{"operation":"document","citation":"CPF 120191015M","title":"ALGONQUIN GAS TRANSMISSION, L.L.C. (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-08-12","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191015m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191015m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120191015m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120191015M","body":"Notice of Amendment involving ALGONQUIN GAS TRANSMISSION, L.L.C. (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2019-08-12 and is reported as closed as of 2019-11-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120191015M_Closure Letter_11262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191015M/120191015M_Closure%20Letter_11262019.pdf\n\n120191015M_Closure Letter_11262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191015M/120191015M_Closure%20Letter_11262019_text.pdf\n\n120191015M_Notice of Amendment_08122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191015M/120191015M_Notice%20of%20Amendment_08122019.pdf\n\n120191015M_Notice of Amendment_08122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191015M/120191015M_Notice%20of%20Amendment_08122019_text.pdf\n\n120191015M_Operator Response to Notice_09102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120191015M/120191015M_Operator%20Response%20to%20Notice_09102019.pdf\n\n120191015M_Closure Letter_11262019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nNovember 26, 2019\nMichelle Harradence\nVP Gas Transmission & Midstream Operations\nAlgonquin Gas Transmission, LLC\n5400 Westheimer Court\nHouston, TX 77056\nCPF 1-2019-1015M\nDear Ms. Harradence:\nOn October 16 – October 20, 2017, and May 15-17, 2018, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Algonquin Gas Transmission,\nLLC’s (Algonquin’s) procedures in Waltham, Massachusetts. As a result of the inspection,\nAlgonquin was issued a Notice of Amendment on August 12, 2019, which proposed amendment\nof your procedures.\nAlgonquin submitted its amended procedures on September 10, 2019. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave 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\n120191015M_Notice of Amendment_08122019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nAugust 12, 2019\nMichele Harradence\nVP Gas Transmission & Midstream Operations\nAlgonquin Gas Transmission, LLC\n5400 Westheimer Court\nHouston, TX 77056\nCPF 1-2019-1015M\nDear Ms. Harradence:\nFrom October 16 - October 20, 2017 and May 15 - 17, 2018, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected Algonquin Gas Transmission, LLC (Algonquin)’s procedures for\nthe Mystic River HDD Project in Waltham, Massachusetts.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nAlgonquin’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.\nAlgonquin’s written specifications and standards for constructing each transmission line were\ninadequate. Specifically, Algonquin’s construction standards for coating inspection failed to\nadequately address the requirements of § 192.307 and § 192.461(e) regarding pipe that was\nhorizontally directionally drilled (HDD).\n\n\n\nCPF 1-2019-1015M\nDuring the inspection, a PHMSA inspector requested procedures for assessing and remediating\ncoating that may have been damaged as a result of installation via HDD. Algonquin provided\nCOATING DESIGN FOR HDD INSTALLATIONS (Guideline Number: DG-PC1.1 and\nRevision Date: 11/04/2014) (Design Guideline).\nSection 192.307 stated “Each length of pipe and each other component must be visually inspected\nat the site of installation to ensure that it has not sustained any visually determinable damage that\ncould impair its serviceability.” The Design Guideline did not address inspecting piping in the\nexit pit that was installed via HDD in order to determine if any damage occurred that could impair\nits serviceability, and also subsequent remediation requirements that may be necessary in the event\ndamage was discovered.\nSection 192.461(e) stated “If coated pipe is installed by boring, driving, or other similar method,\nprecautions must be taken to minimize damage to the coating during installation.” The Design\nGuideline did not address inspecting the coating condition of piping in the exit pit that was installed\nvia HDD, and subsequent remediation requirements for damaged coating.\nTherefore, Algonquin’s construction standards failed to address inspecting and remediating, if\nnecessary, the coating of piping in the exit pit that was installed via HDD to comply with\n§ 192.461(e). Also, the procedures did not address inspection of said pipe to determine if any\ndamage occurred during the HDD installation that could impair its serviceability to meet\n§ 192.307, and subsequent remediation, if necessary.\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 Enforcement\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).\n120191015M_Notice of Amendment_08122019_text Page 2 of 3\n\n\n\nCPF 1-2019-1015M\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 Algonquin Gas Transmission, LLC 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, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer\nto CPF 1-2019-1015M on each document you submit, and whenever possible provide a signed\nPDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger\nfiles should be sent on USB flash drive accompanied by the original paper copy to the Eastern\nRegion Office.\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 Enforcement Proceedings\n120191015M_Notice of Amendment_08122019_text Page 3 of 3","truncated":false,"body_characters":8157}