NORTHERN NATURAL GAS CO — Notice of Probable Violation

party submissionOfficial PDF32024012NOPV_Operator Response to Notice_02292024_(23-264235).pdf#

case documentOfficial PDF32024012NOPV_PCP PCO_02062024_(23-264235).pdf#

case documentOfficial PDF32024012NOPV_PCP PCO_02062024_(23-264235)_text.pdf#

32024012NOPV_Closure Letter_03112025_(23-264235)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: mark.hewett@nngco.com; thomas.correll@nngco.com; Brian.Mundt@nngco.com March 11, 2025 Mr. Mark Hewett President & CEO Northern Natural Gas Company 1111 S. 103rd Street Omaha, Nebraska 68124 RE: CPF 3-2024-012-NOPV Dear Mr. Hewett: On April 5, 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Northern Natural Gas Company (NNG) a Final Order pursuant to 49 CFR § 190.213. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation provided and confirmation of payment of the civil penalty, it has been determined that NNG has complied with the terms of this Order. Accordingly, this case is now closed, and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Gregory A. Ochs Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Brian Mundt, VP Operations, NNG, brian.mundt@nngco.com Thomas Correll, Director, Pipeline Safety, NNG, thomas.correll@nngco.com#

32024012NOPV_Final Order_04052024_(23-264235)_text.pdf, page 1Official PDFApril 5, 2024 VIA ELECTRONIC MAIL TO: mark.hewett@nngco.com Mr. Mark Hewett President and Chief Executive Officer BHE Pipeline Group 1111 South 103rd Street Omaha, Nebraska 68124 Re: CPF No. 3-2024-012-NOPV Dear Mr. Hewett: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, finds that the civil penalty amount of $68,800 has been paid in full, and specifies actions that need to be taken to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosures (Final Order and NOPV) cc: Mr. Gregory Ochs, Director, Central Region, Office of Pipeline Safety, PHMSA Ms. Laura Demman, President, Northern Natural Gas Co., laura.demman@nngco.com Mr. Brian Mundt, Vice President of Operations, Northern Natural Gas Co., brian.mundt@nngo.com Mr. Thomas Correll, Vice President, Pipeline Safety and Risk, Northern Natural Gas Co., thomas.correll@nngco.com CONFIRMATION OF RECEIPT REQUESTED#

32024012NOPV_Final Order_04052024_(23-264235)_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 __________________________________________ In the Matter of ) Northern Natural Gas Company, ) CPF No. 3-2024-012-NOPV a subsidiary of Berkshire Hathaway ) Energy Company, ) ) ) ) Respondent. ) __________________________________________) FINAL ORDER On February 6, 2024, pursuant to 49 C.F.R. § 190.207, the Director, Central Region, Office of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Northern Natural Gas Company (Respondent). The Notice proposed finding that Respondent had violated the pipeline safety regulations in 49 C.F.R. Part 192. The Notice also proposed certain measures to correct the violations. Respondent did not contest the allegations of violation or corrective measures, provided additional information, and paid the proposed civil penalty on March 5, 2024. Based upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the pipeline safety regulations listed below, as more fully described in the enclosed Notice, which is incorporated by reference: 49 C.F.R. § 192.5(b)(3)(ii) (Item 1) ─ Respondent failed to identify three sites (located in Sartell, MN; Houghton, MI; and Mankato, MN) as class 3 locations. 49 C.F.R. § 192.605(a) (Item 2) ─ Respondent failed to follow its manual of written procedures as required. Specifically, Respondent failed to follow its procedure 140.101, section 3.11.3 regarding four initial baseline assessment plans in moderate consequence areas. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. In accordance with 49 C.F.R. § 190.223, Respondent is assessed the proposed civil penalty amount of $68,800, which Respondent has already paid in full.#

32024012NOPV_Final Order_04052024_(23-264235)_text.pdf, page 3Compliance Actions Pursuant to 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the actions proposed in the enclosed Notice to correct the violations. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Upon completion of the ordered actions, Respondent may request that the Director close the case. Failure to comply with this Order may result in the assessment of civil penalties under 49 C.F.R. § 190.223 or in referral to the Attorney General for appropriate relief in a district court of the United States. Warning Item With respect to Item 3, the Notice alleged a probable violation of 49 C.F.R. § 192.710(b)(1) but did not propose a civil penalty or compliance order for this item. Therefore, this is considered to be a warning item. If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this order are effective upon service in accordance with 49 C.F.R. § 190.5. April 5, 2024 ___________________________________ _________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#