PORTLAND NATURAL GAS TRANSMISSION SYSTEM — Notice of Amendment

party submissionOfficial PDF120071007M_operator response to notice_09282007.pdf#

120071007m_notice of amendment_080107_text.pdf, page 1Official PDFU 5 Department of Transportation Pipeline and Hazardous Materials Safety Administration 409 3rd Street SW Sorts 300 Washington, DC 20024 NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT RE UESTED August l, 2007 Mr Robert Pirt President Portland Natural Gas Transmission System, LLC One Harbour Place, S-375 Portsmouth, NH 03081 CPF 1-2007-1007M Dear Mr Pirt Dunng the week of Apnl 23, 2007, a representative of the Pipehne and Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 Umted States Code inspected Portland Natural Gas Transmission System's (PNGTS) corrosion procedures in Wtndham, Maine On the basis of the inspection, PHMSA has identified the apparent inadequacies found within PNGTS's plans or procedures, as descnbed below#

120071007m_notice of amendment_080107_text.pdf, page 2I tt192. 463 External corrosion control: Cathodic protection (a) Each cathodic protection system required by this subpart must provide a level of cathodic protection that comphes with one or more of the apphcable criteria contained m Appendix D of this part. If none of these criteria is apphcable, the cathodic protection system must provide a level of cathodic protection at least equal to that provided by compliance with one or more of these criteria. PNGTS's procedures 453 and EDMS 004258833 do uot state explicitly that the measured pipe to soil voltage measurements must be a negative voltage of at least 0 85 volts to indicate an adequate level of cathodic protection The procedures do uot state that the voltage measurement must consider the effect of voltage (IR) drops in the voltage measurement 2. tt 192. 465 External corrosion control Monitoring. (d) Each operator shall take prompt remedial action to correct any deficiencies indicated by the monitoring. PNGTS's procedures 453 and EDMS 004258833 do not specify a time frame for correcting any deficiencies indicated by external corrosion morutonng 3 It 192. 473 External corrosion control: Interference currents (a) Each operator whose pipelme system is subiected to stray currents shall have m effect a continuing program to mmtmixe the detrimental effects of such currents Apparently there is no PNGTS wntteu plan or procedure that addresses this code requirement 4. g 192 481 Atmospheric corrosion control Monitoring (c) If atmosphenc corrosion is found durmg an mspection, the operator must provide protection against the corrosion as required by $192. 479. PNGTS's EDMS 004266539 does not specify a time frame for evaluating data and determining a course of remedial action to correct deficiencies indicated by atmosphenc corrosion control moiutoriug#

120071007m_notice of amendment_080107_text.pdf, page 3Res onse to this Notice Tlus Notice is provided pursuant to 49 U S C $ 60108(a) and 49 C F R II 190 237 Enclosed as part of this Notice is a document entitled Response Options for Pipehne Operators in Comphance 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 sublect to being made pubhcly available If you beheve that any portion of your responsive material quahfies 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 quahfies 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 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 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 60 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 1-2007-1007M and, for each document you submit, please provide a copy in electronic format whenever possible By on Coy, PE Director, Eastern Region Pipeline and Hazardous Matenals Safety Administration Enclosure Response Options for Pipeline Operators in Compliance Proceedings#