{"operation":"document","citation":"CPF 12021051NOA","title":"ANR PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-07-16","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a), 192.605(b)(3), 192.605(b)(8), 192.605(d), 192.907(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021051noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021051noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021051noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021051NOA","body":"Notice of Amendment involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(3),  192.605(b)(8),  192.605(d),  192.907(a). The case was opened on 2021-07-16 and is reported as closed as of 2021-10-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021051NOA/12021051NOA_Notice%20of%20Amendment%20(Amended)_10142021_(21-198992).pdf\n\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021051NOA/12021051NOA_Notice%20of%20Amendment%20(Amended)_10142021_(21-198992)_text.pdf\n\n12021051NOA_Notice of Amendment_07162021_(21-198992).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021051NOA/12021051NOA_Notice%20of%20Amendment_07162021_(21-198992).pdf\n\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021051NOA/12021051NOA_Notice%20of%20Amendment_07162021_(21-198992)_text.pdf\n\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: stanley chapman iii@tcenergy.com\nJuly 16, 2021\nMr. Stan Chapman\nExecutive Vice President & President, US Pipelines\nANR Pipeline Company\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nCPF 1-2021-051-NOA\nDear Mr. Chapman:\nFrom April 12 through April 16, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected ANR\nPipeline Company’s (ANR) natural gas pipeline operation and maintenance procedures. ANR is\nthe primary OPID in its safety program relationship (SPR) for the following OPIDs: 993, 2616,\n2620, 6660, 13769, 15014, 30838, 31145, 31891, 32487, and 39542.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within ANR’s\nplans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nANR’s procedural manual failed to sufficiently describe a process to review and update the\n\n\n\nCPF 1-2021-051-NOA\nprocedural manual, and was therefore inadequate to comply with the requirements of § 192.605(a).\nSpecifically, ANR’s Operations & Maintenance Manual – U.S. Natural Gas Pipelines and\nUnderground Natural Gas Storage Facilities, dated 03/16/21 (O&M Manual) failed to explicitly\nincorporate or reference ANR’s Operations and Maintenance Manual Review Process, dated\n04/07/2021 (O&M Review Procedure).\nDuring the inspection, the PHMSA inspectors requested ANR’s O&M Manual review procedures.\nANR provided its O&M Manual, referencing Section 192.605(a) therein, and its separate O&M\nReview Procedure. When the PHMSA inspectors asked how the O&M Review Procedure is\nincorporated to the O&M Manual, ANR personnel stated, “This is not currently in the O&M\nmanual it is a separate document but will be considered to be included in the future.” Furthermore,\nthe O&M Manual failed to include a process for including all operation and maintenance manual\nreferenced documents into the annual review.\nTherefore, ANR failed to include an adequate process to review and update the operations and\nmaintenance manual, in accordance with § 192.605(a). ANR must revise its procedures to\nadequately address this requirement.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nANR’s procedures for conducting emergency response activities failed to specify the appropriate\nreview interval not exceeding 15 months, and were therefore inadequate to comply with\n§ 195.605(a). Specifically, ANR’s Emergency Management Corporate Program Manual, dated\n12/03/20 (ERP Procedure) stated that ANR may modify the manual at any frequency during the\ncalendar year, but the manual will be reviewed at least annually. ANR’s ERP Procedure failed to\nrequire a review within the 15-month interval. ANR did not provide any additional procedure\nrelated to the review interval. When the PHMSA inspectors asked if there were additional\nprocedures or guidance related to the review frequency of the emergency response plans, ANR did\nnot provide a response.\nTherefore, ANR failed to adequately address the requirement to review and update its emergency\nresponse procedures at intervals not exceeding 15 months, but at least once each calendar year, in\naccordance with § 192.605(a). ANR must revise its procedures to address this requirement.\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text Page 2 of 6\n\n\n\nCPF 1-2021-051-NOA\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) …\n(3) Making construction records, maps, and operating history\navailable to appropriate operating personnel.\nANR’s procedural manual failed to include a process which makes construction records, maps,\nand operating history available to appropriate operating personnel, and was therefore inadequate\nto comply with § 192.605(b)(3). During the inspection, the PHMSA inspectors requested ANR’s\nprocedure regarding § 192.605(b)(3). ANR provided the O&M Manual and referenced its Section\n192.605(b)(3) therein. The O&M Manual - Section 192.605(b)(3) required that construction\nproject managers ensure that maps and records are accessible to personnel and that revisions are\nsubmitted as necessary.\nDuring the inspection ANR discussed a process related to how technicians and managers gain and\nmaintain access to internal databases as well as record availability, but stated this process is not\ndocumented in the O&M Manual.\nTherefore, ANR failed to include a process which makes construction records, maps, and operating\nhistory available to appropriate operating personnel, in accordance with § 192.605(b)(3). ANR\nmust revise its procedures to adequately address this requirement.\n4. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) …\n(8) Periodically reviewing the work done by operator personnel to\ndetermine the effectiveness, and adequacy of the procedures used in\nnormal operation and maintenance and modifying the procedures\nwhen deficiencies are found.\nANR’s procedural manual failed to provide details to periodically review the work done by\noperator personnel to determine the procedures’ effectiveness and was therefore inadequate to\ncomply with § 192.605. Specifically, Section 192.605(b)(8) and Appendix B of the O&M Manual\nstated that procedures used in normal operations and maintenance that have not been subject to a\nreview within the last three years are identified and reviewed. The O&M Manual failed to include\na process requiring that ANR conduct periodic reviews of work done by operator personnel to\ndetermine the effectiveness and adequacy of the procedures. Furthermore, the O&M Manual failed\nto include a process for how ANR will modify the procedures when deficiencies are found.\nDuring the inspection, ANR stated, “[t]here is not a documented process for O&M effectiveness\nreviews and correction of deficiencies other than the procedure reviews and changes to the revision\nhistory.”\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text Page 3 of 6\n\n\n\nCPF 1-2021-051-NOA\nTherefore, ANR failed to include details in its procedures to periodically review the work done by\noperator personnel to determine the effectiveness of the procedures, in accordance with\n§ 192.605(b)(8). ANR must revise its procedures to address this requirement.\n5. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(d) Safety-related condition reports. The manual required by\nparagraph (a) of this section must include instructions enabling\npersonnel who perform operation and maintenance activities to\nrecognize conditions that potentially may be safety-related conditions\nthat are subject to the reporting requirements of §191.23 of this\nsubchapter.\nANR’s procedural manuals failed to include instructions enabling personnel to recognize safety-\nrelated conditions (SRCs) subject to § 191.23, and were therefore inadequate under § 192.605(d).\nSpecifically, ANR’s O&M Manual and January 2021 NETT Schedule and New Employee\nTechnical Training- Compliance Module (SRC Training Procedures) did not provide any\ninstructions enabling personnel who perform operation and maintenance activities to recognize\nconditions that potentially may be SRCs.\nDuring the inspection, the PHMSA inspectors requested ANR’s procedure regarding recognizing\nsafety related conditions. ANR provided the O&M Manual and referenced Section 191.23 therein.\nWhen the PHMSA inspectors re-requested procedures related to recognizing safety related\nconditions, ANR stated, “SRC training is included in on-board training for personnel.” ANR\nprovided SRC Training Procedures. However, these documents were not referenced or\nincorporated into the O&M Manual. Furthermore, the SRC Training Procedures failed to provide\nany further guidance or instruction related to recognition of safety-related conditions.\nTherefore, ANR failed to include instructions in its procedures to enable personnel to recognize\nconditions that potentially may be safety-related conditions in accordance with § 192.605(d).\nANR must revise its procedures to address this requirement.\n6. § 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nANR’s Integrity Management Program (IMP) failed to require the operator to notify OPS of any\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text Page 4 of 6\n\n\n\nCPF 1-2021-051-NOA\nchange to the program that may substantially affect its implementation or significantly modify the\nprogram or schedule for carrying out the program elements in accordance with § 192.909(b), and\nwas therefore inadequate to comply with § 192.907(a). Under § 192.909(b), an operator must\n“notify OPS, in accordance with §192.18, of any change to the program that may substantially\naffect the program's implementation or may significantly modify the program or schedule for\ncarrying out the program elements. An operator must provide notification within 30 days after\nadopting this type of change into its program.” Specifically, ANR’s O&M Manual and US-Gas-\nIMP US Onshore Gas Pipeline Integrity Management Program, dated 04/01/21 (IMP Manual)\nfailed to include procedures requiring the operator to notify PHMSA’s Office Pipeline Safety\n(OPS) within 30 days after adopting any change that may substantially affect the program’s\nimplementation or which may significantly modify the program or schedule.\nDuring the inspection, the PHMSA inspectors requested ANR’s procedure regarding § 192.909.\nANR provided the O&M Manual and referenced Section 192.18 therein. However, the O&M\nManual did not include the § 192.909 requirements. Furthermore, ANR provided the IMP Manual\nand referenced Section 13.4.1 therein. Section 13.4.1 of the IMP Manual stated that changes to\nthe integrity management program are made in accordance with the regulation.\nHowever, the IMP Manual failed to state that the operator must notify OPS within 30 days after\nadopting any change that may substantially affect the program’s implementation or which may\nsignificantly modify the program or schedule.\nTherefore, ANR failed to include adequate details in its integrity management procedures requiring\nnotification to OPS within 30 days after adopting any change that may substantially affect the\nprogram’s implementation, in accordance with § 192.909(b). ANR must revise its procedures to\naddress this requirement.\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.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text Page 5 of 6\n\n\n\nCPF 1-2021-051-NOA\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 30 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 ANR Pipeline Company’s maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. In correspondence concerning this matter, please refer to CPF 1-2021-051-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\naccompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021051NOA_Notice of Amendment_07162021_(21-198992)_text Page 6 of 6\n\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992)_text.pdf\n\nAMENDED NOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nOctober 14, 2021\nMr. Stan Chapman\nExecutive Vice President & President, US Pipelines\nANR Pipeline Company\n700 Louisiana Street, Suite 700\nHouston, Texas 77002\nCPF 1-2021-051-NOA\nDear Mr. Chapman:\nFrom April 12 through April 16, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected ANR\nPipeline Company’s (ANR) natural gas pipeline operation and maintenance procedures. ANR is\nthe primary OPID in its safety program relationship (SPR) for the following OPIDs: 993, 2616,\n2620, 6660, 13769, 15014, 30838, 31145, 31891, 32487, and 39542.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within ANR’s\nplans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nANR’s procedural manual failed to sufficiently describe a process to review and update the\n\n\n\nCPF 1-2021-051-NOA\nprocedural manual, and was therefore inadequate to comply with the requirements of § 192.605(a).\nSpecifically, ANR’s Operations & Maintenance Manual – U.S. Natural Gas Pipelines and\nUnderground Natural Gas Storage Facilities, dated 03/16/21 (O&M Manual) failed to explicitly\nincorporate or reference ANR’s Operations and Maintenance Manual Review Process, dated\n04/07/2021 (O&M Review Procedure).\nDuring the inspection, the PHMSA inspectors requested ANR’s O&M Manual review procedures.\nANR provided its O&M Manual, referencing Section 192.605(a) therein, and its separate O&M\nReview Procedure. When the PHMSA inspectors asked how the O&M Review Procedure is\nincorporated to the O&M Manual, ANR discussed that their process is not currently in the O&M\nmanual, rather it is located in a separate document but will be considered to be included in the\nfuture. Furthermore, the O&M Manual failed to include a process for including all operation and\nmaintenance manual referenced documents into the annual review.\nTherefore, ANR failed to include an adequate process to review and update the operations and\nmaintenance manual, in accordance with § 192.605(a). ANR must revise its procedures to\nadequately address this requirement.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nANR’s procedures for conducting emergency response activities failed to specify the appropriate\nreview interval not exceeding 15 months, and were therefore inadequate to comply with\n§ 195.605(a). Specifically, ANR’s Emergency Management Corporate Program Manual, dated\n12/03/20 (ERP Procedure) stated that ANR may modify the manual at any frequency during the\ncalendar year, but the manual will be reviewed at least annually. ANR’s ERP Procedure failed to\nrequire a review within the 15-month interval. ANR did not provide any additional procedure\nrelated to the review interval. When the PHMSA inspectors asked if there were additional\nprocedures or guidance related to the review frequency of the emergency response plans, ANR did\nnot provide a response.\nTherefore, ANR failed to adequately address the requirement to review and update its emergency\nresponse procedures at intervals not exceeding 15 months, but at least once each calendar year, in\naccordance with § 192.605(a). ANR must revise its procedures to address this requirement.\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992)_text Page 2 of 5\n\n\n\nCPF 1-2021-051-NOA\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) …\n(3) Making construction records, maps, and operating history\navailable to appropriate operating personnel.\nANR’s procedural manual failed to include a process which makes construction records, maps,\nand operating history available to appropriate operating personnel, and was therefore inadequate\nto comply with § 192.605(b)(3). During the inspection, the PHMSA inspectors requested ANR’s\nprocedure regarding § 192.605(b)(3). ANR provided the O&M Manual and referenced its Section\n192.605(b)(3) therein. The O&M Manual - Section 192.605(b)(3) required that construction\nproject managers ensure that maps and records are accessible to personnel and that revisions are\nsubmitted as necessary.\nDuring the inspection ANR discussed a process related to how technicians and managers gain and\nmaintain access to internal databases as well as record availability, but stated this process is not\ndocumented in the O&M Manual.\nTherefore, ANR failed to include a process which makes construction records, maps, and operating\nhistory available to appropriate operating personnel, in accordance with § 192.605(b)(3). ANR\nmust revise its procedures to adequately address this requirement.\n4. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(d) Safety-related condition reports. The manual required by\nparagraph (a) of this section must include instructions enabling\npersonnel who perform operation and maintenance activities to\nrecognize conditions that potentially may be safety-related conditions\nthat are subject to the reporting requirements of §191.23 of this\nsubchapter.\nANR’s procedural manuals failed to include instructions enabling personnel to recognize safety-\nrelated conditions (SRCs) subject to § 191.23, and were therefore inadequate under § 192.605(d).\nSpecifically, ANR’s O&M Manual and January 2021 NETT Schedule and New Employee\nTechnical Training- Compliance Module (SRC Training Procedures) did not provide any\ninstructions enabling personnel who perform operation and maintenance activities to recognize\nconditions that potentially may be SRCs.\nDuring the inspection, the PHMSA inspectors requested ANR’s procedure regarding recognizing\nsafety related conditions. ANR provided the O&M Manual and referenced Section 191.23 therein.\nWhen the PHMSA inspectors re-requested procedures related to recognizing safety related\nconditions, ANR discussed that SRC training is included in on-board training for personnel. ANR\nprovided SRC Training Procedures. However, these documents were not referenced or\nincorporated into the O&M Manual. Furthermore, the SRC Training Procedures failed to provide\nany further guidance or instruction related to recognition of safety-related conditions.\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992)_text Page 3 of 5\n\n\n\nCPF 1-2021-051-NOA\nTherefore, ANR failed to include instructions in its procedures to enable personnel to recognize\nconditions that potentially may be safety-related conditions in accordance with § 192.605(d).\nANR must revise its procedures to address this requirement.\n5. § 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nANR’s Integrity Management Program (IMP) failed to require the operator to notify OPS of any\nchange to the program that may substantially affect its implementation or significantly modify the\nprogram or schedule for carrying out the program elements in accordance with § 192.909(b), and\nwas therefore inadequate to comply with § 192.907(a). Under § 192.909(b), an operator must\n“notify OPS, in accordance with §192.18, of any change to the program that may substantially\naffect the program's implementation or may significantly modify the program or schedule for\ncarrying out the program elements. An operator must provide notification within 30 days after\nadopting this type of change into its program.” Specifically, ANR’s O&M Manual and US-Gas-\nIMP US Onshore Gas Pipeline Integrity Management Program, dated 04/01/21 (IMP Manual)\nfailed to include procedures requiring the operator to notify PHMSA’s Office Pipeline Safety\n(OPS) within 30 days after adopting any change that may substantially affect the program’s\nimplementation or which may significantly modify the program or schedule.\nDuring the inspection, the PHMSA inspectors requested ANR’s procedure regarding § 192.909.\nANR provided the O&M Manual and referenced Section 192.18 therein. However, the O&M\nManual did not include the § 192.909 requirements. Furthermore, ANR provided the IMP Manual\nand referenced Section 13.4.1 therein. Section 13.4.1 of the IMP Manual stated that changes to\nthe integrity management program are made in accordance with the regulation.\nHowever, the IMP Manual failed to state that the operator must notify OPS within 30 days after\nadopting any change that may substantially affect the program’s implementation or which may\nsignificantly modify the program or schedule.\nTherefore, ANR failed to include adequate details in its integrity management procedures requiring\nnotification to OPS within 30 days after adopting any change that may substantially affect the\nprogram’s implementation, in accordance with § 192.909(b). ANR must revise its procedures to\naddress this requirement.\nOn September 27, 2021, ANR provided revised procedures relative to the original Notice issued\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992)_text Page 4 of 5\n\n\n\nCPF 1-2021-051-NOA\non July 16, 2021. My staff has reviewed the amended procedures, and it appears that the\ninadequacies outlined in the Notice have been corrected. Therefore, no further action is necessary,\nand this case is now closed. Thank you for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021051NOA_Notice of Amendment (Amended)_10142021_(21-198992)_text Page 5 of 5","truncated":false,"body_characters":28623}