{"operation":"document","citation":"CPF 120171009M","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":"2017-05-11","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171009M","body":"Notice of Amendment involving EASTERN SHORE NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2017-05-11 and is reported as closed as of 2017-12-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171009M_Closure Letter_12072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171009M/120171009M_Closure%20Letter_12072017.pdf\n\n120171009M_Closure Letter_12072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171009M/120171009M_Closure%20Letter_12072017_text.pdf\n\n120171009M_Notice of Amendment_05112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171009M/120171009M_Notice%20of%20Amendment_05112017.pdf\n\n120171009M_Notice of Amendment_05112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171009M/120171009M_Notice%20of%20Amendment_05112017_text.pdf\n\n120171009M_Operator Response To Notice_06072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171009M/120171009M_Operator%20Response%20To%20Notice_06072017.pdf\n\n120171009M_Closure Letter_12072017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nDecember 7, 2017\nSteven Thompson\nSenior Vice President\nEastern Shore Natural Gas Co\n909 Silver Lake Blvd.\nDover, DE 19904\nCPF 1-2017-1009M\nDear Mr. Thompson:\nDuring the weeks of May 16 and September 26, 2016; a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States\nCode, conducted an on-site pipeline safety inspection of Eastern Shore Natural Gas’s (ESNG)\nWhite Oak Mainline Expansion and US301/SR1 Relocation construction projects at locations in\nCochranville, PA and Biddles Corner, DE. As a result of the inspection, ESNG was issued a Notice\nof Amendment (NOA) on May 11, 2017, which proposed amendment of your procedures.\nESNG submitted its amended procedures on June 6, 2017. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this NOA have been corrected.\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\n120171009M_Notice of Amendment_05112017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 11, 2017\nSteven Thompson,\nSenior Vice President\nEastern Shore Natural Gas Co\n909 Silver Lake Blvd\nDover, DE 19904\nCPF 1-2017-1009M\nDear Mr. Thompson:\nDuring the weeks of May 16 and September 26, 2016, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Eastern Shore Natural Gas’s (ESNG) White Oak Mainline Expansion and\nUS301/SR1 Relocation construction projects at locations in Cochranville, PA and Biddles Corner,\nDE.\nOn the basis of the inspections, PHMSA has identified the apparent inadequacy found within\nESNG’s plans or procedures, as described below:\n1. §192.303 Compliance with specifications or standards.\nEach Transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nESNG’s written specifications for each transmission line constructed in accordance with Part 192\nwere inadequate. Specifically, ESNG’s Construction Standards Manual, Revision 3, dated 3/16/13\n(Manual) did not provide sufficient guidance for securing ground clamps during welding to\nmaintain electrical conductivity.\nDuring the inspection in May of 2016, the PHMSA inspector reviewed ESNG’s Manual. Section\n9.3.11 of the Manual, Ground Clamps, states:\n\n\n\nCPF 1-2017-1009M\n\"A. External pressure-type clamps shall be utilized when performing all welding. Ground\nclamps may be fitted with copper or brass contact tips to prevent arc burns on the pipe\nsurfaces.\nB. A welder is automatically disqualified if he tacks the ground lead to a pipe or\nappurtenance.\"\nOn May 17, 2016 and September 27, 2016, the PHMSA inspector observed several occasions\nwhere the grounding clamp utilized during welding was not firmly secured to the pipeline.\nAmerican Petroleum Institute (API) Standard 1104 “Welding of Pipelines and Related Facilities”,\n20th Edition, incorporated by reference in §192.7(b)(9), states in Section A.5.3 that “Arc burns\nmay occur on the internal or external surface of the pipe as a result of inadvertent arc strikes or\nimproper grounding.”\nIn order to maintain electrical conductivity for proper grounding throughout the welding process,\na secured ground contact is necessary. Unsecured ground contact may lead to inadequate\ngrounding, interruption of welding and/or arc burns.\nESNG’s Manual lacked guidance on how ground clamps will be secured to the pipeline in order\nto maintain electrical conductivity.\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. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes 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)\n120171009M_Notice of Amendment_05112017_text Page 2 of 3\n\n\n\nCPF 1-2017-1009M\nand submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-1009M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120171009M_Notice of Amendment_05112017_text Page 3 of 3","truncated":false,"body_characters":7636}