{"operation":"document","citation":"CPF 120171005W","title":"ALGONQUIN GAS TRANSMISSION, L.L.C. (SPECTRA ENERGY PARTNERS, LP) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-02-27","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171005W","body":"Warning Letter involving ALGONQUIN GAS TRANSMISSION, L.L.C. (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2017-02-27 and is reported as closed as of 2017-02-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171005W_Operator Response to Notice_03242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171005W/120171005W_Operator%20Response%20to%20Notice_03242017.pdf\n\n120171005W_Warning Letter_02272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171005W/120171005W_Warning%20Letter_02272017.pdf\n\n120171005W_Warning Letter_02272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171005W/120171005W_Warning%20Letter_02272017_text.pdf\n\n120171005W_Warning Letter_02272017_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nFebruary 27, 2017\nJ. Andrew Drake\nVice President, Operations & EHS\nAlgonquin Gas Transmission, L.L.C. (Spectra Energy Partners, LP)\n5400 Westheimer Court\nHouston, TX 77056\nCPF 1-2017-1005W\nDear Mr. Drake:\nFrom November 2 – 6, 2015, representatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, pursuant to Chapter 601 of 49 United States Code, inspected\nAlgonquin Gas Transmission, L.L.C.’s (a subsidiary of Spectra Energy Partners, LP) (Spectra)\nBoston/Westwood Division Office Unit #1931 in Westwood, MA.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation is:\n1. § 192. 605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of written\nprocedures for conducting operations and maintenance activities and for emergency\nresponse. For transmission lines, the manual must also include procedures for handling\nabnormal operations. This manual must be reviewed and updated by the operator at\nintervals not exceeding 15 months, but at least one each calendar year. This manual must\nbe prepared before operations of a pipeline system commence. Appropriate parts of the\nmanual must be kept at locations where operations and maintenance activities are\nconducted.\nSpectra failed to follow its written procedure 2-2200, Application of Cathodic Protection Criteria, by\nfailing to investigate areas with indications of over voltage that could potentially lead to cathodic\ndisbondment of the coating and/or hydrogen embrittlement of the steel pipe.\nSpectra SOP 2-2200, Application of Cathodic Protection Criteria, dated 4/30/2014, Section 7.0, Over\nVoltage, states in part:\n“Cathodic protection levels which are “too high” (over voltage) may cause damage to the pipeline coating\nand to the pipe itself.\n7.1 As a guideline, polarized potentials should be maintained more positive than -1.2 to -1.5 VDC in order\nto minimize the possibility of cathodic disbondment of the coating and hydrogen embrittlement of the steel.\n\n\n\n1-2017-1005W\n7.4 The results of bell hole examinations along with the pipe-to-soil potential measurements taken before\nand during the examination should be reviewed to determine whether over voltage is a concern for the\npipeline segment if polarized potentials more negative than -1.2 VDC are identified. If over-voltage is\ndetermined to be a problem, then the magnitude of the influencing current must be reduced and possibly\nadditional cathodic protection sources established so as to more uniformly distribute the CP current.”\nDuring the inspection, the PHMSA inspector reviewed Annual Survey records from 2013 to November\n2015 for the Q System pipelines located in the Westwood, MA operating area. The records show that in\n2014 there were 12 test stations along the Q-1 pipeline which had IRF (IR Free) polarized pipe-to-soil\npotentials ranging from -1.5V to negative -2.647V. Field measurements taken during the inspection of\nsome test stations and recorded “Off” polarized potentials more negative than -1.5V.\nNo documentation was provided to demonstrate that these indications of potential over voltage had been\ninvestigated to determine if they are a concern to the pipeline segment.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638 per\nviolation per day the violation persists up to a maximum of $2,056,380 for a related series of violations.\nFor violation occurring between January 4, 2012 to August 1, 2016, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed\n$100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item identified in this letter. Failure to do so will result in Spectra being subject\nto additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-\n2017-1005W. Be advised 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 qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document, you must provide\na second copy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120171005W_Warning Letter_02272017_text Page 2 of 2","truncated":false,"body_characters":6098}