{"operation":"document","citation":"CPF 320171001W","title":"VIKING GAS TRANSMISSION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-01-04","effective_on":null,"summary":"CLOSED warning letter citing 192.917(a), 192.917(b), 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320171001W","body":"Warning Letter involving VIKING GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192.917(a),  192.917(b),  192.947(d). The case was opened on 2017-01-04 and is reported as closed as of 2017-01-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320171001W_Warning Letter_01042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171001W/320171001W_Warning%20Letter_01042017.pdf\n\n320171001W_Warning Letter_01042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171001W/320171001W_Warning%20Letter_01042017_text.pdf\n\n320171001W_Warning Letter_01042017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 4, 2017\nMr. Michel Nelson\nSr. VP Operations of Natural Gas Pipelines\nViking Gas Transmission Company\n100 West Fifth Street\nTulsa, OK 74103\nCPF 3-2017-1001W\nDear Mr. Nelson:\nBeginning March 9, 2015 and ending June 12, 2015, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Viking Gas Transmission Company (Viking) procedures, facilities and records in North\nDakota and Wisconsin.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation(s) are:\n1. §192.947 What records must an operator keep?\nAn operator must maintain, for the useful life of the pipeline, records that demonstrate\ncompliance with the requirements of this subpart. At minimum, an operator must maintain\nthe following records for review during an inspection.\n\n\n\n(d) Documents to support any decision, analysis and process developed and used to\nimplement and evaluate each element of the baseline assessment plan and integrity\nmanagement program. Documents include those developed and used in support of any\nidentification, calculation, amendment, modification, justification, deviation and\ndetermination made, and any action taken to implement and evaluate any of the\nprogram elements;\n§192.917 How does an operator identify potential threats to pipeline integrity and use the\nthreat identification in its integrity program?\n(b) Data gathering and integration. To identify and evaluate the potential threats to a\ncovered pipeline segment, an operator must gather and integrate existing data and\ninformation on the entire pipeline that could be relevant to the covered segment. In\nperforming this data gathering and integration, an operator must follow the\nrequirements in ASME/ANSI B31.8S, section 4. At a minimum, an operator must gather\nand evaluate the set of data specified in Appendix A to ASME/ANSI B31.8S, and\nconsider both on the covered segment and similar non-covered segments, past incident\nhistory, corrosion control records, continuing surveillance records, patrolling records,\nmaintenance history, internal inspection records and all other conditions specific to each\npipeline.\nViking did not document its integration of data for assessment review to identify potential threats\nto pipeline integrity. Viking integrated ILI or ECDA results with data on encroachments and\nforeign line crossings in the same segment to define locations of potential third party damage\nmanually, but results of integration were not documented for assessment review.\n2. §192.917 How does an operator identify potential threats to pipeline integrity and use the\nthreat identification in its integrity program?\n(a) Threat identification. An operator must identify and evaluate all potential threats to\neach covered pipeline segment. Potential threats that an operator must consider include,\nbut are not limited to, the threats listed in ASME/ANSI B31.8S (incorporated by\nreference, see §192.7), section 2, which are grouped under the following four categories:\n(1) Time dependent threats such as internal corrosion, external corrosion, and stress\ncorrosion cracking;\n(2) Static or resident threats, such as fabrication or construction defects;\n(3) Time independent threats such as third party damage and outside force damage; and\n(4) Human error.\nViking did not evaluate all potential threats to each covered pipeline segment according to\nASME/ANSI B31.8S, Section 2. Viking’s integrity management program failed to list all of the\nthreats associated with the categories. As a result, a relief valve leak in 2013 was not incorporated\ninto the risk model.\n2\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638 per\nviolation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for\na related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty\nmay not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for\na related series of violations. We have reviewed the circumstances and supporting documents involved\nin this case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the items identified in this letter. Failure to do so\nwill result in Viking being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n3-2017-1001W. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for 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 confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6247}