{"operation":"document","citation":"CPF 320211001M","title":"NORTHERN NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-02-10","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.631(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320211001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320211001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320211001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320211001M","body":"Notice of Amendment involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.631(e)(5). The case was opened on 2021-02-10 and is reported as closed as of 2021-02-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320211001M_Closure Letter_02252021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211001M/320211001M_Closure%20Letter_02252021.pdf\n\n320211001M_Closure Letter_02252021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211001M/320211001M_Closure%20Letter_02252021_text.pdf\n\n320211001M_Notice of Amendment_02102021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211001M/320211001M_Notice%20of%20Amendment_02102021.pdf\n\n320211001M_Notice of Amendment_02102021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211001M/320211001M_Notice%20of%20Amendment_02102021_text.pdf\n\n320211001M_Operator Response to Notice_02242021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211001M/320211001M_Operator%20Response%20to%20Notice_02242021.pdf\n\n320211001M_Notice of Amendment_02102021_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: royce.ramsay@nngco.com\nmark.hewitt@nngco.com and\nFebruary 10, 2021\nMr. Mark Hewitt\nPresident & CEO\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, NE 68124\n3-2021-1001M\nDear Mr. Hewitt:\nBetween May 13 and August 22, 2019, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) and state agents from\nMichigan, Iowa and Minnesota pursuant to Chapter 601 of 49 United States\nCode inspected Northern Natural Gas Company (Northern Natural) procedures\nfor Operations, Maintenance, Control Room, Integrity Management, and\nPublic Awareness in Omaha, Nebraska, as well as its gas pipeline system\nfacilities located in Iowa, Minnesota, Wisconsin and Michigan.\nOn the basis of the inspection, PHMSA has identified the apparent\ninadequacies found within Northern Natural’s plans or procedures, as\ndescribed below:\n1. § 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the\n\n\n\n2\nfollowing, if applicable, to provide safety during maintenance and\noperations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and\nsubpart M of this part.\nNorthern Natural’s procedure 80.407 Gas Leak Detection Survey (Rev.26:\n12/31/2015) (Procedure) fails to address the gas leak detection survey\nfrequency for non-odorized gas lines for a feature relating to leak surveys over\nwater. Leakage surveys locations are governed by § 192.706, which is\nincluded within subpart M of part 192. The regulation requires that operators\nof non-odorized gas transmission lines located in a Class 3 location perform\nleakage surveys at intervals not exceeding 7 ½ months, but at least twice each\ncalendar year. Pursuant to § 192.706(b)(1), operators must have adequate\nprocedure(s) to assure the safe operation of pipelines through compliance with\nthe applicable requirements of subpart M of part 192. Northern Natural fails to\nhave such a procedure.\nDuring the field inspection, the inspector from the State of Michigan observed\nthat an un-odorized Class 3 pipeline in the Houghton and Hancock area crosses\nthe Portage Canal. It was communicated to the inspector that the instrumented\nleak survey stopped at the edge of the water. Section 192.706 requires the\nsurvey to be conducted over the entire pipeline, and the associated\nprocedure(s) must cover all conditions. Northern Natural’s procedure 80.407\n“Gas Leak Detection Survey” does not describe requirements or provide\nguidance related to how a leak detection survey over bodies of water is to be\nperformed. Section 5.2.1 of the Procedure refers the operator to the Gas Leak\nDetection Frequency Table listed at the end of the Procedure. While there is\nfrequency guidance for special permit un-odorized lines, un-odorized lines not\ncovered by special permits are not addressed.\n2. § 192.631 Control Room Management\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must\nhave a written alarm management plan to provide for effective\ncontroller response to alarms. An operator’s plan must include\nprovisions to:\n(1) . . . .\n(5) Monitor the content and volume of general activity being\ndirected to and required of each controller at least once each\ncalendar year, but at intervals not to exceed 15 months, that will\nassure controllers have sufficient time to analyze and react to\nincoming alarms;\n\n\n\n3\nNorthern Natural’s Control Room Procedure 050.400b, Alarm Management\nAnnual Review of General Activity, does not contain adequate provisions to\nmonitor the content and general activity being directed to and required of each\ncontroller. Operators are required to develop procedures necessary to ensure\nthat controllers are able to identify alarm “floods”, which can involve many\nalarms occurring simultaneously or in a short period of time. In order to assure\nthat controllers are not overwhelmed in their ability to recognize problems and\nevents that may underlie the alarms, and thus delay prompt response, operators\nmust prepare procedures that identify and define the content and general\nactivity. Having such procedures assures that the ability of a controller to\nrespond appropriately to a safety-related event is not compromised. A\nprocedure required under this regulation requires a process that includes, for\nexample, reviewing phone calls, alarms responded to, commands sent, email\nactivity, field response, nomination review and set ups, planning, training, shift\nchange, monitoring weather and news reports, and planning actives. Further,\nthe process set forth in the procedure must be able to support the findings and\nany conclusions about maintaining or changing assigned duties.\nNorthern Natural’s Control Room Procedure 050.400b is inadequate to assure\nthe safe operation of its pipelines. Specifically, the procedure does not review\nall required activities of a controller and develop a criterion that will assure\ncontrollers have sufficient time to analyze and react to incoming alarms.\nNorthern Natural must modify its procedure 050.400b, Alarm Management\nAnnual Review of General Activity, to expand the activities reviewed and\nperform analysis to substantiate the conclusions about the activities directed to\nthe controller, during normal and peak hours of activity, that will assure\ncontrollers have sufficient time to analyze and react to incoming alarms.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. §\n190.206. Enclosed as part of this Notice is a document entitled Response\nOptions for Pipeline Operators in Enforcement Proceedings. Please refer to\nthis document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly\navailable. 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\noriginal document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\n\n\n\n4\nFollowing the receipt of this Notice, you have 30 days to submit written\ncomments, revised procedures, or a request for a hearing under §190.211. If\nyou do not respond within 30 days of receipt of this Notice, this constitutes a\nwaiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this\nNotice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct\nthe inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice,\nwe propose that you submit your amended procedures to my office within 30\ndays of receipt of this Notice. This period may be extended by written request\nfor good cause. Once the inadequacies identified herein have been addressed\nin your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that northern Natural Gas Transmission maintain\ndocumentation of the safety improvement costs associated with fulfilling this\nNotice of Amendment (preparation/revision of plans, procedures) and submit\nthe total to Gregory A. Ochs, Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 3-2021-1001M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nGregory A. Ochs, Director\nCentral Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement\nProceedings\ncc: Royce Ramsay, VP Operations, royce.ramsay@nngco.com\n\n320211001M_Closure Letter_02252021_text.pdf\n\nVIA ELECTRONIC MAIL TO: royce.ramsay@nngco.com\nmark.hewett@nngco.com and\nFebruary 25, 2021\nMr. Mark Hewett\nPresident & CEO\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, NE 68124\nRe: CPF 3-2021-1001M\nDear Mr. Hewett:\nBetween May 13 and August 22, 2019, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Northern Natural Gas Company’s (NNGC)\nprocedures in Omaha, NE. As a result of the inspection, Northern Natural Gas Comany was\nissued a Notice of Amendment on February 10, 2021, which proposed amendment of your\nprocedures.\nNorthern Natural Gas Company submitted its amended procedures on February 24, 2021. My\nstaff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Royce Ramsay, VP Operations, royce.ramsay@nngco.com","truncated":false,"body_characters":10497}