{"operation":"document","citation":"CPF 32021002WL","title":"NORTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-01-15","effective_on":null,"summary":"CLOSED warning letter citing 192.605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021002wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021002wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021002wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021002WL","body":"Warning Letter involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(1). The case was opened on 2021-01-15 and is reported as closed as of 2021-01-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021002WL_Warning Letter_01152021_(20-192781).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021002WL/32021002WL_Warning%20Letter_01152021_(20-192781).pdf\n\n32021002WL_Warning Letter_01152021_(20-192781)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021002WL/32021002WL_Warning%20Letter_01152021_(20-192781)_text.pdf\n\n32021002WL_Warning Letter_01152021_(20-192781)_text.pdf\n\nWARNING LETTER\nmark.hewett@nngco.com , Royce.ramsay@nngco.com , and\nVIA ELECTRONIC MAIL TO: Jonathan.wolfgram@state.mn.us\nJanuary 15, 2021\nMr. Mark Hewett\nPresident & CEO\nNorthern Natural Gas Co\n1111 South 103rd Street\nOmaha, NE 68124\nCPF 3-2021-002-WL\nDear Mr. Hewett:\nOn September 30, 2020, a representative of the Minnesota Office of Pipeline Safety (MNOPS)\nacting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted an investigation\nof an overpressure event at the Hayward, MN town border station. The investigation was\ninitiated after the event was reported as a safety related condition.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1. § 192.605 - Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\nNorthern Natural Gas Company (NNG) did not have adequate procedures to maintain the\noperating pressure under the maximum allowable operating pressure (MAOP) during the\noff-loading of natural gas from a bottle tanker to a town border station. As a result, the\ninlet piping to the Hayward MN town border station exceeded the MAOP.\n\n\n\n2\nOn August 25, 2020, NNG was engaged in a replacement project on the mainline\nupstream of the Hayward town border station tap. In order to facilitate the replacement\nand not shut natural gas off to the town, NNG brought in natural gas bottle tankers to\ntemporarily maintain the distribution system for the city. While delivering the natural\ngas from the tankers to the town border station, NNG personnel allowed the pressure to\ngo above the 500 psig MAOP to 667 psig. NNG’s gas control received alarms and\nnotified personnel on site who subsequently reduced the pressure to under the MAOP\nwhich took approximately one hour. No other parts of the station or the downstream\ndistribution system was affected. After identifying the non-compliance, NNG took\ndocumented actions to address the cause and corrected the non-compliances that\ncontributed to the issue including adding additional procedures for off-loading bottle\ntankers and requalifying personnel for this task.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a\nrelated series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring\nprior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per\nday, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item(s) identified in this letter. Failure to do so will result in\nNorthern Natural Gas Company being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2021-002-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nCc: Royce Ramsay, Vice President, Operations, Royce.ramsay@nngco.com\nJonathan Wolfgram, Chief Engineer, MNOPS, Jonathan.wolfgram@state.mn.us","truncated":false,"body_characters":5473}