{"operation":"document","citation":"CPF 32024010NOA","title":"NORTHERN NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-02-06","effective_on":null,"summary":"CLOSED notice of amendment citing 192.607(d)(1), 192.607(f), 192.624(c)(1)(ii), 192.624(c)(1)(iii), 192.710(d), 192.917(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024010noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024010noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024010noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024010NOA","body":"Notice of Amendment involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.607(d)(1),  192.607(f),  192.624(c)(1)(ii),  192.624(c)(1)(iii),  192.710(d),  192.917(c). The case was opened on 2024-02-06 and is reported as closed as of 2024-05-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024010NOA_Closure Letter_05242024_(23-264235).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024010NOA/32024010NOA_Closure%20Letter_05242024_(23-264235).pdf\n\n32024010NOA_Closure Letter_05242024_(23-264235)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024010NOA/32024010NOA_Closure%20Letter_05242024_(23-264235)_text.pdf\n\n32024010NOA_Notice of Amendment_02062024_(23-264235).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024010NOA/32024010NOA_Notice%20of%20Amendment_02062024_(23-264235).pdf\n\n32024010NOA_Notice of Amendment_02062024_(23-264235)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024010NOA/32024010NOA_Notice%20of%20Amendment_02062024_(23-264235)_text.pdf\n\n32024010NOA_Operator Response to Notice_02292024_(23-264235).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024010NOA/32024010NOA_Operator%20Response%20to%20Notice_02292024_(23-264235).pdf\n\n32024010NOA_Closure Letter_05242024_(23-264235)_text.pdf\n\nVIA ELECTRONIC MAIL TO: mark.hewett@nngco.com, thomas.correll@nngco.com;\ndavid.geck@nngco.com;\nMay 24, 2024\nMr. Mark Hewett\nPresident/CEO\nNorthern Natural Gas Company\n1111 S. 103rd Street\nOmaha, NE 68124\nRE: CPF No. 3-2024-010-NOA\nDear Mr. Hewett:\nFrom April 10 through May 4, 2023, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), along with representatives from the Michigan Public Service\nCommission, Minnesota Office of Pipeline Safety, and the Iowa Utility Board acting as Interstate\nAgents pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Northern Natural\nGas Company’s (NNG) procedures for the new gas integrity rule in Omaha, Nebraska. As a\nresult of the inspection, Northern Natural Gas Company was issued a Notice of Amendment on\nFebruary 6, 2024, which proposed amendment of its procedures. Northern Natural Gas Company\nsubmitted its amended procedures on May 2, 2024, which my staff has reviewed and it appears\nthat the inadequacies outlined in the Notice 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: Thomas Correll (thomas.correll@nngco.com)\nDavid Geck (david.geck@nngco.com)\nLaura Demman (laura.demman@nngco.com)\nBrian Mundt (brian.mundt@nngo.com)\n\n32024010NOA_Notice of Amendment_02062024_(23-264235)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: mark.hewett@nngco.com; thomas.correll@nngco.com;\ndavid.geck@nngco.com; john.gormley@nngco.com; Laura.Demman@nngco.com;\nBrian.Mundt@nngco.com\nFebruary 6, 2024\nMr. Mark Hewett\nPresident & CEO\nNorthern Natural Gas Company\n1111 S. 103rd Street\nOmaha, NE 68124\nCPF 3-2024-010-NOA\nDear Mr. Hewett:\nFrom April 10 through May 4, 2023, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), along with representatives from the Michigan Public Service\nCommission, Minnesota Office of Pipeline Safety, and the Iowa Utility Board acting as Interstate\nAgents, pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Northern Natural\nGas Company’s (NNG) procedures for the new gas integrity rule1 in Omaha, Nebraska.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nNNG’s plans or procedures. The items inspected and the inadequacies are described below:\n1 Docket No. PHMSA–2011–0023; Amdt. Nos. 191–26; 192–125 Pipeline Safety: Safety of Gas Transmission\nPipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments\n\n\n\n1. 2. 3. § 192.607 Verification of Pipeline Material Properties and Attributes: Onshore steel\ntransmission pipelines.\n(a) . . . .\n(d) Special requirements for nondestructive Methods. Procedures developed in\naccordance with paragraph (c) of this section for verification of material properties\nand attributes using nondestructive methods must:\n(1) Use methods, tools, procedures, and techniques that have been validated by a\nsubject matter expert based on comparison with destructive test results on material\nof comparable grade and vintage.\nNNG’s procedures did not provide adequate guidance for nondestructive testing in\naccordance with the requirements of § 192.607(d)(1). Specifically, NNG’s procedure\n80.803 section 3.7 simply repeated the code requirements; it did not include any\nspecificity or guidance with respect to the types of in-situ tools that would be used and\nthe proper calibration of such tools.\n§ 192.607 Verification of Pipeline Material Properties and Attributes: Onshore steel\ntransmission pipelines.\n(a) . . . .\n(f) Components. For mainline pipeline components other than line pipe, an operator\nmust develop and implement procedures in accordance with paragraph (c) of this\nsection for establishing and documenting the ANSI rating or pressure rating (in\naccordance with ASME/ANSI B16.5 (incorporated by reference, see\n§ 192.7)) . . . .\nNNG’s procedure 80.803 section 5.3 did not adequately provide guidance for traceable,\nverifiable, and complete (TVC) records of components required under § 192.607(f).\nWhile the procedure restated the requirements of the regulation, the procedure did not\nspecify details such as whether personnel can get TVC information strictly from records,\nor whether personnel have to visually inspect the component itself to get the information.\nAdditionally, for above-ground facilities, such as meter stations and compressor stations,\nNNG’s procedures did not define what would be considered a “mainline pipeline\ncomponent other than line pipe” for the purpose of compliance with § 192.607(f).\nNNG must amend its written procedures to comply with the requirements of §\n192.607(f).\n§ 192.624 Maximum allowable operating pressure reconfirmation: Onshore steel\ntransmission pipelines.\n(a) . . . .\n(c) Maximum allowable operating pressure determination. Operators of a pipeline\nsegment meeting a condition in paragraph (a) of this section must reconfirm its\nMAOP using one of the following methods:\n(1) Method 1: Pressure test. Perform a pressure test and verify material\n\n\n\n4. properties records in accordance with § 192.607 and the following requirements:\n(i) . . . .\n(ii) Material properties records. Determine if the following material properties\nrecords are documented in traceable, verifiable, and complete records: Diameter,\nwall thickness, seam type, and grade (minimum yield strength, ultimate tensile\nstrength).\nNNG’s procedure 80.801 section 5.3 did not adequately include all of the required\nattributes for obtaining TVC information as it pertains to Method 1 under MAOP\nreconfirmation as required by § 192.624(c)(1)(ii). Specifically, procedure 80.801 section\n5.3.1 indicated that the attributes to be TVC’d include diameter, wall thickness, seam\ntype, and grade (yield strength). The procedure must also include getting the TVC\nrecords for ultimate tensile strength.\nNNG must amend its written procedures to comply with the requirements of §\n192.624(c)(1)(ii) in accordance with § 192.605(a).\n§ 192.624 Maximum allowable operating pressure reconfirmation: Onshore steel\ntransmission pipelines.\n(a) . . . .\n(c) Maximum allowable operating pressure determination. Operators of a pipeline\nsegment meeting a condition in paragraph (a) of this section must reconfirm its\nMAOP using one of the following methods:\n(1) Method 1: Pressure test. Perform a pressure test and verify material\nproperties records in accordance with § 192.607 and the following requirements:\n(i) . . . . .\n(iii) Material properties verification. If any of the records required by\nparagraph (c)(1)(ii) of this section are not documented in traceable, verifiable, and\ncomplete records, the operator must obtain the missing records in accordance with\n§ 192.607. An operator must test the pipe materials cut out from the test manifold\nsites at the time the pressure test is conducted. If there is a failure during the\npressure test, the operator must test any removed pipe from the pressure test failure\nin accordance with § 192.607.\nNNG’s procedure 80.801 section 5.3 did not adequately require obtaining TVC\ninformation on a pressure test header for reconfirmation per § 192.624(c)(1)(iii).\nSpecifically, procedure 80.801 section 5.3.1 indicated that NNG personnel must test pipe\ncut out from the pressure test manifold sites in accordance to NNG’s procedure 80.803.\nHowever, procedure 80.803 section 3.1 specified that this only applies to pressure test\nheaders that are within one mile of the pipe to be tested. There is no geographic\nrequirement for testing the pressure test manifold as required in § 192.624(c)(1)(iii) and\ntherefore, NNG’s one mile limitation should be removed from its procedures.\nNNG must amend its written procedures to comply with the requirements of §\n192.624(c)(1)(iii) in accordance with § 192.605(a).\n\n\n\n5. 6. § 192.710 Transmission lines: Assessments outside of high consequence areas.\n(a) . . . .\n(d) Data analysis. An operator must analyze and account for the data obtained from\nan assessment performed under paragraph (c) of this section to determine if a\ncondition could adversely affect the safe operation of the pipeline using personnel\nqualified by knowledge, training, and experience. In addition, when analyzing inline\ninspection data, an operator must account for uncertainties in reported results (e.g.,\ntool tolerance, detection threshold, probability of detection, probability of\nidentification, sizing accuracy, conservative anomaly interaction criteria, location\naccuracy, anomaly findings, and unity chart plots or equivalent for determining\nuncertainties and verifying actual tool performance) in identifying and\ncharacterizing anomalies.\nNNG’s procedures for data analysis did not provide adequate guidance on how NNG\nintegrates the information from the assessments performed in locations outside of a high\nconsequence area (HCA) as required by § 192.710(d). Specifically, NNG’s procedure\n140.201 section 5.2 only provided a basic overview of NNG’s process for data\nintegration. NNG did not provide specifics for how to perform data integration and the\nprocedure did not include a process for graphically integrating all data. During PHMSA’s\ninspection, NNG’s personnel verbally explained to PHMSA representatives NNG’s\nactual detailed data integration process, but none of what was verbally described was\nincluded in the written procedure.\nNNG must amend its written procedures to comply with the requirements of § 192.710(d)\nin accordance with § 192.605(a).\n§ 192.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(a) . . . .\n(c) Risk assessment. An operator must conduct a risk assessment that follows\nASME/ANSI B31.8S, section 5, and considers the identified threats for each covered\nsegment. An operator must use the risk assessment to prioritize the covered\nsegments for the baseline and continual reassessments (§§ 192.919, 192.921,\n192.937), and to determine what additional preventive and mitigative measures are\nneeded (§ 192.935) for the covered segment….\nNNG’s risk model prioritizing moderate consequence areas (MCAs) and HCAs did not\nadequately consider the identified threats for each covered segment, per § 192.917(c).\nSpecifically, the weighting factors used to determine risk for two threats (internal\ncorrosion and stress corrosion cracking) were assigned abnormally low weights in the\nmodel which were not technically justified. This is an issue because if a failure occurred\ndue to either of those risks, the risk model ranking would not be affected.\nNNG must amend its written risk assessment procedures and re-run the risk model to also\n\n\n\namend the written baseline assessment schedule for MCAs to comply with the\nrequirements of § 192.917(c) in accordance § 192.907(a), which requires implementation\nof Subpart O, and §192.911, which provides the elements of an integrity management\nprogram.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\nPlease refer to this 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 available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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 of\nreceipt 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 in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n90 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that NNG maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Gregory A Ochs, Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 3-2024-010-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n\n\ncc: David Geck (david.geck@nngco.com)\nThomas Correll (thomas.correll@nngco.com)\nJohn Gormley (john.gormley@nngco.com)\nLaura Demman (laura.demman@nngco.com)\nBrian Mundt (brian.mundt@nngo.com)","truncated":false,"body_characters":15122}