: $192.911(f) and $192.937(b)
TransCanada has not defined proc€dure and process requirements, including
responsibilities, required steps, and documentation requirements for the conduct
ofperiodic evaluation and assessment that are based on data integration and risk
assessment of the entire pipeline as required by 192.937@). TransCanada's
continual evaluation and assessment program does not include key program steps
to address:
a. past and present assessment results,
b. data integration and risk assessment information,
c. decisions about remediation, and
d. additional preventive and mitigative actions
The IMP process for conduct of periodic evaluation and assessment lacks the
detail expected for a mature developed integrity management program. A mature
program must include complete, well-documented, and effectively implemented
processes for all implemented integrity management program elements. Complete
documentation for periodic evaluation conducted in early 2006 to re-establish the
baseline assessment plan was not available for review.
Preventive and Mitigative Measures
$192.911 What are the elements of an integrity management program?
(h) Provisions meeting the requirements of $192.935 for adding preventive and
mitigative measures to protect the high consequence area.
$192.935 What additional preventive and mitigative measures must an operator
take?
(a) General Requirements. An operator must take additional measures beyond
those already required by Part 192 to prevent a pipeline failure and to mitigate



the consequences of a pipeline failure in a high consequence area. An operator
must base the additional measures on the threats the operator has identified to
each pipeline segment. (see $192.917.) An operator must conduct, in accordance
with one of the risk assessment approaches in ASME/ANSI 831.85, Section 5' a
risk analysis of its pipeline to identify additional measures to protect the high
consequence area and enhance public safety. Such additional measures include'
but are not timited to, installing Automatic Shut-off Valves or Remote Control
Valves, installing computerized monitoring and leak detection systems' replacing
pipe segments with pipe of heavier wall thickness, providing additional training
to personnel on response procedures, conducting drills with local emergency
responders and implementing additional inspection and maintenance programs.
(b) Third Parfy Damage and Outside Force Damage.
i. Third party damage. An operator must Qnhance its damage
prevention program' as required under $192.614 of this part, with
respect to a covered segment to prevent and minimize the
consequenc€s of a release due to third party damage. Enhanced
measures to an existing damage prevention program include, at a
minimum-
ii. Using qualified personnel (see $192.915) for work an operator is
conducting that could adversely affect the integrity of a covered
segment, such as marking locating, and direct supervision of known
excavation work.
iii. coltecting in a central database information that is location specific
on excavation damage that occurs in covered and non covered
segments in the transmission system and the root cause analysis to
support identification of targeted additional preventative and
mitigative measures in the high consequence areas. This information
must include recognized damage that is not required to be reported as
an incident under Part 191.
iv. Participating in one-call systems in locations where covered segments
are present.
v. Monitoring of excavations conducted on covered pipeline segments by
pipeline personnel. Ifan operator linds physical evidence of
encroachment involving excavation that the operator did not monitor
near a covered segment' an operator must either excavate the area
near the encroachment or conduct an above ground survey using
methods defined in NACE RP-0502-2002 (ibr, see $192.7). An
operator must excavate, and remediate, in accordance with
ANSIiASME B3l8.S and $192.933 any indication of coating holidays
or discontinuity warranting direct examination.
vi. Outside force damage. If an operafor deterrnines that outside force
(e.g." earth movementt floods, unstable suspension bridge) is a threat
to the integrity of a covered segmentr the operator must take measures
to minimize the consequences to the covered segm€nt from outside
force damage. These measures include, but are not limited to,
increasing the frequency of aerialr foot or other methods of patrols'



4.
adding external protection, reducing external stress, and relocating
the line.
r Item 3.{: $192.911(h) and $r92.935(a)
TransCanada has not defined procedure and process requirements, including
responsibilities, required steps, and the elements required for documentation for
the identification of additional preventive and mitigative measures based on both
the identified threats to each pipeline segment and the risk analysis as required by
t92.935.
r Item 3B: $192.911(h) and $192.935(a)
TransCanada procedure TED-INT-MIT does not include decision making criteria
for conduct of preventive and mitigative measures analyses and does not specify
the expected analysis documentation requirernents.
o Item 3C: $r92.9rr(h) and $r92.935(b)
TransCanada indicated that it had identified the need to conduct more frequent
aerial patrols due to the threat of outside force damage, its P&M Measures
process, and proximity to high population areas. However, TransCanada was
unable to show how its P&M Measures process resulted in this decision. Note: the
issue ofthe effectiveness ofa single person conducting aerial patrols was brought
to the attention of GTN's Compliance Coordinator during the last 2 WUTC
inspections. This concern has not been resolved and was brought to the attention
of TransCanada for investieation.
Management of Change
$f92.9f 1 What are the elements of an integrity management program?
(k) A management of change process as outlined in ASME/ANSI 831.85,
Section 11.
Item 4A: $192.91r(k)
TransCanada Process for documenting BAP changes does not include provisions
for the analysis of the implications of changes. This concern was addressed during
the inspection as IMP Section 9.7.1 was updated to require that changes be
managed in accordance with IMP Chapter 15 for Management of Change. IMP
Section 15.4.6 requires that MOCs under go a technical review and impact
analysis of any proposed change.
Item 48: S192.91r(k)



TransCanada referred to IMP Section 15.4.2 for process step to address new
information. IMP Section 5.5.2 also requires that data be updated within one year.
IMP Secfion 5.5.2 indicates that TransCanada has identified appropriate sources
ofinformation and has acquired/collected data, or has developed plans to acquire
additional data to address data gaps. All data collected is to be integrated into the
TransCanada ORION database. New information or data received will be
incorporated into the integrity management program within one year of its
integration/documentation. IMP Section 15.4.2 states that employees are trained
to recognize potential changes or factors that should prompt a change requiring
the use of the MOC process. Details of TransCanada IMP program requirements
and responsibilities are lacking and have not been defined that address how new
information is incorporated into the risk assessment in a timely and effective
manner.
Resnonse to this Notice
This Notice is provided pursuant to 49 U.S.C. g 60108(a) and 49 C.F.R . 5 190.237. Enclosed as
pan of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance 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 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
redacied information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do
not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to
contesi 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 a Final
Order.
If, after opportunity for a hearing, 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 C.F.R. $ 190.237). If you are not contesting this Notice, we propose that you submit your
amended procedures to my office within one hundred twenty (120) 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.
In correspondence concerning this matter, please refer to CPF 1-2007-1003M and, for each
document you submit, please provide a copy in electronic format whenever possible.



Sincerely,
Aru-/,E//6J/f
Mark F. Wendorff
Acting Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
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