{"operation":"document","citation":"CPF 120171001M","title":"EASTERN SHORE NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-01-06","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171001M","body":"Notice of Amendment involving EASTERN SHORE NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2017-01-06 and is reported as closed as of 2017-03-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171001M_Closure Letter_03082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171001M/120171001M_Closure%20Letter_03082017.pdf\n\n120171001M_Closure Letter_03082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171001M/120171001M_Closure%20Letter_03082017_text.pdf\n\n120171001M_Notice of Amendment_01062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171001M/120171001M_Notice%20of%20Amendment_01062017.pdf\n\n120171001M_Notice of Amendment_01062017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171001M/120171001M_Notice%20of%20Amendment_01062017_text.pdf\n\n120171001M_Operator Response to Notice_02022017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171001M/120171001M_Operator%20Response%20to%20Notice_02022017.pdf\n\n120171001M_Closure Letter_03082017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMarch 8, 2017\nSteven Thompson\nSenior Vice President\nEastern Shore Natural Gas Co\n909 Silver Lake Blvd\nDover, DE 19901\nCPF 1-2017-1001M\nDear Mr. Thompson:\nDuring the week of December 1, 2014, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Eastern Shore Natural Gas’s (ESNG) procedures in Dover,\nDE. As a result of the inspection, ESNG was issued a Notice of Amendment on January 6, 2017,\nwhich proposed amendment of your procedures.\nESNG submitted its amended procedures on February 2, 2017. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120171001M_Notice of Amendment_01062017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 6, 2017\nSteven Thompson\nSenior Vice President\nEastern Shore Natural Gas Co\n909 Silver Lake Blvd\nDover, DE 19901\nCPF 1-2017-1001M\nDear Mr. Thompson:\nDuring the week of December 1, 2014, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nEastern Shore Natural Gas’s (ESNG) procedures for operations and maintenance in Dover, DE.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nESNG’s plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\nEach operator shall include the following in its operating and maintenance plan:\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. . .\nESNG’s manual of written procedures for conducting maintenance activities was inadequate in\nthat it did not sufficiently detail how to meet the requirements prescribed in §192.745(a), which\nstates in part that “Each transmission line valve that might be required during any emergency must\nbe inspected and partially operated. . .”\n\n\n\n1-2017-1001M\nDuring the inspection, a PHMSA inspector reviewed ESNG’s valve inspection records and\nESNG’s O&M Manual Subsection, 310, Periodic Surveys, Inspections, and Patrols. Subsection\n320 BLOCK VALVE OPERATION SURVEY [192.745] states that:\n“Once each calendar year, but at intervals not exceeding fifteen (15) months, each block valve\nshall be operated and inspected.\n320.1\nRecords The results of the survey for each valve and any work performed shall be recorded\non Form 325, “Valve Record Card\" by Measurement personnel. The Measurement\nDepartment shall maintain these records.”\nThe procedure failed to provide details such as:\n1. Criteria / process for identifying valves that may be required in an emergency\n2. Individuals responsible for developing the criteria\n3. Process for keeping the list of emergency valves current\n4. Documentation requirements\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\nEach operator shall include the following in its operating and maintenance plan:\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. . .\nESNG’s manual of written procedures for conducting maintenance activities was inadequate in\nthat it did not adequately detail how to meet the requirements prescribed in §192.745(b) which\nstates that “Each operator must take prompt remedial action to correct any valve found inoperable,\nunless the operator designates an alternative valve.”\nDuring the inspection, a PHMSA inspector reviewed ESNG’s valve inspection records and\nESNG’s O&M Manual Subsection, 310, Periodic Surveys, Inspections, and Patrols.\nThe procedure failed to provide details such as:\n1. Definition of “prompt” remedial action\n2. Designation of another valve or valves to substitute for the inoperable valve that\nwill provide a similar level of effectiveness for isolating the line section.\nConsideration should be given to the following:\na. Spacing requirements as prescribed in §192.179\nb. Updating records for emergency shutdown and future maintenance\nrequirements\nc. Informing employees of the change to the isolation or emergency shutdown\nplan\nd. Individuals responsible for developing the criteria\nProcess for keeping the list of emergency and alternate valves current\n4. Documentation requirements\n3. 120171001M_ NOA_01062017 Page 2 of 3\n\n\n\n1-2017-1001M\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document, you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment 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. Failure to respond within 30 days of receipt\nof this Notice constitutes a waiver of your right to contest the allegations in this Notice, and\nauthorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that ESNG maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear\nTavern Road, Suite 103, West Trenton, NJ 08628. In correspondence concerning this matter,\nplease refer to CPF 1-2017-1001M, and for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120171001M_ NOA_01062017 Page 3 of 3","truncated":false,"body_characters":8697}