{"operation":"document","citation":"CPF 120181004M","title":"TENNESSEE GAS PIPELINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-02-09","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120181004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120181004M","body":"Notice of Amendment involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2018-02-09 and is reported as closed as of 2018-05-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120181004M_Closure Letter_05102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181004M/120181004M_Closure%20Letter_05102018.pdf\n\n120181004M_Closure Letter_05102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181004M/120181004M_Closure%20Letter_05102018_text.pdf\n\n120181004M_Notice Of Amendment_02092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181004M/120181004M_Notice%20Of%20Amendment_02092018.pdf\n\n120181004M_Notice Of Amendment_02092018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181004M/120181004M_Notice%20Of%20Amendment_02092018_text.pdf\n\n120181004M_Operator Response To Notice_04122018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181004M/120181004M_Operator%20Response%20To%20Notice_04122018.pdf\n\n120181004M_Closure Letter_05102018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 10, 2018\nMr. Kenneth Grubb\nChief Operating Officer\nTennessee Gas Pipeline Company\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 1-2018-1004M\nDear Mr. Grubb:\nFrom August 1-3, 2017 and August 29-31, 2017, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Tennessee Gas Pipeline Company’s procedures\nin Agawam, MA. As a result of the inspection, Tennessee Gas Pipeline Company was issued a\nNotice of Amendment on February 9, 2018, which proposed amendment of your procedures.\nTennessee Gas Pipeline Company submitted its amended procedures on April 12, 2018. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment 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\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120181004M_Notice Of Amendment_02092018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nFebruary 9, 2018\nMr. Kenneth Grubb\nChief Operating Officer\nTennessee Gas Pipeline Company\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 1-2018-1004M\nDear Mr. Grubb:\nFrom August 1-3, 2017 and August 29-31, 2017, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected the Tennessee Gas Pipeline Company’s CT Expansion Project – MA Loop in Agawam,\nMA.\n1. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nTennessee Gas Pipeline Company’s plans or procedures, as described below:\n§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.\nTennessee Gas Pipeline Company’s (TGP) written construction standards for each transmission\nline constructed in accordance with Part 192 were inadequate. Specifically, TGP’s construction\nstandards for pipe coating did not adequately address minimizing damage to pipe coating during\ninstallation via boring, per the requirements of §192.461(e).\nSection 192.461(e) states:\n“If coated pipe is installed by boring, driving, or other similar method, precautions must be taken\nto minimize damage to the coating during installation.”\n\n\n\nCPF 1-2018-1004M\nDuring the inspection, the PHMSA inspector requested procedures addressing coating conditions\nof a pipeline when it is pulled out of the bore during horizontal directional drilling (HDD). TGP\nprovided Construction Standards Section C1080, Below-grade or Submerged Pipe Coatings,\nrevised 2017-04-01 (construction standards). However, the construction standards did not address\nhow TGP will assess the coating condition of piping that is exposed during a pull-back in the HDD\nprocess, and how TGP will remediate if the coating is damaged.\nTherefore, TGP’s construction standards did not adequately address minimizing damage to pipe\ncoating during installation via boring, per the requirement of §192.461(e).\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 60 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 60 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 Tennessee Gas Pipeline Company maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nPHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, New Jersey 08628.\nPlease refer to CPF 1-2018-1004M on each document you submit, and whenever possible provide\na signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov.\nLarger files should be sent on a CD accompanied by the original paper copy to the Eastern Region\nOffice.\n120181004M_Notice Of Amendment_02092018_text Page 2 of 3\n\n\n\nCPF 1-2018-1004M\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120181004M_Notice Of Amendment_02092018_text Page 3 of 3","truncated":false,"body_characters":7358}