{"operation":"document","citation":"CPF 220071006M","title":"OZARK GAS TRANSMISSION, L.L.C — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-04-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.911, 192.911(c), 192.933(d)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220071006M","body":"Notice of Amendment involving OZARK GAS TRANSMISSION, L.L.C. PHMSA's enforcement data identifies the cited regulations as 192.911,  192.911(c),  192.933(d)(1). The case was opened on 2007-04-17 and is reported as closed as of 2007-06-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220071006M notice letter_04172007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071006M/220071006M%20notice%20letter_04172007.pdf\n\n220071006m notice letter_04172007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071006M/220071006m%20notice%20letter_04172007_text.pdf\n\n220071006M_Operator Response to notice letter_05142007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071006M/220071006M_Operator%20Response%20to%20notice%20letter_05142007.pdf\n\n220071006m notice letter_04172007_text.pdf\n\nO\nU 5 Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n233 Peachtree Street Sts 600\nAtlanta, GA 30303\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApnl 17, 2007\nMr Tom Williams\nSenior Vice President\nOzark Gas Transmission — Atlas Pipehne Mid-Continent, LLC\n1437 South Boulder, Suite 1500\nTulsa, OK 74119\nCPF 2-2007-1006M\nDear Mr Wilhams\nOn June 6-8, 2006 and June 20, 2006, representatives of the Pipeline and Hazardous Mateinals\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nthe Ozark Gas Transmission Integnty Management Plan (IMP) in Tulsa, Oklahoma\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nthe Ozark Gas Transmission Integrity Management Plan, as described below\n1. II192. 911 What are the elements of an integrity management program? An\noperator's initial integrity management program begins with a framework (see\ntt192. 907) and evolves into a more detaded and comprehensive mtegrtty\nmanagement program, as information is gained and incorporated into the\nprogram. An operator must make contmual improvements to its program. The\ninitial program framework and subsequent program must, at minimum, contain\nthe elements (a) thru (p) in tf192. 911. (When indicated, refer to ASME/ANSI\nB31. 8S (ibr, see tf192. 7) for more detaded mformation on the listed element. )\na The Ozark Gas Transmission (OGT) IMP documentation must have sufficient\ndetail about IMP processes (e g data gathenng, questionable data) to understand\nhow a task is performed The details should include the following\n\n\n\n~ Who owns/is responsible for the task,\n~ What are the goals/ob) ectives of the task,\n~ What data/information/resources is required to complete the task,\n~ How is the task to be completed,\n~ When or how often is the task to be completed,\n~ Are key elements to the task completion documented,\n~ Where is task documentation stored,\n~ Are task outputs/results communicated to key personnel,\n~ Is there a method for process improvement (reviews/feedback loops)\nPrior to the close of the inspection, OGT updated the Responsibihties Matnx in Section\n3 of the IM Program manual and added titles and section numbers in Appendix B to\naddress the first bullet of this issue The remaining items on this issue remained open at\nthe close of the inspection\n2. (1192. 911(c) What are the elements of an mtegrity management program? An\nidentification of threats to each covered pipehne segment, which must mclude data\nintegration and a risk assessment. An operator must use the threat identification\nand risk assessment to prioritize covered segments for assessment (11192. 917) and\nto evaluate the ments of additional preventive and mitigative measures ((1192. 935)\nfor each covered segment.\na The IMP Section 6 I 3 2 identifies \"typical data sources\", aud Section 6 1 3 3\ndiscusses integrating data OGT gathered data for the entire pipehne, not)ust\nHCAs The inspection team noted that additional detail was needed on the\nprocesses and procedures (e g IMP-6-003 Section 2 1 6) for identifying threats\nand data integration\n3. 11192. 933(d)(1) Immediate Repair conditions. An operator's evaluation and\nremediation schedule must follow ASME/ANSI B31. S, section 7 in providing for\nimmediate repair conditions. To maintam safety, an operator must temporardy\nreduce operatmg pressure in accordance with paragraph (a) of this section or shut\ndown the pipehne untd the operator completes the repair of these conditions.\na OGT needs to provide more detail on how the process for discovery of\nimmediate conditions is implemented, starting with the first receipt of\nprehminary assessment information to discovery following final report\ninformation from the pigging vendor Prior to the close of the inspection, OGT\nclarified the requirement for pressure reduction and remediation within five days\nby modifying Section 6 3 3 I of the IMP to state, \"The operator shall examine\nthese mdications withm a pemod not to exceed five days following determmation\nof the condition After examination and evaluation any defect found to require\nrepair or removal shall be promptly remedkated by repair or removal unless the\noperating pressure ts lowered to mitigate the need to repair or remove the\ndefect \" Please provide a copy of the revised procedure to the PHMSA\nSouthern Region Office\n\n\n\nb OGT needs to address how multiple immediate conditions discovered dunng an\nassessment covenng multiple covered segments are individually prhoihthzed and\nscheduled for remediation Prior to the close of the inspection, OGT modified\nSection 2 4 2 of IMP-6-017 to state, \"Pmomtize the evaluation and remediation\nof mdhvidual anomahes within the HCA segments porn highest to lowest msk\nutilizmg the Gas Ph eline Risk Assessment IMP-6-003 procedure \" Please\nprovide a copy of the revised procedure to the PHMSA Southern Region Office\nc OGT did not have provisions in their IMP or implementing procedures to\nschedule and remediate anomalies ansing from threat conditions that do not\nmeet the classification criteria of II192 933(c) Pnor to the close of the\ninspection, OGT modifie Table 1, Scheduhng Requirements by Type of\nCondition, in IMP-6-018 to address this issue by adding the following \"Any\nmdkcation, anomaly, or other condition that is not hsted m the above\ncategomzed items that reduces the integmty of the lme such that it warrants\nremediation \" Please provide a copy of the revised procedure to the PHMSA\nSouthern Region Office\nRes onse to this Notice\nTins Notice is provided pursuant to 49 U S C Ih 60108(a) and 49 C F R Ih 190 237 Enclosed\nas part of this Notice is a document entitled Response Options for Pipelme Operators hn\nCompliance Proceedings Please refer to this document and note the response options Be\nadvised that all material you submit in response to this enforcement action is sublect to being\nmade publicly available If you believe that any portion of your responsive matenal quahfies\nfor confidential treatment under 5 U S C 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe quahfy for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nquahfies for confidential treatment under 5 U S C 552(b). If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\ntins Notice and authorizes the Associate Admmistrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue a Final Order\nIf, Mer opportumty for a heanng, your plans or procedures are found inadequate as alleged hn\ntlus Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C F R Ih 190 237) If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 45 days of receipt of this Notice Ttus period may be\nextended by written request for good cause Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed\n\n\n\nIn correspondence concerning this matter, please refer to CPF 2-2007-1006M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible\nSincerely, (\nLinda Daugherty\nDirector, Southern Region\nPipehne and Hazardous Materials Safety Administration\nEnclosure Response Options for Pipelme Operators m Compliance Proceedings","truncated":false,"body_characters":8418}