{"operation":"document","citation":"CPF 320071009W","title":"NORTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-02-26","effective_on":null,"summary":"CLOSED warning letter citing 192.225(a), 192.491(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320071009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320071009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320071009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320071009W","body":"Warning Letter involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.225(a),  192.491(c). The case was opened on 2007-02-26 and is reported as closed as of 2007-02-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320071009W_operator response to warning letter_04062007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320071009W/320071009W_operator%20response%20to%20warning%20letter_04062007.pdf\n\n320071009W_warning Letter_02262007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320071009W/320071009W_warning%20Letter_02262007.pdf\n\n320071009W_warning Letter_02262007.pdf\n\nf .':r : I ff07\nA\n\\7\nU.S. Deportment\nof Tronsoorlotion\nPipellne qnct\nHozordous lrloleriolt Soloty\nAdminlst?qfion\n901 Locust Street, Suite 462\nKansas City, MO 64106-2641\nWARNING LETTER\nFebruary 26,2007\nMr. Royce Ramsay\nVice Presiden! Operations\nNorlhern Natural Gas Co., Inc.\nIIllS. 103rdStreet\nOmaha, NE 68124\ncPF 3-2007-1009w\nDear Mr- Ramsay:\nOn August 15-17,2006, a rcpresentative of the Michigan Public Service Commission acting\nas an Interstate Agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Codc inspected your facilities and\nrecords in Negaunee, Michigan.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulafions, Title 49, Code of Federal Regulations. The items inspected and\nthe probablc violation(s) are:\nl. $192.491 Corrosion control records.\n(c) Each opcrator shall maintain a record ofeach tes! s'rvey, or inspection\nrequired by this subpart in suflicient detail to demonstrate thc adequacy of\ncorrosion control mcasures or that a corrosivc condition does not exist. These\nrecords must be retaincd for at lease 5 years, except that records related to $$\n192-465(a) and (e) and r92.475(b) must be retained for as long as the pipetine remains in\nservice.\n\n\n\nDuring the M-35 replacement project, the inside of the pipeline was observed for internal\ncorrosion, but an inspcction report was not completed. Your personnel indicated that the\ninspection was done but not documented.\n2. $192.225 Welding procedures.\n(a) Welding nrust be performed by a qualified rvelder in accordance with welding\nprocedures qualificd under section 5 ofAPI ll04 (ibr, see $192.7) or section IX of\nthe ASIIIE Boiler and Pressure Vessel Code (' Welding and Brazing Qualificationst,\n(ibr, see $192.7) to produce welds meeting the requirements of this subpart. The\nquality of the test rvelds used to qualify wclding procedures shall tre determined by\ndestructive testing in accordance with the appricabre rvelding standard(s).\nAccording to the API 1 104 Welder Qualification Test Report, one of the welders that\nworked on the M-35 replacement project was not qualified correctly to ApI 1104\nstandards. The correct number of destructive tests wero not perform€d: onlv two root-\nbend tests were used for branch-on-pipe multiple welding qualification. ThL welder was\nlisted as qualified for branch-on-pipe werding even though ApI 1 104 scction 6.3.1\nrequir-es four Nick-Break tests for multiple weldine qualification.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $ t 00,000 .\nfor each violation for each day the violaiions persists up to a *u*irn,r* of $ 1,000,000 for any\nrelated series of l'iolations. Wc have reviewed the circumstances ancl supporting documents\ninvolved in this case, and have decided not to conduct additional enforcernent action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nBc advised that failure to do so will result in Northem Natural Gas co. being subject to\nadditional enforcemcnt action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2007-1009W. Be advised that all material you submit in response to this enforcement\nactionissubjecttobeingmadepubliclyavailable. Ifyoubelievethatanyportionofyour\nresponsive material qualifies for confidential treatment under 5 U.S.C. 5520); along with the\ncomplete original docunent you must provide a second copy of the document with the poftions\nyou believe qualif,, for confidential treatment redactcd and an explanation ofwhy you believe\nthe redacted information qualifies for confidential keatment under 5 U.S.C. 552(b).\nSincerely,\nDirector, Central Region\nPipelinc and Hazardous Materials Safety Administration","truncated":false,"body_characters":4569}