{"operation":"document","citation":"CPF 320091006W","title":"GREAT PLAINS NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-04-22","effective_on":null,"summary":"CLOSED warning letter citing 192.911(k), 192.911(l), 192.921(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320091006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320091006W","body":"Warning Letter involving GREAT PLAINS NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.911(k),  192.911(l),  192.921(a). The case was opened on 2009-04-22 and is reported as closed as of 2009-04-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320091006W_Warning Letter_04222009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091006W/320091006W_Warning%20Letter_04222009.pdf\n\n320091006W_Warning Letter_04222009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320091006W/320091006W_Warning%20Letter_04222009_text.pdf\n\n320091006W_Warning Letter_04222009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 22, 2009\nMr. Jay Skabo, Vice President, Operations\nMontana Dakota Utilities Company/\nGreat Plains Natural Gas Company\n400 North Fourth Street\nBismarck, ND 58501-4092\nCPF 3-2009-1006W\nDear Mr. Skabo:\nOn June 18-22, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) and Minnesota Office of Pipeline Safety pursuant to Chapter 601 of\n49 United States Code inspected the Great Plains Natural Gas (GPNG) integrity management\n(IM) plan and procedures in Fergus Falls, Minnesota.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n§192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see\n§192.907) and evolves into a more detailed and comprehensive integrity management\nprogram, as information is gained and incorporated into the program. An operator must\nmake continual improvements to its program. The initial program framework and\nsubsequent program must, at minimum, contain the following elements. (When\nindicated, refer to ASME/ANSI B31.8S (ibr, see §192.7) for more detailed information\non the listed element.)\n1. §192.911(b) A baseline assessment plan meeting the requirements of §192.919 and\n§192.921.\n\n\n\nItem 1A: §192.921(a) Assessment methods. An operator must assess the integrity\nof the line pipe in each covered segment by applying one or more of the following\nmethods depending on the threats to which the covered segment is susceptible. An\noperator must select the method or methods best suited to address the threats\nidentified to the covered segment (See §192.917).\nThe GPNG integrity management program (IMP) plan, Section 4, indicates baseline\nassessments will be completed on each identified high consequence area (HCA) no\nlater than October 31, 2006 and, in addition, lists what the baseline assessment plan\nmust include; but a baseline assessment plan was not prepared.\n2. §192.911(k) A management of change process as outlined in ASME/ANSI B31.8S,\nsection 11.\nItem 2A: ASME/ANSI B31.8S Section 11(d) Management of change ensures that\nthe integrity management process remains viable and effective as changes to the\nsystem occur and/or new, revised, or corrected data becomes available. Any\nchange to equipment or procedures has the potential to affect pipeline integrity.\nMost changes, however small, will have a consequent effect on another aspect of\nthe system. For example, many equipment changes will require a corresponding\ntechnical or procedural change. All changes shall be identified and reviewed\nbefore implementation. Management of change procedures provides a means of\nmaintaining order during periods of change in the system and helps to preserve\nconfidence in the integrity of the pipeline.\nGPNG’s plan concerning management of change requirements was not followed. A\nnew interconnect to serve an ethanol plant off of MN Highway 210, west of Fergus\nFalls, was not reviewed for potential IMP impacts prior to installation.\n3. §192.911(l) A quality assurance process as outlined in ASME/ANSI B31.8S,\nsection 12.\nItem 3A: ASME/ANSI B31.8S Section 12.2(b)(3) Results of the integrity\nmanagement program and the quality control program shall be reviewed at\npredetermined intervals, making recommendations for improvement.\nNo annual review or 3-year evaluation of the GPNG plan was conducted, as required\nby Section 13 of the GPNG plan. No documentation of the reviews was made\navailable to the PHMSA inspection team.\nUnder 49 United States Code, §60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\n2\n\n\n\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Be advised that failure to do so will result in GPNG being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2009-1006W.\nSincerely,\nIvan A. Huntoon\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5191}