OZARK GAS TRANSMISSION, L.L.C — Notice of Amendment

party submissionOfficial PDF220071006M_Operator Response to notice letter_05142007.pdf#

220071006m notice letter_04172007_text.pdf, page 1Official PDFO U 5 Department of Transportation Pipeline and Hazardous Materials Safety Administration 233 Peachtree Street Sts 600 Atlanta, GA 30303 NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT RE UESTED Apnl 17, 2007 Mr Tom Williams Senior Vice President Ozark Gas Transmission — Atlas Pipehne Mid-Continent, LLC 1437 South Boulder, Suite 1500 Tulsa, OK 74119 CPF 2-2007-1006M Dear Mr Wilhams On June 6-8, 2006 and June 20, 2006, representatives of the Pipeline and Hazardous Mateinals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Ozark Gas Transmission Integnty Management Plan (IMP) in Tulsa, Oklahoma On the basis of the inspection, PHMSA has identified the apparent inadequacies found within the Ozark Gas Transmission Integrity Management Plan, as described below 1. II192. 911 What are the elements of an integrity management program? An operator's initial integrity management program begins with a framework (see tt192. 907) and evolves into a more detaded and comprehensive mtegrtty management program, as information is gained and incorporated into the program. An operator must make contmual improvements to its program. The initial program framework and subsequent program must, at minimum, contain the elements (a) thru (p) in tf192. 911. (When indicated, refer to ASME/ANSI B31. 8S (ibr, see tf192. 7) for more detaded mformation on the listed element. ) a The Ozark Gas Transmission (OGT) IMP documentation must have sufficient detail about IMP processes (e g data gathenng, questionable data) to understand how a task is performed The details should include the following#

220071006m notice letter_04172007_text.pdf, page 2~ Who owns/is responsible for the task, ~ What are the goals/ob) ectives of the task, ~ What data/information/resources is required to complete the task, ~ How is the task to be completed, ~ When or how often is the task to be completed, ~ Are key elements to the task completion documented, ~ Where is task documentation stored, ~ Are task outputs/results communicated to key personnel, ~ Is there a method for process improvement (reviews/feedback loops) Prior to the close of the inspection, OGT updated the Responsibihties Matnx in Section 3 of the IM Program manual and added titles and section numbers in Appendix B to address the first bullet of this issue The remaining items on this issue remained open at the close of the inspection 2. (1192. 911(c) What are the elements of an mtegrity management program? An identification of threats to each covered pipehne segment, which must mclude data integration and a risk assessment. An operator must use the threat identification and risk assessment to prioritize covered segments for assessment (11192. 917) and to evaluate the ments of additional preventive and mitigative measures ((1192. 935) for each covered segment. a The IMP Section 6 I 3 2 identifies "typical data sources", aud Section 6 1 3 3 discusses integrating data OGT gathered data for the entire pipehne, not)ust HCAs The inspection team noted that additional detail was needed on the processes and procedures (e g IMP-6-003 Section 2 1 6) for identifying threats and data integration 3. 11192. 933(d)(1) Immediate Repair conditions. An operator's evaluation and remediation schedule must follow ASME/ANSI B31. S, section 7 in providing for immediate repair conditions. To maintam safety, an operator must temporardy reduce operatmg pressure in accordance with paragraph (a) of this section or shut down the pipehne untd the operator completes the repair of these conditions. a OGT needs to provide more detail on how the process for discovery of immediate conditions is implemented, starting with the first receipt of prehminary assessment information to discovery following final report information from the pigging vendor Prior to the close of the inspection, OGT clarified the requirement for pressure reduction and remediation within five days by modifying Section 6 3 3 I of the IMP to state, "The operator shall examine these mdications withm a pemod not to exceed five days following determmation of the condition After examination and evaluation any defect found to require repair or removal shall be promptly remedkated by repair or removal unless the operating pressure ts lowered to mitigate the need to repair or remove the defect " Please provide a copy of the revised procedure to the PHMSA Southern Region Office#

220071006m notice letter_04172007_text.pdf, page 3b OGT needs to address how multiple immediate conditions discovered dunng an assessment covenng multiple covered segments are individually prhoihthzed and scheduled for remediation Prior to the close of the inspection, OGT modified Section 2 4 2 of IMP-6-017 to state, "Pmomtize the evaluation and remediation of mdhvidual anomahes within the HCA segments porn highest to lowest msk utilizmg the Gas Ph eline Risk Assessment IMP-6-003 procedure " Please provide a copy of the revised procedure to the PHMSA Southern Region Office c OGT did not have provisions in their IMP or implementing procedures to schedule and remediate anomalies ansing from threat conditions that do not meet the classification criteria of II192 933(c) Pnor to the close of the inspection, OGT modifie Table 1, Scheduhng Requirements by Type of Condition, in IMP-6-018 to address this issue by adding the following "Any mdkcation, anomaly, or other condition that is not hsted m the above categomzed items that reduces the integmty of the lme such that it warrants remediation " Please provide a copy of the revised procedure to the PHMSA Southern Region Office Res onse to this Notice Tins Notice is provided pursuant to 49 U S C Ih 60108(a) and 49 C F R Ih 190 237 Enclosed as part of this Notice is a document entitled Response Options for Pipelme Operators hn Compliance Proceedings Please refer to this document and note the response options Be advised that all material you submit in response to this enforcement action is sublect to being made publicly available If you believe that any portion of your responsive matenal quahfies for confidential treatment under 5 U S C 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe quahfy for confidential treatment redacted and an explanation of why you believe the redacted information quahfies for confidential treatment under 5 U S C 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in tins Notice and authorizes the Associate Admmistrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order If, Mer opportumty for a heanng, your plans or procedures are found inadequate as alleged hn tlus Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C F R Ih 190 237) If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 45 days of receipt of this Notice Ttus period may be extended by written request for good cause Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed#

220071006m notice letter_04172007_text.pdf, page 4In correspondence concerning this matter, please refer to CPF 2-2007-1006M and, for each document you submit, please provide a copy in electronic format whenever possible Sincerely, ( Linda Daugherty Director, Southern Region Pipehne and Hazardous Materials Safety Administration Enclosure Response Options for Pipelme Operators m Compliance Proceedings#