{"operation":"document","citation":"CPF 220071018","title":"SOUTHERN NATURAL GAS CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-10-31","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.195(a), 192.465(a), 192.709(c), 192.731(a), 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220071018","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220071018","body":"Notice of Probable Violation involving SOUTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.195(a),  192.465(a),  192.709(c),  192.731(a),  192.739(a). The case was opened on 2007-10-31 and is reported as closed as of 2009-12-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220071018_FinalOrder_12282009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071018/220071018_FinalOrder_12282009.pdf\n\n220071018_FinalOrder_12282009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071018/220071018_FinalOrder_12282009_text.pdf\n\n220071018_NOPV letter_10312007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071018/220071018_NOPV%20letter_10312007.pdf\n\n220071018_nopv letter_10312007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071018/220071018_nopv%20letter_10312007_text.pdf\n\n220071018_operator response to notice_08012008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071018/220071018_operator%20response%20to%20notice_08012008.pdf\n\n220071018_operator response_01172008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071018/220071018_operator%20response_01172008.pdf\n\n220071018_FinalOrder_12282009_text.pdf\n\nDEC 28 2009\nMr. Bill Cope\nVice President, Eastern Pipeline Operations\nSouthern Natural Gas Company\nan El Paso Company\nP.O. Box 2563\nBirmingham, AL 35202-2563\nRE: CPF 2-2007-1018\nDear Mr. Cope:\nEnclosed is the Final Order issued in the above-referenced case. It makes findings of violation\nand finds that Southern Natural Gas Company has completed the actions specified in the Notice\nrequired to comply with the pipeline safety regulations. This case is now closed. Your receipt of\nthe Final Order constitutes service of that document under 49 C.F.R. §190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Kenneth Peters, Manager-DOT Compliance Services, Southern Natural Gas\nLinda Daugherty, Director, Southern Region, PHMSA\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 0390 0005 6162 5289]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n__________________________________________\nIn the Matter of )\nSouthern Natural Gas Company, ) CPF No. 2-2007-1018\nan El Paso Company )\n)\n)\nRespondent. )\n__________________________________________)\nFINAL ORDER\nBetween October 10, 2006 and December 1, 2006, pursuant to 49 U.S.C. § 60117, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office\nof Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of Southern Natural\nGas Company (Southern Natural or Respondent)’s facilities in Mississippi and Alabama and\nreviewed records at the offices in Heidelberg and Columbus, Mississippi and Tarrant and\nElmore, Alabama. Southern Natural Gas, a subsidiary of El Paso Corporation, is based in\nBirmingham, Alabama and transports natural gas through 8,000 miles of pipeline within the\nSoutheast region of the United States. As a result of the inspection, the Director, Southern\nRegion, OPS, issued to Respondent, by letter dated October 31, 2007, a Notice of Probable\nViolation and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207,\nthe Notice proposed finding that Respondent committed violations of 49 C.F.R. Part 192. The\nNotice also proposed ordering Respondent to take certain measures to correct the alleged\nviolations.\nIn a letter dated December 3, 2007, Respondent requested a 30-day extension of time to respond\nto the Notice. Respondent was granted an extension until January 18, 2008 to respond to the\nNotice. Southern Natural Gas responded to the Notice by letters dated January 17, 2008 and\nAugust 1, 2008 (Response). Respondent did not contest the allegations of violation but offered\nan explanation and provided information concerning the corrective actions it has taken.\nRespondent did not request a hearing, and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nIn its Response, Southern Natural Gas did not contest the allegations in the Notice that it violated\n49 C.F.R. Part 192, as follows:\n\n\n\n2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. §192.195(a), which states:\n§ 192.195 Protection against accidental overpressuring.\n(a) General requirements. Except as provided in §192.197, each\npipeline that is connected to a gas source so that the maximum allowable\noperating pressure could be exceeded as the result of pressure control\nfailure or of some other type of failure, must have pressure relieving or\npressure limiting devices that meet the requirements of §§192.199 and\n192.201\n§ 192.201 Required capacity of pressure relieving and limiting stations.\n(a) Each pressure relief station or pressure limiting station or group\nof those stations installed to protect a pipeline . . . must be set to operate,\nto insure the following. . . .\n(2) In pipelines other than a low pressure distribution system:\n(i) If the maximum allowable operating pressure is 60 p.s.i. (414 kPa)\ngage or more, the pressure may not exceed the maximum allowable\noperating pressure plus 10 percent or the pressure that produces a hoop\nstress of 75 percent of SMYS, whichever is lower. . . .\nThe Notice alleged that Respondent’s pressure limiting device located at the New Calera Tap\nfacility did not meet the requirements of §192.195(a). The New Calera Tap, located at North\nMain Line milepost 300.513 and installed in 1997, does not have a pressure relieving or pressure\nlimiting device that is set to operate at the pressure prescribed in §192.201(a)(2)(i). The North\nMain Line MAOP (525 psig) could be exceeded if the 16” check valve that isolates the 2nd North\nMain Line from the North Main Line was to catastrophically fail (pressure control failure or of\nsome other type of failure). It is not uncommon for pressure in the 2nd North Main Line to reach\n600 psig at this location.\nRespondent’s records indicate that pressure in the North Main Line at New Calera Tap is\nremotely monitored by Gas Control via SCADA and high pressure alarm(s). Also, Valve 4 at\nNew Calera Tap can be closed remotely by Gas Control to isolate the 2nd North Main Line from\nthe North Main Line. However, Valve 4 does not meet the requirements of §192.201(a)(2)(i) in\nthat the valve is not set to operate at the pressure prescribed in §192.201(a); the valve can only be\nclosed upon human action.\nIn its Response, Southern Natural Gas explained that it is taking steps to achieve compliance\nwith facility modifications, which will take approximately six months to complete. Respondent\nadvised it is reviewing its facilities1\nin PHMSA’s Southern Region to determine where similar\ninstallations exist. Respondent advised that its review identified only one installation on its\n1Generally includes all SNG facilities except those located in Louisiana, Texas, and offshore Gulf of\nMexico.\n\n\n\n3\nNorth Main Pipeline utilizing check valve to separate pipelines of differing MAOPs, the\nRoebuck Meter Station Tap, Milepost 328.854. Respondent explained that it will take six\nmonths for it to design and implement a viable alternative to achieve compliance. Respondent\nadvised that it will notify PHMSA when facility remediation is complete, even without a\ncompliance order.\nRespondent requested that the proposed compliance order be rescinded. Respondent suggested\nthat the proposed compliance order was unnecessary because of the remedial measures that it will\ntake to accomplish the intent of the proposed compliance order. Respondent suggested that the\nproposed compliance order is overly burdensome relative to the scope of its remedial measures.\nRespondent also suggested that under these circumstances it is appropriate for it to act on good\nfaith in lieu of the proposed order.\nContrary to Respondent’s position, the purpose of the compliance order is to ensure and achieve\ncompliance with the pipeline safety regulations applicable to its operations. Respondent has not\nprepared and submitted to PHMSA a written correction plan and schedule for a system-wide\nreview to identify devices that are not designed to operate at a set pressure in accordance with 49\nC.F.R. §§192.195(a) and 192.201(a)(2)(i). In its response, Respondent clearly states that its\nremedial measures “are expected to be completed within the next six months.” Respondent has\nnot demonstrated that the requirements in the proposed compliance order have been performed\nto ensure compliance with the pipeline safety regulations.\nRespondent’s New Calera Tap, located at North Main Line, does not have a pressure relieving or\npressure limiting device that is set to operate at the pressure prescribed in §192.201(a)(2)(i).\nCatastrophic failure of the 16” check valve, without an immediate response from Gas Control to\nclose Valve 4, could pressurize the North Main Line to a pressure significantly higher than the\nestablished MAOP, thus possibly reducing the safety margin that would be provided by a valve\nset to automatically close upon sensing a set pressure. Respondent does not have a pressure\nlimiting or a pressure relieving device set to operate if the MAOP is 60 p.s.i. (414 kPa) gage or\nmore, as the pressure may not exceed the maximum allowable operating pressure plus 10 percent\nor the pressure that produces a hoop stress of 75 percent of SMYS, whichever is lower.\nAccordingly, I find Respondent violated § 192.195(a) by failing to have a pressure limiting\ndevice located at the New Calera Tap facility meeting the requirements of § 192.201(a)(2)(i).\nItem 5: The Notice alleged that Respondent violated 49 C.F.R. §192.739(a), which states:\n§ 192.739 Pressure limiting and regulating stations: Inspection and\ntesting.\n(a) Each pressure limiting station, relief device (except rupture\ndiscs), and pressure regulating station and its equipment must be subjected\nat intervals not exceeding 15 months, but at least once each calendar year, to\ninspections and tests to determine that it is--\n(1) In good mechanical condition;\n\n\n\n4\n(2) Adequate from the standpoint of capacity and reliability of\noperation for the service in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to\ncontrol or relieve at the correct pressure consistent with the pressure limits of\n§192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other\nconditions that might prevent proper operation….\nThe Notice alleged that Respondent did not inspect and test its 16” check valve located between\nvalve numbers 1 and 2 at New Calera Tap (MP 300.513 North Main Line, MP 178.016 2nd North\nMain Line), as required by §192.739(a). The check valve is considered by PHMSA to be a\npressure limiting station because it effectively isolates the North Main Line (525 psig MAOP)\nfrom the 2nd North Main Line (750 psig MAOP), and could conceivably fail. It is not uncommon\nfor pressure in the 2nd North Main Line to reach 600 psig at this location. The check valve should\nbe inspected and tested at the referenced frequency, to ensure it operates and seals as designed (is\nin good mechanical condition), and is properly installed and protected. During the inspection,\nRespondent did not provide inspection and test records.\nIn its Response, Respondent explained that it is taking steps to achieve compliance with piping\nmodifications, which will take approximately six months to complete. Respondent advised it has\ninitiated a review of its facilities in PHMSA’s Southern Region to determine where similar\ninstallations exist. Respondent advised that its review found only one installation utilizing check\nvalves to separate pipelines of differing MAOPs, the Roebuck Meter Station Tap, Milepost\n328.854 on its North Main Pipeline. Respondent explained that it will take six months for it to\ndesign and implement a viable alternative to achieve compliance for the New Calera Tap.\nSection 192.739(a) requires an operator, at specified intervals, to inspect and test each pressure\nlimiting station, relief device, and pressure regulating station and its equipment to determine that\nthe device is in good mechanical conditions, is adequate for the service for which it is used and\nset to control or relieve at correct pressure. Failure to insure that all relief devices are properly\nfunctioning creates the risk that one or all devices may not operate correctly in the event of an\nemergency. This regulation provides safety precautions that minimize the risk of accident or\ninjury to human life, the environment and property during an emergency. Respondent did not\ninspect and test its 16” check valve within the required intervals to determine that the device is\nfunctioning properly. Accordingly, I find Respondent violated §192.739(a) by failing to inspect\nand test its 16” check valve within the required intervals to assure it operates and seals as\ndesigned (is in good mechanical condition) and is properly installed and protected.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\n\n\n\n5\nCOMPLIANCE ORDER\nThe Notice proposed a Compliance Order with regards to Items 1 and 5 in the Notice for\nviolations of 49 C.F.R. Part 192.\nUnder 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns\nor operates a pipeline facility is required to comply with the applicable safety standards\nestablished under chapter 601. In letter dated August 1, 2008, Southern Natural Gas Company\nindicated that it accomplished the remedial measures required by the proposed Compliance\nOrder. The Director has indicated that Respondent has taken the following actions specified in\nthe proposed compliance order:\n1. In regard to Item Number 1 of the Notice pertaining to pressure relieving or pressure\nlimiting devices required of §192.195(a), Southern Natural Gas (SNG) completed piping\nmodifications to isolate check valves and prevent accidental over pressuring of pipelines\nwith differing MAOPs. These modifications ensure over pressure protection is provided\nby the existing regulators and monitoring stations at the New Calera Tap location.\n2. In regard to Item Number 5 of the Notice pertaining to the requirement to inspect and test\ncheck valves that operate in compliance with §192.739(a), SNG reviewed its system in\nthe Southern Region and found one additional location where a check valve might have\ncome into play in preventing an accidental over pressure situation with two pipelines of\ndiffering MAOPs. This facility is located at the Cartersville No. 2 Meter Station at\nMilepost 46.005 on SNG’s Rome-Calhoun pipeline. SNG closed and locked the\nseparating valve and eliminated dual feed capability at this station to ensure over pressure\nprotection. If the other pipelines need additional gas supply, the valves will be manually\ncontrolled to ensure the two Rome-Calhoun pipelines remain isolated from each other.\n3. SNG also modified the pressure controls at the Roebuck Meter Station Tap facility to\nprevent a pipeline with higher MAOP from releasing gas pressure into a pipeline of lower\nMAOP. Software logic was installed, tested and proven to perform as designed and will\nbe tested once per calendar year not to exceed 15 months.\n4. In accordance with §192.739(a), SNG has also completed a system wide review beyond\nthe Southern Region and found no other situations where check valves were being used as\nprimary over pressure protection devices.\nAccordingly, since compliance has been achieved with respect to these violations, the\ncompliance terms are not included in this Order.\n\n\n\n6\nWARNING ITEMS\nWith respect to Items 2, 3, and 4, the Notice alleged probable violations of Part 192 but did not\npropose a civil penalty or compliance order for these items. Therefore, these are considered to be\nwarning items. The warnings were for:\n49 C.F.R. § 192.465(a) (Notice Item 2) ─ Respondent’s alleged failure to test the\ncathodically protected North Alabama Pipeline at least once each calendar year,\nbut with intervals not exceeding 15 months between MP 32.216 and MP 122.175;\n49 C.F.R. § 192.709 (c) (Notice Item3) ─ Respondent’s alleged failure to\nmaintain records required by §192.709(c) relating to surveys performed in\naccordance with §§192.625 Odorization of gas, 192.705 Transmission lines:\nPatrolling, and 192.706 Transmission lines: Leakage surveys; and\n49 C.F.R. § 192.731 (a) (Notice Item4) ─ Respondent’s alleged failure to\nadequately test the Gwinville Compressor Station high pressure shutdown devices\n(Unit nos. 10 and 12) at intervals not exceeding 15 months, as required by\n192.731(a).\nRespondent presented information in its Response showing that it had taken certain actions to\naddress the cited items. Having considered such information, I find, pursuant to 49 C.F.R. §\n190.205, that probable violations of 49 C.F.R. § 192.465(a) (Notice Item 2 ), 49 C.F.R. §\n192.709(c) (Notice Item 3) and 49 C.F.R. § 192.731 (a) (Notice Item 4) have occurred and\nRespondent is hereby advised to correct such conditions. In the event that OPS finds a violation\nfor any of these items in a subsequent inspection, Respondent may be subject to future\nenforcement action.\nThe terms and conditions of this Final Order are effective upon receipt.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":17542}