NORTHERN NATURAL GAS CO — Warning Letter

party submissionOfficial PDF320071009W_operator response to warning letter_04062007.pdf#

320071009W_warning Letter_02262007.pdf, page 1Official PDFf .':r : I ff07 A \7 U.S. Deportment of Tronsoorlotion Pipellne qnct Hozordous lrloleriolt Soloty Adminlst?qfion 901 Locust Street, Suite 462 Kansas City, MO 64106-2641 WARNING LETTER February 26,2007 Mr. Royce Ramsay Vice Presiden! Operations Norlhern Natural Gas Co., Inc. IIllS. 103rdStreet Omaha, NE 68124 cPF 3-2007-1009w Dear Mr- Ramsay: On August 15-17,2006, a rcpresentative of the Michigan Public Service Commission acting as an Interstate Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Codc inspected your facilities and records in Negaunee, Michigan. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulafions, Title 49, Code of Federal Regulations. The items inspected and the probablc violation(s) are: l. $192.491 Corrosion control records. (c) Each opcrator shall maintain a record ofeach tes! s'rvey, or inspection required by this subpart in suflicient detail to demonstrate thc adequacy of corrosion control mcasures or that a corrosivc condition does not exist. These records must be retaincd for at lease 5 years, except that records related to $$ 192-465(a) and (e) and r92.475(b) must be retained for as long as the pipetine remains in service.#

320071009W_warning Letter_02262007.pdf, page 2During the M-35 replacement project, the inside of the pipeline was observed for internal corrosion, but an inspcction report was not completed. Your personnel indicated that the inspection was done but not documented. 2. $192.225 Welding procedures. (a) Welding nrust be performed by a qualified rvelder in accordance with welding procedures qualificd under section 5 ofAPI ll04 (ibr, see $192.7) or section IX of the ASIIIE Boiler and Pressure Vessel Code (' Welding and Brazing Qualificationst, (ibr, see $192.7) to produce welds meeting the requirements of this subpart. The quality of the test rvelds used to qualify wclding procedures shall tre determined by destructive testing in accordance with the appricabre rvelding standard(s). According to the API 1 104 Welder Qualification Test Report, one of the welders that worked on the M-35 replacement project was not qualified correctly to ApI 1104 standards. The correct number of destructive tests wero not perform€d: onlv two root- bend tests were used for branch-on-pipe multiple welding qualification. ThL welder was listed as qualified for branch-on-pipe werding even though ApI 1 104 scction 6.3.1 requir-es four Nick-Break tests for multiple weldine qualification. Under 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $ t 00,000 . for each violation for each day the violaiions persists up to a *u*irn,r* of $ 1,000,000 for any related series of l'iolations. Wc have reviewed the circumstances ancl supporting documents involved in this case, and have decided not to conduct additional enforcernent action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Bc advised that failure to do so will result in Northem Natural Gas co. being subject to additional enforcemcnt action.#

320071009W_warning Letter_02262007.pdf, page 3No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 3-2007-1009W. Be advised that all material you submit in response to this enforcement actionissubjecttobeingmadepubliclyavailable. Ifyoubelievethatanyportionofyour responsive material qualifies for confidential treatment under 5 U.S.C. 5520); along with the complete original docunent you must provide a second copy of the document with the poftions you believe qualif,, for confidential treatment redactcd and an explanation ofwhy you believe the redacted information qualifies for confidential keatment under 5 U.S.C. 552(b). Sincerely, Director, Central Region Pipelinc and Hazardous Materials Safety Administration#