{"operation":"document","citation":"CPF 220131003M","title":"EAST TENNESSEE NATURAL GAS, LLC (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-03-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.917(a), 192.921(a)(4), 192.937(c)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220131003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220131003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220131003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220131003M","body":"Notice of Amendment involving EAST TENNESSEE NATURAL GAS, LLC (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulations as 192.917(a),  192.921(a)(4),  192.937(c)(4). The case was opened on 2013-03-20 and is reported as closed as of 2013-06-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220131003M_closure letter_06052013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131003M/220131003M_closure%20letter_06052013.pdf\n\n220131003M_closure letter_06052013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131003M/220131003M_closure%20letter_06052013_text.pdf\n\n220131003M_notice of amendment_03202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131003M/220131003M_notice%20of%20amendment_03202013.pdf\n\n220131003M_notice of amendment_03202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131003M/220131003M_notice%20of%20amendment_03202013_text.pdf\n\n220131003M_Operator Response_04182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131003M/220131003M_Operator%20Response_04182013.pdf\n\n220131003M_closure letter_06052013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 5, 2013\nMr. Theopolis Holeman\nGroup Vice President of U.S. Operations\nEast Tennessee Natural Gas Company\n5400 Westheimer Court\nHouston, TX 77056\nCPF 2-2013-1003M\nDear Mr. Holeman:\nFrom June 11, 2012, to June 21, 2012, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Southern Region, Office of Pipeline Safety,\npursuant to Chapter 601 of 49 United States Code, inspected the East Tennessee Natural Gas\nCompany’s (ETNG’s) written Integrity Management Program (IMP) procedures at your\nHouston headquarters office pursuant to Chapter 601 of 49 United States Code.\nThe PHMSA Southern Region received and reviewed the amended procedures ETNG\nsubmitted in correspondences dated April 18, 2013 and May 15, 2013, and we find them\nadequate. This letter is to inform you that ETNG has complied with the terms of the NOA\nand that no further actions are necessary with regards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2013-1003M) and not to any\nother PHMSA pending cases, if any. Also be advised that nothing herein states or implies\nthat the above described IMP procedures meet the requirements of the federal pipeline safety\nregulations or that the IMP procedures are approved. The pipeline system and IMP\nprocedures remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220131003M_notice of amendment_03202013_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 20, 2013\nMr. Theopolis Holeman\nGroup Vice President of U.S. Operations\nEast Tennessee Natural Gas Company\n5400 Westheimer Court\nHouston, TX 77056\nCPF 2-2013-1003M\nDear Mr. Holeman:\nFrom June 11, 2012, to June 21, 2012, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Southern Region, Office of Pipeline Safety,\npursuant to Chapter 601 of 49 United States Code, inspected the East Tennessee Natural Gas\nCompany’s (ETNG’s) written Integrity Management Program (IMP) procedures at your\nHouston headquarters office pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within ETNG’s\nwritten IMP procedures, as described below:\n1. § 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 threats\nto each covered pipeline segment. Potential threats that an operator must consider\ninclude, but are not limited to, the threats listed in ASME/ANSI B31.8S\n(incorporated by reference, see §192.7), section 2, which are grouped under the\nfollowing four categories:\nETNG’s written Integrity Management Program (IMP) did not require the adequate\nevaluation of manufacturing threats1 with regards to increases in historical operating\npressures for certain covered pipeline segments susceptible to increases in pressure.\nETNG’s Integrity Management Program Threat Response Guidance Documents\nManufacturing: Section Number 440, Appendix A, Figure 3-1 did not clearly require that\ncertain pipe having a potential manufacturing threat be prioritized as high risk and\n1 ETNG includes in this category pipe with a joint factor less than 1, low-frequency ERW pipe, flash-welded\npipe, pipe with a material related in-service failure, or other pipe in the opinion of ETNG’s subject matter expert.\n\n\n\n2. 3. 2 Stress Corrosion Cracking Direct Assessment (SCCDA) Procedure Number: 9-2040\n3 Stress Corrosion Cracking Direct Assessment (SCCDA) Procedure Number: 9-2040\nscheduled for an assessment in accordance with §192.917(e)(3)(i) if it experiences an\nincrease above the maximum operating pressure during the five years preceding the\nidentification of a high consequence area (HCA); i.e. the 5-year MOP. Figure 3-1 stated\nfor manufactured pipe made of certain materials susceptible to increases in internal\npressure that has not been hydrotested to at least 1.25 MAOP, “unless there are near term\nplans to operate at pressures above the historic operating pressure, the manufactured\npipe materials are deemed stable with respect to circumferential functional loadings, and\nno further integrity assessment required unless operating pressure increase.” That is, the\nprocedure did not clearly explain that any increase in pressure above the 5-year MOP,\nregardless of the amount of increase, would require that the applicable segment be\nprioritized as high risk for integrity assessment.\n§ 192.921 How is the baseline assessment to be conducted?\n(a) Assessment methods. An operator must assess the integrity of the line pipe in\neach covered segment by applying one or more of the following methods depending\non the threats to which the covered segment is susceptible. An operator must select\nthe method or methods best suited to address the threats identified to the covered\nsegment ( See §192.917).\n. . . (4) Other technology that an operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option\nmust notify the Office of Pipeline Safety (OPS) 180 days before conducting the\nassessment, in accordance with §192.949. . . .\nETNG considered the threat of near-neutral-pH stress corrosion cracking (SCC) to exist\non its pipeline system and had a written procedure2 in its IMP to complete Stress\nCorrosion Cracking Direct Assessments (SCCDA). However, ETNG did not have a\nwritten procedure that required it to notify the Office of Pipeline Safety (OPS) about its\nplanned use of SCCDA as a baseline assessment method. SCCDA is an “other\ntechnology” in the integrity management regulations that requires the operator to notify\nOPS 180 days before conducting a baseline assessment using this method.\n§ 192.937 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n. . . (c) Assessment methods. In conducting the integrity reassessment, an operator\nmust assess the integrity of the line pipe in the covered segment by any of the\nfollowing methods as appropriate for the threats to which the covered segment is\nsusceptible\n(see §192.917), or by confirmatory direct assessment under the conditions specified\nin §192.931.\n. . . (4) Other technology that an operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option\nmust notify the Office of Pipeline Safety (OPS) 180 days before conducting the\nassessment, in accordance with §192.949 . . . .\nETNG considered the threat of near-neutral-pH stress corrosion cracking (SCC) to exist\non its pipeline system and had a written procedure3 in its IMP to complete Stress\n2\n\n\n\nCorrosion Cracking Direct Assessments (SCCDA). However, ETNG did not have a\nwritten procedure that required it to notify the Office of Pipeline Safety (OPS) about its\nplanned use of SCCDA as a continual assessment method. SCCDA is an “other\ntechnology” in the integrity management regulations that requires the operator to notify\nOPS 180 days before conducting a continual assessment using this method.\nResponse 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 treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further 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\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 30 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that East Tennessee Natural Gas Company maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Wayne T.\nLemoi, Director, Southern Region, Pipeline and Hazardous Materials Safety Administration.\nIn correspondence concerning this matter, please refer to CPF 2-2013-1003M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":10783}