{"operation":"document","citation":"CPF 220081009M","title":"RATON GAS TRANSMISSION CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-12-16","effective_on":null,"summary":"CLOSED notice of amendment citing 192.243(b)(1), 192.453, 192.455(a)(1), 192.463(a), 192.471(a), 192.479(a), 192.491(c), 192.605(b)(2), 192.615(b), 192.615(b)(2), 192.911.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220081009M","body":"Notice of Amendment involving RATON GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192.243(b)(1),  192.453,  192.455(a)(1),  192.463(a),  192.471(a),  192.479(a),  192.491(c),  192.605(b)(2),  192.615(b),  192.615(b)(2),  192.911. The case was opened on 2008-12-16 and is reported as closed as of 2010-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220081009M_closure letter_12142010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_closure%20letter_12142010.pdf\n\n220081009M_closure letter_12142010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_closure%20letter_12142010_text.pdf\n\n220081009M_notice of amendment_12162008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_notice%20of%20amendment_12162008.pdf\n\n220081009m_notice of amendment_12162008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009m_notice%20of%20amendment_12162008_text.pdf\n\n220081009M_operator response_02122009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_operator%20response_02122009.pdf\n\n220081009M_operator response_08102009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_operator%20response_08102009.pdf\n\n220081009M_revised IM procedures associated with operator response dated _02122009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_revised%20IM%20procedures%20associated%20with%20operator%20response%20dated%20_02122009.pdf\n\n220081009M_revised OM manual associated with operator response dated _02122009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_revised%20OM%20manual%20associated%20with%20operator%20response%20dated%20_02122009.pdf\n\n220081009M_revised OQ plan associated with operator response dated _02122009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081009M/220081009M_revised%20OQ%20plan%20associated%20with%20operator%20response%20dated%20_02122009.pdf\n\n220081009m_notice of amendment_12162008_text.pdf\n\nU. S. Department\nof Transportation\nPlpetlne ond\nHazardous Materials Safety\nAdministration\n233 Peachtree Street Ste. 600\nAtlanta, GA 30303\nNOTICE OF AMENDMENT\nD\nDecember 16, 2008\nMr. David N. Link\nVice President\nRaton Gas Transmission\n223 N. Guadalupe //274\nSanta Fe, New Mexico 87501-1850\nCPF 2-2008-1009M\nDear Mr. Link:\nOn July 22 — 24 and August 5 — 6, 2008, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Raton Gas Transmission's (Raton) procedures for operator qualification (OQ),\npipeline integrity management (IM), and operations and maintenance in Raton, New Mexico.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nRaton's plans or procedures, as described below:\nt)192. 911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see\nea\n192. 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\ninitial program framework and subsequent program must, at minimum, contain\nthe following elements. (When indicated, refer to ASMK/ANSI B31. 8S (ibr, see tt\n192. 7) for more detailed information on the listed element. )\n(p) A process for identification and assessment of newly-identified high\nconsequence areas. (See tI 192. 905 and tt 192. 921. )\nt'1192. 905(c) Newly identified areas. When an operator has information that the\narea around a pipeline segment not previously identified as a high consequence\narea could satisfy any of the definitions in ta 192. 903, the operator must complete\nthe evaluation using method (I) or (2). If the segment is determined to meet the\ndefinition as a high consequence area, it must be incorporated into the operator's\n\n\n\nbaseline assessinent plan (BAP) as a high consequence area within one year from\nthe date the area is identified.\nRaton's Pipeline Integrity Management Plan, Revised August I, 2008 states that on an\nannual basis Raton's transmission pipeline system will be reviewed for high\nconsequence area identification by the maintenance crew walking the pipeline using\nPatrolling Form 11000 found in Procedure 30 of Raton's Operations and Maintenance\n(O&M) Manual looking for identified sites within 100 meters of the pipeline. Neither\nProcedure 30 of Raton's O&M Manual, nor Form 11000, addresses the check for\nidentified sites nor defines what an identified site is.\n2. $192. 605 Procedural manual for operations, inaintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once\neach calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations\nwhere operations and maintenance activities are conducted.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\n(j192. 479 Atmospheric corrosion control; General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\nRaton's O&M Manual Procedure 200 — External Corrosion Control — Monitoring\nrequires that above ground pipelines or portions of pipelines exposed to the atmosphere\nbe inspected and any areas of atmospheric corrosion found shall be cleaned and either\ncoated or jacketed with a material suitable to prevent atmospheric corrosion. The\nprocedure does not require that each pipeline or portion of pipeline that is exposed to\nthe atmosphere be coated to prevent atmospheric corrosion, just those on which\natmospheric corrosion has been found.\n$192. 455 External corrosion control: Buried or submerged pipelines installed after\nJuly 31, 1971.\n(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or\nsubmerged pipeline installed after July 31, 1971, must be protected against\nexternal corrosion, including the following:\n(1) It must have an external protective coating meeting the requirements of\n$192. 461.\n\n\n\n(j192. 461 External corrosion controL Protective coating.\n(a) Each external protective coating, whether conductive or insulating, applied for\nthe purpose of external corrosion control must—\n(1) Be applied on a properly prepared surface;\n(2) Have sufficient adhesion to the metal surface to effectively resist underfilm\nmigration of moisture;\n(3) Be sufficiently ductile to resist cracking;\n(4) Have sufficient strength to resist damage due to handling and soil stress; and,\n(5) Have properties compatible with any supplemental cathodic protection.\n(b) Each external protective coating which is an electrically insulating type must\nalso have low moisture absorption and high electrical resistance.\n(c) Each external protective coating must be inspected just prior to lowering the\npipe into the ditch and backfilling, and any damage detrimental to effective\ncorrosion control must be repaired.\n(d) Each external protective coating must be protected from damage resulting\nfrom adverse ditch conditions or damage from supporting blocks.\nRaton's O&M Manual Procedure 200 — External Corrosion Control — Monitoring and\nProcedure 190 — Examination of Exposed Pipe and Determination of Remaining\nStrength require that each buried or submerged pipeline be protected by the installation\nof an acceptable external protective coating and that the coating be properly applied\nafter cleaning the pipe to bare metal. Raton's procedures do not address the\nrequirements for an acceptable coating, that it be protected from damage, nor that it be\ninspected prior to backfilling. Raton uses Tape Coat and coal tar as it's approved\nexternal protective coatings and this is not addressed in the procedures.\ntj192. 463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide a level\nof cathodic protection that complies with one or more of the applicable criteria\ncontained in Appendix D of this part. If none of these criteria is applicable, the\ncathodic protection system must provide a level of cathodic protection at least\nequal to that provided by compliance with one or more of these criteria.\nAppendix D — Criteria for Cathodic Protection and Determination of Measurements\nI. Criteria for cathodic protection—\nA. Steel, cast iron, and ductile iron structures.\n(1) A negative (cathodic) voltage of at least tLS5 volt, with reference to a\nsaturated copper-copper sulfate half cell. Determination of this voltage must be\nmade with the protective current applied, and in accordance with sections II\nand IV of this appendix.\nII. Interpretation of voltage measurement. Voltage (IR) drops other than those\nacross the structure electrolyte boundary must be considered for valid\ninterpretation of the voltage measurement in paragraphs A(1) and (2) and\nparagraph B(1) of section I of the appendix.\nRaton's O&M Manual Procedure 200 — External Corrosion Control — Monitoring\nestablishes a protective level of at least negative 0. 85 volts DC with the protective\n\n\n\ncurrent applied. Raton has a sacrificial anode cathodic protective system and Raton\ntechnicians take readings with the protective current applied and with the current\ninterrupted to produce an IR free reading. The requirement to consider IR drop is uot\naddressed in the procedure, nor does the procedure reflect the task being performed by\nRaton technicians which accounts for IR drop.\ntj192. 453 GeneraL The corrosion control procedures required by $192. 605(b)(2),\nincluding those for the design, installation, operation, and maintenance of cathodic\nprotection systems, must be carried out by, or under the direction of, a person\nqualified in pipeline corrosion control methods.\nRaton's procedures do not address that the corrosion control procedures will be carried\nout by, or under the direction of, a person qualified in pipeline corrosion control\nmethods.\ntj192. 471 External corrosion controL Test leads.\n(a) Each test lead wire must be connected to the pipeline so as to remain\nmechanically secure and electrically conductive.\n(b) Each test lead wire must be attached to the pipeline so as to minimize stress\nconcentration on the pipe.\n(c) Each bared test lead wire and bared metallic area at point of connection to the\npipeline must be coated with an electrical insulating material compatible with the\npipe coating and the insulation on the wire.\nRaton's 08cM Manual Procedure 200 — Externai Corrosion Control — Monitoring\nrequires that all damaged test stations be repaired but it does not address the\nrequirement that the test lead be securely attached to the pipeline, electrically\nconductive, and that the test lead and bared metallic area at the point of connection be\ncoated. Raton addresses these in their evaluation \"E8 - Ability to Attach Wire to Pipe\nby Thermoweld Procedure\" of Raton's OQ program.\ntj192. 491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to\n@192. 465(a). and (e) and 192. 475(b) must be retained for as long as the pipeline\nremains in service.\n$192. 461 External corrosion control: Protective coating.\n(c) Each external protective coating must be inspected just prior to lowering the\npipe into the ditch and backfilling, and any damage detrimental to effective\ncorrosion control must be repaired.\nRaton's OEM forms do not address the inspection and repair of coating prior to\nbackfilling. Form 1010 — Report of Corrosion Leaks, Breaks, and Pits records the type\n\n\n\nof coating applied but not inspection and repairs of the coating and Form 6000 General\nPipeline Repair Record does not address coatings used in repairs.\ng. $192. 481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed\nto the atmosphere for evidence of atmospheric corrosion, as follows:\nIf the\npipeline is\nlocated:\nOnshore\nOffshore\nThen the frequency of\ninspection is:\nAt least once every 3 calendar\nyears, but with intervals not\nexceedin 39 months\nAt least once ach calendar year,\nbut with intervals not\nexceedin 15 months\n$192. 491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to\n@192. 465(a) and (e) and 192. 475(b) must be retained for as long as the pipeline\nremains in service.\nRaton's O&M Manual Procedure 200 — External Corrosion Control — Monitoring\nrequires that parts the exposed to the atmosphere be inspected at least once each\ncalendar year and that where areas of atmospheric corrosion are found Form 1060 will\nbe completed. Raton is performing the atmospheric corrosion inspection as part of their\npipeline patrol and documenting the results on Form 11000 — Pipeline Patrolling\nRecord. The performance of the atmospheric corrosion inspection as part of the\npipeline patrol, and its documentation on Form 11000 — Pipeline Patrolling Record is\nnot addressed in Procedure 30 — pipeline Patrolling.\nI't192. 615 Emergency plans.\n(b) Each operator shall:\n(2) Train the-appropriate operating personnel to assure that they are\nknowledgeable of the emergency procedures and verify that the training is\neffective.\nRaton's O&M Manual Procedurel80 — Emergency Plan requires that ail Raton\nemergency response personnel be trained regarding the provisions of the Emergency\nplan on an annual basis but it does not verifying that the training is effective.\n4. tt192. 615 Emergency plans.\n(b) Each operator shall:\n\n\n\n(3) Review employee activities to determine whether the procedures were\neffectively followed in each emergency.\nRaton's O&M Manual Procedure180 — Emergency Plan requires that after each\nemergency event a review of all facts and response activities will be conducted to\ndetermine the effectiveness of the response and establish areas of response that could be\nimproved. The procedure does not specifically address the review of employee actions\nto determine that the procedures were effectively followed during the emergency.\ntj192. 243 Nondestructive testing.\n(b) Nondestructive testing of welds must be performed:\n(1) In accordance with written procedures; and\n(2) By persons who have been trained and qualified in the established procedures\nand with the equipment employed in testing.\nRaton's O&M Manual Procedure110 — General Pipeline Repair requires that repaired\nareas be nondestructively tested and meet the same quality requirements for a new weld.\nNeither procedure 110, nor other Raton procedures, address the requirements that\nnondestructive testing must be performed in accordance with written procedures and by\npersons who have been trained and qualified in the established procedures and\nequipment used in the testing.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 190. 237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\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 subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\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 qualify for\nconfidential ueatment redacted and an explanation of why you believe the redacted information\nqualifies 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\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without fiuther notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C. F. R. $ 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. This 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 2-2008-1009M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nLinda Daugherty\nDirector, ~ Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n\n220081009M_closure letter_12142010_text.pdf\n\nDecember 14, 2010\nMr. David N. Link\nVice President\nRaton Gas Transmission\n223 N. Guadalupe #274\nSanta Fe, New Mexico 87501-1850\nCPF 2-2008-1009M\nDear Mr. Link:\nOn July 22-24 and August 5-6, 2008, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety inspected the Raton Gas\nTransmission (Raton) operator qualification (OQ), pipeline integrity management (IM), and\noperations and maintenance (O&M) procedures in Raton, New Mexico, pursuant to Chapter\n601 of 49 United States Code.\nAs a result of the inspection, PHMSA issued a Notice of Amendment (NOA) on December\n16, 2008, which required Raton to amend its pipeline integrity management procedures; and,\nits operations and maintenance procedures.\nThe PHMSA Southern Region reviewed your most recent written response to the NOA dated\nMay 7, 2010, and your November 21, 2010, electronic response to the NOA. We find that you\nhave met the requirements specified in the NOA. No further action is necessary with regards\nto the NOA and this case is now closed.\nPlease be advised that nothing herein states or implies that the above described procedures\nmeet the requirements of the federal pipeline safety regulations or that the procedures are\napproved. The pipeline system, its IM program, OQ program and O&M procedures remain\nsubject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, PHMSA Southern Region\nOffice of Pipeline Safety","truncated":false,"body_characters":19563}