{"operation":"document","citation":"CPF 220071009M","title":"SOUTH CAROLINA PIPELINE CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-05-22","effective_on":null,"summary":"CLOSED notice of amendment citing 192.905(b), 192.911(a), 192.911(k), 192.911(l), 192.915(a), 192.917(a), 192.917(c), 192.917(e)(1), 192.917(e)(3), 192.917(e)(5), 192.919(c), 192.925(b), 192.925(b)(3)(i), 192.925(b)(3)(ii), 192.933(a), 192.933(c), 192.933(d)(3), 192.935(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220071009M","body":"Notice of Amendment involving SOUTH CAROLINA PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 192.905(b),  192.911(a),  192.911(k),  192.911(l),  192.915(a),  192.917(a),  192.917(c),  192.917(e)(1),  192.917(e)(3),  192.917(e)(5),  192.919(c),  192.925(b),  192.925(b)(3)(i),  192.925(b)(3)(ii),  192.933(a),  192.933(c),  192.933(d)(3),  192.935(a). The case was opened on 2007-05-22 and is reported as closed as of 2008-01-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220071009M_notice of amendment_06182007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071009M/220071009M_notice%20of%20amendment_06182007.pdf\n\n220071009m_notice of amendment_06182007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071009M/220071009m_notice%20of%20amendment_06182007_text.pdf\n\n220071009M_notice sent_05222007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071009M/220071009M_notice%20sent_05222007.pdf\n\n220071009M_operator response_09172007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071009M/220071009M_operator%20response_09172007.pdf\n\n220071009M_notice sent_05222007.pdf\n\n,l \\t7\nU.5. Deporfment\nof Tronsporfotion\nPlpellno ond\nHozonlour ilsDadolr\nAdminl$rsrlon\n239 Peecnfee Streel Sle- 600\nAtanta,GA 30303\n3df.ty\n:\nNOTICE OF AMENDMENT\nCERTIF'IED MArL - RETLIRN RECETPT_BSOITESTEn\nMay 22,2007\nMr. Sarruel L. Dozier\nVice President and Commercial Field Operations\nCarolina Gas Transmission (CGT)\n105 New Way Road\nColumbia Souttr Carolina 29224-2407\ncP['2-2007-1009M\nDear Mr. Dozier:\nOn October 2-5 and October 23-26,2006, representatives of the Pipeline and Hazardous\nMaterials Safety Admifislplion (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Carolina Gas Transmission (CGT) procedures for gas integrity management program\nin Columbia\" South Carolina.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies for:nd within\nCGT plans or procedures, as described below:\n1. $le2.erl(a)\n$ 192.91f (a) An identifrcation of all high consequence orets' in accordance with\ns 192.90s.\n$ 192.905 IIow does an operator identify a high consequence area?\n. (a) General To determine which seguents of an operator'g transmission\npipeline system ere covered by this subpart, an operator must identify the high\ncorsequence areas. An operator must use method (1) or (2) from the definition\n\n\n\nin $192.903 to identify a high consequence area. An operator may apply one\nmethod to its entire pipetine system, or an operrtor may apply one method to\nindividual pofrions ofine pipetine system. An operator must describe in its\nintegrity -uoug\"*\"ot program which method it is applyingto each portion of\nthe Jpeiator's fipeline system- The description must include the potentirl\nimpact radius when utilized to establish a high consequence area.\n(bxl) Identifrcd sites. An operator must identify an identifred site' for purposeg\nitthi. subpart, from information the operator has obtained from routine\noperation and maintenance ectivities and from public olficials with safety or\ncmergency response or planning responsibilities who indicate to the operator\nthat they i*ow of locations that meet the identified site criteria. These pubHc\noffrcialscould include officials on e local emergency planning commission or\nrelevant Native American tribal officials.\n(2) If e public official with safety or emergency response or planning\n.\"rpoorlbilities informs an operator that it does not have the information to\niOentify an identilied site, the operator must use one of the following sources' 8s\nto identify these sites. (i) Visible marking (e-gua sign); or (ii) The\n\"pptoi\"i\"te,\nsite is licensed or registered by a Federal, State, or local goYernment agency; or\n(iii) The site is on a list (including a list on an intetnet web site) or map\nmaintained by or available from a Federalo State, or local goYenrment agency\nand avaihble to the general public.\n(c) Newly identifted areas. When an operator has information that the area\naround a pipeline segment not previously identified as a high consequence arel\ncould satisfy any of the delinitions in $ 192.903, the operator must complete the\nevaluation using method (1) or (2). If the segment is determined to meet the\ndefinition as a high consequetrce lre& it must be incorporated into the\noperator,$ baseline assessment plrn as a high consequence area within one year\nfrom the date the area is idenffied.\n$ f92.903 \\ilhat definitions apply to this subpart?\nHigh consequcilce area meuns ln lrea established by one of the methods\ndescribed in paragraphs (f) or (2) as follows:\n(f) An area defmed as{i) A Class 3 location under $ 192.5; or (ii) A Class 4\nlbcation under $ 192.5; or (iii) Any area in a Class 1 or Class 2 location where\nthe potential imprct radius is greater than 660 feet (200 meters), and the area\nwitnin a potential impact circle contains 20 or moIle buildings intended for\nhuman o\"copancy; or (iv) Any area in a Class I or Class 2location where the\npotential impact circle contrins rn identilied site.\n(2) The areawithin a potential impaet circle containing{i) 20 or more\nbuildings intended for human occupancy, unless the exception in paragraph (4)\napplies; or (ii) An identified site.\n\n\n\n(3) rwhere a potential impact circle is calculafed under either method (1) or (2)\nto establish a high consequence area' the length of the high consequence area\nextends axially atong thelength of the pipeline from the outermost edge of the\nfirst potential impact circle that contains either an identified site or 20 or more\nbuildlngs intended for human occupancy to the outermost edge of the last\n-\ncontiguius potentiat impact circle that contains either an identified site or 20 or\nmorelbuildings intended for human occupancy. {See Figure E.I.A. in appendix\nE.)\n{4) If in identifying a hrgh consequence arer under paragraph (lxiiD of this\ndefinition or panagnrph (2Xi) of this definition, the radius of the potential\nimpact circle is gr-atir than 660 feet (200 meters), the operetor mry identify a\nhigh conseqoence area based on a prortted number of buildings intended_for\nhumrn o.\"op\"o\"y within a distancl 660 feet (200 meters) from the centerline of\nthe pipeline until-December 17r2OO6.If an operator chooses this approachn the\nopeia-o\" must prorate the number of buildingr intended for human occupancy\nbased on the ratio of an trea with a radius of 660 feet (200 meterc) to the area\nof the potcntial impact circle (ie., the prorated number of buildingc intended\nfor human occupancy is equal to [20 x (560 feet [or 200 meters l/ potential\nimpact radius in feet for metersl) 2 l).\nIdentifud tite means each of the following areas: (a) An outside aret or open\nstructure that is occupied by twenty (20) or mono persorr$ on at least 50 days in\nany twelre (l2)-month period. (Ihe days need not be consecutive.) Examples\ninclude but are nsl limited to, beaches, playgrounds, recreational facilities'\ncamping grounds, outdoor theaters, stadiums, recreational ereas near a body\notwatei o\"\noutside a rural building such as a religious facility; or (b) A\n\"t\"\"s\nbuilding that is occupied by twenty (20) or more persons on at least live (5)\ndays a week for ten (10) weeks in any twelve (|2)-month period. (Ihe days and\nweeks need not be consecutive.) Examples include, but are not limited tor\nreligious facilities, office buildings, community centers, generll storesr'4-H\nfacilities, or roller skating rinks; or (c) A facility occupied by persons who are\nconfined, are of impaired mobilitV, or would be difficutt to evacuate. Examples\ninclude but are not limited to hospitals, prisons, schools, day-carc facilities'\nretircment facilities or assisted-living facilities.\nPotential impact circle is a circle of radius equal to the potential impact radius\n(PrR).\nPotentidl impact radi.us (PIR) metns the radius of a circle within which the\npotential failure of e pipeline could have significant impact on people or\nproperty. PIR is determined by the formula r = 0.69* (square root of (p*d 2))t\nwhere'r' is the radius of a circular anea in feet surrounding the point of\nfailure,'p' is the maximum allowable operating pressure (MAOP) in the\npipeline segment in pounds per square inch and ndt is the nominal diameter of\n\n\n\nthe pipeline in inches. Note: 0.69 is the factor for natural gas. This numberwill\nvary for other geses depending upon their heat of combustion. An operator\ntransporting gas other than natural gas must use section 3.2 of ASME/ANSI\n831.8-5-2001 (Supplement to ASME 831.8; ibr, see $ 192.7) to calculate the\nimpact radius formula. Remcdifiion is a repair or mitigation activity an_\noperator takes on a covered segment to limit or reduce the probability of an\nundesired event occurring or the expected consequences from the event.\nItem 1A: $ 192.905(a) and $ 192.903(2), (3), and (a)\nThere are no detailed procedures describing a repeatable process by which HCA maps\nare produced. Flow charts are being used that do not adequatety address the process\nus\"i to produce the maps. For example, the flow charts do not describe who is to\nperfornr-specific tasks and how they are to docume,lrt fhe output of those tasks. In\naddition, ihere is inadequate guidance for application of PIRs as they relate to identified\nsites. For example, no direction is provided that describes where a PIR is to be located\nin relation to a school with a playground.\nItem LB: $ 192.905(b) and $ 192.903(4)\nThere is no documentation of the basis for inclusion or exclusion of identified sites.\nAdditionally, no instruetions are provided regarding how to provide this documentation'\nItem LC: $ 192.9050)\nThere is a lack of instruction provided to emergency responders to ensure that they\nprovide consistent and quality feedback during events designed to obtain this\ninformation. There wasno documentation available to substantiate HCA identification\nupdates.\n$rez.er1G)\n$192.911(b) A baseline assessment plan meeting the requirements of $192.919 and\nsl92.921.\n$ f92.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(el Aetions to address particular thrests.If an operetor identifies flny of the\nfollowing threats, the operator must take the following actions to address the\nthreat\n(3) Manufacturing and construction defects. If an operator identifies the threat of\nmanufacturing and construction defects (including seam defects) in the covered\nsegment, an operator must an*lyze the covered segment to determine the risk of\nfnilure from these defects. The analysis must consider the results of prior\n\n\n\nassessments on the cov€red segment An operator may consider manufacturing\nand construction related defects to be stable defects ilthe operating pressure on\nthe covered segment has nOt increased over the maximum operating prcssune\nexperienced during the live years preceding identffication of the high coneequence\narea. If eny of the following changes occur in the covered segment' an operltor\nmust prioritize the covered segment as a high risk segment for the baseline\nassessment or a subsequent reassessment. (i) Operating pressure increases above\nthe maximo- op*\"\"tiog pressure experienced during the preceding five years; (ii)\nMAOP increasesl or (iii) The stresses teading to cyclic fatigue increase'\n(4) ERW pipe. If a covered pipeline segment contains low frequency electric\nwelded pipe @Rw), lap welded pipe or other pipe that satislies the\n\".*i*t\"oru\nconditions specifredin ASME/ANSI mf.$ S, Appendices A4.3 and A4'4' and any\ncovered or non-covered segment in the pipeline system with such pipe has\nexperienced seam failure, or operating pressure on the covered segment has\nincreased over the maximum operatingpnessure experienced during the preceding\nfive years, an operator must select an assessment technologr or technologies with a\np\"oo*o applicrtion capable of assessing sesm integrity and seam corrosion\nanomaUei. The operaior must prioritize the covered segment as a high risk\nsegment for the baseline assessment or a subsequent reasseesmenl\nS f92.919 What must be in the baseline assessment plan?\nAn operetor must include each of the following elements in its written baseline\nassessment plan:\n(a) tdentification of the potential threats to each covered pipeline segment rnd the\ninformation supporting the threat identilication. (See $f92.914\n(c) A schedule for completing the integrity assessment of all covered segments'\nincluding risk factors considered in establishing the assessment schedule;\n$ 192.921 How is the baseline assesgmeut to be conducted?\n{d) Thnc period\" Al operator must prioritize alt the covered segments for\nssse$sment in accordance with $ 192.917(c) and peragraph (b) of this section' An\noperator must assess at least 507o of the covered segments beginning with the\nhighest risk segments, by December 1712007. An operator must complete the\nbaseline assessment of all covered segments by Deeember 1712012.\n$ 192.933 What actions must be taken to address integrity issues?\n(bl Discovery of condition. Iliscovery of a condition occurs when an operator has\nadequate information about a condition to determine that the condition presents a\npotential threat to the integrity of the pipeline. A condition that presents a\npotential threat includes, but is not limited to, those conditions that require\nremediation or monitoring listed under paragraphs (dxl) through (dX3) of this\n\n\n\nsection. An operator must promptly, but no later than 180 days after conducting\nan integrity assessment, obtain sufficient information about a condition to make\nthat determination, unless the operator demonstrates that the 180-day period is\nimpracticable.\n§ 192.937 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(a) General. After completing the baseline integrity assessment of a covered\nsegment, an operator must continue to assess the line pipe of that segment at the\nintervals specified in § 192.939 and periodically evaluate the integrity of each\ncovered pipeline segment as provided in paragraph (b) of this section. An operator\nmust reassess a covered segment on which a prior assessment is credited as a\nbaseline under § 192.921(e) by no later than December 17, 2009. An operator must\nreassess a covered segment on which a baseline assessment is conducted during the\nbaseline period specified in § 192.921(d) by no later than seven years after the\nbaseline assessment of that covered segment unless the evaluation under\nparagraph (b) of this section indicates earlier reassessment.\n• Item 2A: § 192.917 (e)(3) and (4)\nCGT program and procedure requirements are inadequate to track MOP and MAOP\nchanges to ensure that stable long seam threats do not become unstable for both covered\nand non-covered segments.\n• Item 2B: § 192.919(c), § 192.921(l), § 192.933(b), and § 192.937(a)\nCGT does not have program requirements to ensure that the date for completion of field\nactivities for an assessment is recorded so that the timeframe for evaluating anomalies\nand reassessment date(s) can be accurately determined.\n3.\n§192.911(c)\n§192.911 (c) An identification of threats to each covered pipeline segment, which\nmust include data integration and a risk assessment. An operator must use the\nthreat identification and risk assessment to prioritize covered segments for\nassessment (§ 192.917) and to evaluate the merits of additional preventive and\nmitigative measures (§ 192.935) for each covered segment.\n§ 192.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(a) Threat identification. An operator must identify and evaluate all potential\nthreats to each covered pipeline segment. Potential threats that an operator must\nconsider include, but are not limited to, the threats listed in ASME/ANSI B31.8S\n(ibr, see § 192.7), section 2, which are grouped under the following four categories:\n6\n\n\n\n(1) Time dependent threats such as internal corrosion, external corrosion, and\nstress corrosion cracking; (2) Static or resident threats, such as fabrication or\nconstruction defects; (3) iime independent threats such as third party damage and\noutside force damage; and (4) Human error.\n(b) Data gilhering and integrati.on.To identify and evaluate the potential threats to\n\".o\"*rd pipeline segmeni; an operetor must gather and integrate existing_data\nand information on the entire pipeline that could be relevant to the covered\nsegment. In performing this data gathering aUd integration, an operator must\nfo[ow the requirements in ASME/AI\\[SI B3l.8S, section 4. At a minimum' an\noperator must gather and evaluate the set of data specified in Appendix A to\n.tSUf,laXSI B3l.8S, and consider both on the covered segment and similar non-\neovered segments, past incident history, corrosion control records, conlinuing\nsutTeillancu\n\"e\"o\"dr, patrolling records, maintenance history, internal inspection\nrecords and all other conditions specific to each pipeline'\n(c),Rrst assessmentAn operator must conduct a risk assessment that follows\n^q,SUnnnSI831.85, r*\"iioo 5, and considers the identified threats for each\ncovered segment. An operator must use the risk assessment to prioritize the\ncovered segments for tle baseline snd continual reassessments ($$ l92'919t\nlg1.g1l,tgZ,gST),and to determine what additional preventive and mitigative\nmeasures are needed ($ f92.935) for the covered cegment.\n(e) Acttons to address pafiicular thrcats, If an operator identifies any of the\nioitowing threats, the operator must take the following actions to address the\nthreat\n(ll Third pafi danuge,An operator must utilize the data integration required in\ni\"t\"g*pi O) of this section and ASME/ANSI B3l.8S, Appendix A7 to determine\nine suscep6bility of each covered segment to the threat of third party damage.If\nan operator identifies the threat of third prrty damage, the operator must\nimptement comprehensive additional preventive measure$ in accordance with\n$1i2.935 and monitor the effectiveness of the preventiv€ measurss.Ift in\nconducting a baseline lssessment under $192.921, or a reassessment under\n$192.93?, au operator uses an intemal inspection tool or external cotrosion direct\nassessment, the operator must integrate data from these rssessments with data\nrelated to eny eniroachment or foreign line crossing on the covered segment' to\ndefine where potential indications of third party damage may exist in the covered\nsegment.\nAn operator must also have procedures in its integrity management program\neddressing actions it will take to respond to findings frcm this data integration.\no ltem 3A: $ 192.917(a)\n\n\n\nCGT's IMP includes a statement (in Section 4.4) that threat interaction will be\nconsidered, but includes no process for implementation. The Kiefner model currently\nused by CGT, does not address threat interaction.\n• Item 3B: § 192.917(a)\nCGT has concluded, without an adequate documented basis, that three threats - stress\ncorrosion cracking, internal corrosion, and human error - are not threats of concern\nthroughout their system.\n• Item 3C: § 192.917(e)(1)\nThere is no procedure to assure that data on encroachments and foreign line crossings\nare integrated with ILI or ECDA results. This data integration process is required by\n192.917(e)(1) for addressing the threat of third-party damage.\n• Item 3D: § 192.917(c)\nCGT has insufficient description in its program to demonstrate that risk assessment is being\nused to address the objectives listed in ASME/ANSI B31.8S, other than risk ranking of HCA\nsegments.\n• Item 3E: § 192.917(c)\nThere are bai or tian he is a oris process to assure that riskhar prevalated on\n• Item 3F: § 192.917(c)\nThere is no detailed process to assure validation of risk results against\ncompany/industry experience.\n4.\n§192.911 (d)\n§192.911(d) A direct assessment plan, if applicable, meeting the requirements of §§\n192.923, and depending on the threat assessed, of 192.925, 192.927, or 192.929.\n§192.925 What are the requirements for using External Corrosion Direct\nAssessment (ECDA)?\n(b) General requirements. An operator that uses direct assessment to assess the\nthreat of external corrosion must follow the requirements in this section, in\nASME/ANSI B31.8S (ibr, see § 192.7), section 6.4, and in NACE RP 0502-2002\n(ibr, see § 192.7). An operator must develop and implement a direct assessment\nplan that has procedures addressing pre-assessment, indirect examination, direct\nexamination, and post-assessment. If the ECDA detects pipeline coating damage,\n8\n\n\n\nthe operator must also integrate the data from the ECDA with other information\nfrom the data integration ($ f92.9f?ft0 to evaluate the covered segment for the\nthreet of third psrty damage, and to address the threst as required by $\nre2.e17(e)(1).\n(l) pre-als essn ent,In addition to the requirements in ASME/AI\\SI 831.85 section\nG.l and NACE Rp 0502-2(X12, section 3, the plen's procedures for pre-assessment\nmust includ* (i) Provisions for applying more restrictive criteria when\nconducting ECDA for the first time on a cover.ed segment'\nQ\\ Indbect Examinatiott ln addition to the requirements in ASMEIAN$ 831.8S\niection 6.4 and NACE RP 0502-2002, section 4, the plan's procedures for indirect\nexamination of the ECIIA regions must include-\n(i) Provisions for applying more restrictive criteria when conducting ECDA for the\nfirst time on a covered segment;\n(ii) Criteria for identifying and documenting those indications that must be\nconsidered for excava*on anO direct examination. Minimum identification criteri|\ninclude the known sensitivities of assessment tools, the procedurw for using each\ntool, and the approach to be used for deereasing the physical spacing of indirect\nassessment tool readings when the presence of a defect is suspected;\n(iii) Criteria for defining the urgency of excavation and direct exrmination of erch\nindication identilied durtng ttre indiiect examination. These criterie must specify\nhow an operator wilt define the urgency of excavating the indication as immediate'\nscheduled or monitored; and 1iv; Criteria for scheduling excavation of indications\nfor each urgency level.\np) Direct wamination In addition to the requirements in ASME/ANSI B31.ES\nr\".tioo 6.4 and NACE RP 0502-2002, section 5, the plan's procedures for direct\nexemination of indications from the indirect examination must include\n(i) Provisions for apptying more restrictive criteria when conducting ECDA for the\nfirst time on a covered sesmsnll\n(ii) criteria for deciding what action should be taken if either:\n(A) Corrosion defects are discovered that exceed allowable limits (Section 5.5.2.2 of\nNACE RP0502-2002), or\n@) Root cause analysis reveals conditions forwhich ECDA is not suitable (Section\n5.6J of NACE RP0502-20v2).\n$ 192.937 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n\n\n\n(a) General. After completing the baseline integrity assessment of a covered\nsegment, an operator must continue to assess the line pipe of that segment at the\nintervals specified in § 192.939 and periodically evaluate the integrity of each\ncovered pipeline segment as provided in paragraph (b) of this section.\n(b) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure the integrity of each covered segment. The periodic evaluation\nmust be based on a data integration and risk assessment of the entire pipeline as\nspecified in § 192.917... For all other transmission pipelines, the evaluation must\nconsider the past and present integrity assessment results, data integration and\nrisk assessment information (§ 192.917), and decisions about remediation (§\n192.933) and additional preventive and mitigative actions (§ 192.935). An operator\nmust use the results from this evaluation to identify the threats specific to each\ncovered segment and the risk represented by these threats.\n• Item 4A: § 192.925(b)(3)(ii)(B)\nThere is no documented process for performing root cause analysis when the operator\nuncovers problems for which ECDA is not well suited.\n• Item 4B: § 192.925(b), § 192.917(a) and (c), and § 192.937(a) and (b)\nCGT has no documented process to continuously assess for SCC during the direct\nexamination step of the ECDA process. Further, there is no evidence that SCC\nassessments have been completed for examinations performed to date.\n• Item 4C: § 192.925(b)(3)(i)\nCGT could not identify provisions in its ECDA Plan or more restrictive criteria it\napplied when conducting the ECDA direct examination step for the first time on a\ncovered segment.\n§192.911(e)\n§192.911(e) Provisions meeting the requirements of § 192.933 for remediating\nconditions found during an integrity assessment.\n§ 192.933 What actions must be taken to address integrity issues?\n(a) General requirements... An operator must be able to demonstrate that the\nemediation of the condition will ensure that the condition is unlikely to pose ‹\nhreat to the integrity of the pipeline until the next reassessment of the coverer\nsegment...\n10\n\n\n\n...A reduction in operating pressure cannot exceed 365 days without an operltor\npnoviding r techniial justification that thc continued pressure restriction will not\nieopardize the integrity of the pipeline.\n(b) Discovery of condition. Discovery of a condition occutll when an operator has\nadeqoate in-formation about a condition to determine that the condition presents a\npoteoti\"l threat to the integrity of the pipeline. A condition that presents a\npotential thrcat includes, nut is not limited to, those conditions that require\nremediation or monitoring tisted under paragraphs (rilf) through (dX3) of this\nsection. An operator -orip.omPtlY, bui no later than 180 days after conducting\nan integrity assessment, obtain suflicient information about a condition to make\nthat determination, unless the operator demonstrates that the 180'day period is\nimpracticable.\n(c) Schedulefor evaluation and remcdiotion. An operator must complete\nremediation of a condition according to a schedule that prioritizes the conditions\nfor evaluation and remediation. Unless a special requirement for remediating\ncertain conditions applies, as provided in paragraph (d) of this section, an operator\nmust follow the scheiurc in ASME/AIrISI831.85 (ibr, see $192.7)' section 7' F'igure\n4. If an operator cannot meet the schedule for any condition, the operrtor must\njustrfy th.\n\".\"sons why it cannot meet the schedule and that the changed schedule\nwill not jeopardize public safety.\n(il) Speciat requbements for scheduling temediutian.-\ne) Monitored conditiow, An operator does not have to schedule the following\nconditions for remediation, but must record and monitor the conditions during\nsubsequent risk assessments and integrity assessments for any change that may\nrequire remediation:\n(i) A dent with a depth gre*ter then6Vo of the pipeline diameter (greater than 0.50\nilches in depth for a pi[e[ne dismeter less than NPS 12) located between the 4\no'clock position and the 8 otclock position ftottom l/3 of the pipe).\n(ii) A dent located between the 8 o'clock and 4 o'clock positions (upper 2 /3 of the\npibe) witfr a depth greater than 67o of the pipeline diameter (greater than 0'50\nioin*t in depth fori pipeline diameterlessthan Nominal Pipe Size (NPS) 12)' and\nengineering analyses oftUu dent demonstrrte critical strnin levels rre not exceeded.\n(iir) A dent with a depth greater thrrn2o/a of the pipeline's diameter (0.250 inches\nin depth for a pipeline diameter less than NPS 12) that affects pipe curuature at a\ngirth weld or a longitudinal seam weld, and engineering tnalyges of the dent and\ngi*tt o\" seam weld demonetrate critical strain levels are not exceeded. These\nanalyse must consider weld propertiee.\nr Item 5A: $ 192.933(c)\n11\n\n\n\nThe CGT IMP does not have a requirement to develop a schedule that prioritizes\nevaluation and remediation of anomalous conditions.\nItem 58: $ 192.933(dX3)\nThere are no detailed procedures to describe the process for recording anomalies that\nare classified as \"monitored conditionso'and monitoring them during subsequent risk\nassessments and reassessments.\nItem 5C: $ f92.933(c)\nThere are no detailed procedures describing a repeatable process by which technical\njustifications are produced when anomaly evaluation timeframes cannot be met-\nItem 5D: $ 192.933(c)\nThe CGT remediation schedule does not provide the criteria in Section 192.93J of the\nRule or in ASME B3l.8S which is the basis for remediation of the respective\nanomalies.\no Item 5F: $ f92.933(a)\nThere is inzufficient evidence in the CGT remediation records to demonstrate that an\nanomaly is unlikety to tlreaten the integrity of the pipeline before the next scheduled\nreassessment. The operator relies upon contractor's reports to provide this evidence,\nhowever the contractor's reports do not provide sufficient details for these conclusions.\nFor example, safe pressure calculations need to be documented to demonstrate thc basis\nof safety urtil reassessments are performed.\n6. $1e2.er1(h)\n$192.9110) Provisions meeting the requirements of $ 192.935 for adding\npreventive and mitigative measures to protect the high consequence area.\n$ 192.935 Whnt additionrl preventive and mitigative measures must an operator\ntake?\n(n) General requiremenls. An operator must take additional mettures beyond those\nalready rcquired by Pert 192 to prevent a pipeline failure and to mitigate the\nconsequences of a pipeline failure in a high consequence area. An operator must\nbase the additional measures on the threats the opsrator has identilied to each\npipeline segment. (^fee $ L92,917) An operator must conduct, in aecordance with\none of the risk assessment approaches in ASME/AIISI831.85 (ibr, see $ 192.7)'\nsection 5, a risk analysis of its pipeline to identify additional metsuros to protect\nthe high consequence area and enhance public safety. Such additional measures\nt2\n\n\n\ninclude, but are not limited to, installing Automatic Shut-off Valves or Remote\nControl Valves, installing computerized monitoring and leak detection systems,\nplacing pipe segments with pipe of heavier wall thickness, providing addition:\n\"aining to personnel on response procedures, conducting drills with loca\nemergency responders and implementing additional inspection and maintenance\nprograms.\n§ 192.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(e) Actions to address particular threats. If an operator identifies any of the\nfollowing threats, the operator must take the following actions to address the\nthreat.\n(5) Corrosion. If an operator identifies corrosion on a covered pipeline segment\nthat could adversely affect the integrity of the line (conditions specified in §\n192.933, the operator must evaluate and remediate, as necessary, all pipeline\nsegments (both covered and non-covered) with similar material coating and\nenvironmental characteristics. An operator must establish a schedule for\nevaluating and remediating, as necessary, the similar segments that is consistent\nwith the operator's established operating and maintenance procedures under part\n192 for testing and repair.\n• Item 6A: § 192.935(a)\nThe CGT IMP does not include an evaluation of threats, a spectrum of preventive and\nmitigative (P&M) alternatives, and the potential impact on the identified risks for HCA\nsegments.\n• Item 6B: § 192.917(e) (5)\nThere is a lack of program requirements to ensure that identified corrosion issues that\nmeet the \"immediate\" classification are evaluated for pipeline segments outside of\nHCAs.\n7.\n§192.911(k)\nSection 11) A management of change process as outined in ASME/ANSI B31.8S,\n§192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see\n$ 192.907) and evolves into a more detailed and comprehensive integrity\nmanagement program, as information is gained and incorporated into the\nprogram. An operator must make continual improvements to its program. The\n13\n\n\n\ninitial program framework and subsequent program must, at minimum, contain\nthe following elements. When indicated, refer to ASME/ANSI B31.85 (ibr, see §\n192.7) for more detailed information on the listed element.)\n• Item 7A: § 192.911(k)\nThe criteria used to determine when an MOC form is used to track physical changes to\nthe pipeline are inadequate. Physical changes are being made to the pipelines that are\nnot being tracked using the MOC process.\n• Item 7B: § 192.911(k)\nThe MOC process does not provide sufficient procedures to describe how a change\nidentifies affected documentation and how the change is communicated to affected\nparties.\n• Item 7C: § 192.911(k)\nThe MOC process does not have provisions to ensure that integrity management system\n-\nchanges are properly reflected in the pipeline system and that pipeline system changes\nare properly reflected in the integrity management program.\n8.\n§192.911(1)\n§192.911(1) A quality assurance process as outlined in ASME/ANSI B31.8S,\nSection 12.\n§192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see\nmanagement program, as information is gained and incorporated into the\nprogram. An operator must make continual improvements to its program. The\ninitial program framework and subsequent program must, at minimum, contain\nthe following elements. (When indicated, refer to ASME/ANSI B31.8S (ibr, see §\n192.7) for more detailed information on the listed element.)\n(I) A quality assurance process as outlined in ASME/ANSI B31.8S, section 12.\n§ 192.915 What knowledge and training must personnel have to carry out an\nintegrity management program?\n(a) Supervisory personnel. The integrity management program must provide that\ncach supervisor whose responsibilities relate to the integrity management program\npossesses and maintains a thorough knowledge of the integrity management\nprogram and of the elements for which the supervisor is responsible. The program\n14\n\n\n\nmust provide that any person who quelilies Ns a superrisor for the integrity\nmatragemcnt program has appropriate training or experience in the area for\nwhich the person is resPonsible.\n(b) Persozs who earry out assessments and anluate assessment resalts. The integrity\nmanagemcnt program must provide criteria for the qualification of any person-\n(f) Who conducts an integrity assessment allowed under this subpart; or (2) Who\nreviews and analyzes the results from an integrity assessment and evaluationl or\n(3) Who makes decisions on actions to be takeu based on these assessments.\n(c) Persons responsiblefor preventive and mitigetive mccsures. The integrity\nmanagemenr program must provide criteria for the qualification of any person-\n(f) Wio inpliments pr*enti\"u and mitigative measures to carry out this subpart'\ninctuding tfe marking and locating of buried structures; or (2) Who directly\nsupen'ises excavation work carried out in conjunction with an integrity\nassessment\n$ f92.7 Incorporation by reference.\n(a) Any documents or portions thereof iucorporated by refercnce in this part are\nincluOea in this part as though set out in full'When only a portion of a document is\nreferenced, the remainder is not incorporated in this part.\nr Item 8A: $ f92.91f0)\nCGT extensively uses contracted services to accomplish important aspects of its IMP.\nIn many areasi, th\" torp\"\"tion Team noted that CGT relies on its contactors to perfornr\nIMP related work without suffrcient guidance and quality as$rance procedures and\nprocesses.\nr ltem 8B: g f92.9f5(a), (b), and (c)\nCGT has not established qualification requirements for personnel participating in IMP\nactivities, including in-house personnel responsible for evaluating assessment results.\n15\n\n\n\n' Response to this Notice\nThis Notice is provided pursuant to 49 U.S.C. $ 6010S(a) and 49 C.F.R. $ 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCimptiance Proceedings. Please rcfer to this document and note the response options. Be\nadvised that all material you submit in response !o this enforcement action is subject to being\nmade publicly available. Hyou believe that any portion of your responsive mlerial qualifies\nfor confidential treatunent rurder 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document wirh the portions you believe qualify for\nconfidential treatnent redact,ed and an explanation of why you believe the redacted inforrration\nqualifies for confidential treafinent 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\nthis Notice and authorizes the Associate Adminisha0or for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue a Final Order'\nIl after opportunity for a hearing, you plans or procedures are found inadequate as alleged in\nthis Notice, yo,r *uy be ordered iounrrnd your plans or procedures to correct the inadequacies\n(49 C.F.R. S 190.237). If you are not contesting this Notice, we propose that 1ou submit your\namended procedwes to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amEsd\"6 procedures, this enforcement action will be closed.\nln correspondence concerning this matter, please refer to CPF 2-2007-1009M and, for each\ndocument you submit, please provide a copy in electronic fonnat whenever possible.\nSincerely,\nr |a\\ 0-r\n,Kj^-€lq\\W\nLinda Daugherty U \\J\nDirector, Southern\nPipetine and Hazardous Materials Safety Administration\nEnclosure: Response Optiorufor Pipeline Operators in Compliance Proceedings\n16\n\n220071009m_notice of amendment_06182007_text.pdf\n\nF Is 0M tMON1, 1UN 18 2007 15 00/8T 14 59/N 68024Ii8986 F 2\nSeawl L Ooxior\nYise Pressdenr\ntonenersxsl p, Fiekl Operations\nssiaiier@ssoaa, sara\nCAHOLlkA GAS\n75bSICfhflSSlON\nA SCAHA COMPANY\n3iuie 18, 2007\nVIA OVERNIGHT Dr. l IVKRY\nAND FACSIMILE\nMs Linda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Material Safety Administration\nU, S Department of Transportation\n233 Peachtree Street, Suite 600\nAtlanta, GA 30303\nRe' Carolina Gas Transmission Corporation, CPF 2-2007-1009M\nRequest For Extension of Time. or, in the Alternative, Request for\nHearing and Statement of Issues\nDear Ms, Daugherty:\nOn May 22, 2007, Carolina Gas Transmission Corporation (\"CGT\") received a Nouce of\nAmendment (\"NOA\") dated May 22, 2007, issued by the Southern Region of the Department of\nI ransportation's Office of Pipeline and Hazardous Materials Safety Administration (\"PHMSA\"),\nln the NOA, based on its review nf CGT's Integrity Management Program (\"IMP\") conducted in\nColumbia, South Carolina, during the weeks of October 2-5 and 23-26, 2006, PHMSA states that\nit has idenu lied apparent inadequacies within CGT's IMP plans or procedures\nCGT respectfully requests a ninety (90) day extension of time within which to respond to\nthc NOA, such that CGT's response to the Notice would be due September 19, 2007. CGl\nrequests this extension in order to (1) more fully review the items listed in the 'NOA; (2) secure\nnecessary assistance and staffing to revise the elcmcnts of CGT's IMP plan addressed in the\nNOA in a comprehensive aud consistent manner; and (3) address in more detail the items Iisted\nin d separate Notice of Proposed Violation, dated May 22, 2007, in Docket CPF-2-2007-1010,\nwhich arises out of the same audit that lead to the NOA\nTo ihe extent this request for an extension of time is denied, CGT hereby requests a\nhearing pursuant to 49 C. F. R. ( 190. 211 in order to present to PHMSA a proposal for developing\namended compliance procedures that appropriately comply with each of the regulations\nreferenced in the NOA, Pursu","truncated":true,"body_characters":40775}