{"operation":"document","citation":"CPF 220141004M","title":"CAROLINA GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-09-11","effective_on":null,"summary":"CLOSED notice of amendment citing 192.616(a), 192.805(c), 192.805(g).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220141004M","body":"Notice of Amendment involving CAROLINA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.616(a),  192.805(c),  192.805(g). The case was opened on 2014-09-11 and is reported as closed as of 2014-10-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220141004M_closure Letter_10072014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141004M/220141004M_closure%20Letter_10072014.pdf\n\n220141004M_closure Letter_10072014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141004M/220141004M_closure%20Letter_10072014_text.pdf\n\n220141004M_notice of amendment_09112014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141004M/220141004M_notice%20of%20amendment_09112014.pdf\n\n220141004M_notice of amendment_09112014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141004M/220141004M_notice%20of%20amendment_09112014_text.pdf\n\n220141004M_Operator Response_10012014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141004M/220141004M_Operator%20Response_10012014.pdf\n\n220141004M_notice of amendment_09112014_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 11, 2014\nMr. Samuel Dozier\nVice President, Operations\nCarolina Gas Transmission\n220 Operations Way\nCayce, SC 29033\nCPF 2-2014-1004M\nDear Mr. Dozier:\nOn July 30-31, 2014, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nCarolina Gas Transmission (CGT) Pipeline Public Awareness Plan and Operator\nQualification Plan at CGT’s office in Cayce, South Carolina, pursuant to Chapter 601 of\n49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within the CGT\nwritten Pipeline Public Awareness Plan and Operator Qualification Plan as described below:\n1. §192.616 Public awareness.\n(a) Except for an operator of a master meter or petroleum gas system covered under\nparagraph (j) of this section, each pipeline operator must develop and implement a\nwritten continuing public education program that follows the guidance provided in\nthe American Petroleum Institute’s (API) Recommended Practice (RP) 1162\n(incorporated by reference, see § 192.7).\nCGT’s written Pipeline Public Awareness Plan (PPAP) did not provide procedures for\nconducting an annual audit or review to determine whether the program had been\ndeveloped and implemented in accordance with API RP 1162.\nAPI RP 1162, Section 8.3 Measuring Program Implementation, requires an operator to\ncomplete an annual audit or review of whether the program has been developed and\nimplemented according to the API RP 1162 guidelines. While CGT’s PPAP stated the\nSCANA Public Awareness Committee will: “Ensure annual reviews of program\nimplementation are conducted using third party audits and/or, internal self-assessments\nand/or regulatory inspections,” it did not provide procedures on how the annual reviews\nwere to be conducted.\n\n\n\n2. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n... (b) Allow individuals that are not qualified pursuant to this subpart to perform a\ncovered task if directed and observed by an individual that is qualified;\nCGT’s Operator Qualification (OQ) Plan did not include a span of control number for all\ncovered tasks.\nCGT’s OQ Plan, Appendix 1-Covered Task List Matrix, identified how many non-\nqualified individuals could perform a given covered task under the direction and\nobservation of an individual qualified to perform the task. The Appendix listed a span of\ncontrol number for each of CGT’s identified covered tasks except the covered task for\nPipeline Pigging (i.e. 107PIG). Instead, the span of control number for covered task\n107PIG was listed as a question mark (?).\n3. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n... (g) Identify those covered tasks and the intervals at which evaluation of the\nindividual’s qualifications is needed;\nCGT’s Operator Qualification (OQ) Plan did not include a re-evaluation interval for all\ncovered tasks.\nCGT’s OQ Plan, Appendix 1-Covered Task List Matrix, identified the intervals at which\nthe evaluation of an individual’s qualifications is needed for covered task for each of\nCGT’s identified covered tasks except the covered task for Pipeline Pigging (i.e. 107PIG).\nInstead, the evaluation interval for covered task 107PIG was listed as a question mark (?).\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 inadequacy\n2\n\n\n\nidentified herein has been addressed in your amended procedures, this enforcement action will\nbe closed.\nIt is requested (not mandated) that Carolina Gas Transmission maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/\nrevision of plans, procedures) and submit the total to Wayne T. Lemoi, Director, Southern\nRegion, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 2-2014-1004M and, for each document you\nsubmit, 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\n\n220141004M_closure Letter_10072014_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 7, 2014\nMr. Paul Fant\nPresident and Chief Operating Officer\nCarolina Gas Transmission\n220 Operations Way\nCayce, SC 29033\nCPF 2-2014-1004M\nDear Mr. Fant:\nOn July 30-31, 2014, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nCarolina Gas Transmission (CGT) Pipeline Public Awareness Program and Operator\nQualification Plan at CGT’s office in Cayce, South Carolina, pursuant to Chapter 601 of\n49 United States Code. As a result of the inspection, the OPS Southern Region issued a\nNotice of Amendment (NOA) to CGT on September 11, 2014.\nSubsequent to the NOA, CGT amended its Public Awareness Program and Operator\nQualification Plan and provided the OPS Southern Region with documentation of those\namendments in a letter dated October 1, 2014. Based on our review of the actions taken by\nCGT to amend its procedures and the supporting documentation, we have determined that\nCGT has complied with the terms of the NOA and that no further action is necessary with\nregards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the above referenced order\n(CPF 2-2014-1004M) and not to any other PHMSA cases, if any.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":8429}