{"operation":"document","citation":"CPF 320171003M","title":"ANR PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-03-16","effective_on":null,"summary":"CLOSED notice of amendment citing 192.911(d), 192.911(e), 192.929(b)(2), 192.933(d)(1)(ii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320171003M","body":"Notice of Amendment involving ANR PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.911(d),  192.911(e),  192.929(b)(2),  192.933(d)(1)(ii). The case was opened on 2017-03-16 and is reported as closed as of 2017-12-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320171003M_Closure Letter_12202017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171003M/320171003M_Closure%20Letter_12202017.pdf\n\n320171003M_Closure Letter_12202017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171003M/320171003M_Closure%20Letter_12202017_text.pdf\n\n320171003M_Notice of Amendment_03162017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171003M/320171003M_Notice%20of%20Amendment_03162017.pdf\n\n320171003M_Notice of Amendment_03162017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171003M/320171003M_Notice%20of%20Amendment_03162017_text.pdf\n\n320171003M_Closure Letter_12202017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 20, 2017\nMr. Stan Chapman\nSenior Vice President & General Manager\nUS Natural Gas Pipelines\nTransCanada Corporation\n700 Louisiana St. Suite 700\nHouston TX, 77002\nCPF 3-2017-1003M\nDear Mr. Chapman:\nBetween July 20, 2015 and December 4, 2015, representatives of the Michigan Public Service\nCommission (MI-PSC) acting as an interstate agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS) pursuant to Chapter 601 of\n49 United States Code inspected ANR Pipeline Company’s (ANR) procedures for integrity\nmanagement in Troy, Michigan. As a result of the inspection, ANR was issued a Notice of\nAmendment on March 16, 2017, which proposed amendment of your procedures.\nANR provided its amended procedures on June 12, 2017 and a revision on December 18,\n2017. My staff reviewed the amended procedures, and it appears that the inadequacies\noutlined in this Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary and this case is closed. Thank\nyou for your cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n\n320171003M_Notice of Amendment_03162017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 16, 2017\nMr. Stanley Chapman\nSenior Vice President and General Manager\nANR Pipeline Company / TransCanada\n700 Louisiana Street\nHouston, TX 77002\nCPF 3-2017-1003M\nDear Mr. Chapman:\nBetween July 20, 2015 and December 4, 2015, representatives of the Michigan Public Service\nCommission (MI-PSC) acting as an interstate agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS) pursuant to Chapter 601 of\n49 United States Code inspected ANR Pipeline Company’s procedures for integrity\nmanagement in Troy, Michigan.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nANR Pipeline Company’s plans or procedures, as described below:\n1. §192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see §\n192.907) and evolves into a more detailed and comprehensive integrity management\nprogram, as information is gained and incorporated into the program. An operator\nmust make continual improvements to its program. The initial program framework\nand subsequent program must, at minimum, contain the following elements. (When\nindicated, refer to ASME/ANSI B31.8S (incorporated by reference, see § 192.7) for\nmore detailed information on the listed element.)\n\n\n\n(d) A direct assessment plan, if applicable, meeting the requirements of § 192.923,\nand depending on the threat assessed, of § § 192.925, 192.927, or 192.929.\n§192.929 What are the requirements for using Direct Assessment for Stress\nCorrosion Cracking (SCCDA)?\n(b) General requirements. An operator using direct assessment as an integrity\nassessment method to address stress corrosion cracking in a covered pipeline\nsegment must have a plan that provides, at minimum, for--\n(2) Assessment method. The plan must provide that if conditions for SCC are\nidentified in a covered segment, an operator must assess the covered segment\nusing an integrity assessment method specified in ASME/ ANSI B31.8S, appendix\nA3, and remediate the threat in accordance with ASME/ANSI B31.8S, appendix\nA3, section A3.4.\nANR Pipeline Company’s (ANR) procedure for SCCDA was inadequate because it did not\ninclude a requirement for an instrumented leak survey upon return to service after\ncompleting a hydrostatic test. ASME B.318S Section A-3.4.2(c), incorporated by\nreference, requires an instrumented leak survey.\n2. §192.911 (See Above)\n(e) Provisions meeting the requirements of § 192.933 for remediating conditions found\nduring an integrity assessment.\n§192.933 What actions must be taken to address integrity issues?\n(d) Special requirements for scheduling remediation. -\n(1) Immediate repair conditions. An operator's evaluation and remediation\nschedule must follow ASME/ANSI B31.8S, section 7 in providing for immediate\nrepair conditions. To maintain safety, an operator must temporarily reduce\noperating pressure in accordance with paragraph (a) of this section or shut down\nthe pipeline until the operator completes the repair of these conditions. An\noperator must treat the following conditions as immediate repair conditions:\n(ii) A dent that has any indication of metal loss, cracking or a stress riser.\nANR’s procedure TEP-INT-ILI Table 6.2 was inadequate because it did not specify that\nany metal loss indication affecting long seams formed by direct or low-frequency ERW or\nby electric flash welding (flash weld) are to be considered immediate repair conditions.\nThe procedure shows that only metal loss indications greater than 20% deep in those type\nof pipe seams is to be considered an immediate repair condition. Therefore, ANR’s\nprocedure did not follow ASME B.318S section 7.2.1 that is incorporated by reference.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 90 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that ANR Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2017-1003M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n3","truncated":false,"body_characters":8613}