{"operation":"document","citation":"CPF 32024070NOA","title":"NORTHERN NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-11-06","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024070noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024070noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024070noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024070NOA","body":"Notice of Amendment involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2024-11-06 and is reported as closed as of 2026-01-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024070NOA_Closure Letter_01122026_(23-264601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Closure%20Letter_01122026_(23-264601).pdf\n\n32024070NOA_Closure Letter_01122026_(23-264601)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Closure%20Letter_01122026_(23-264601)_text.pdf\n\n32024070NOA_Notice of Amendment_11062024_(23-264601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Notice%20of%20Amendment_11062024_(23-264601).pdf\n\n32024070NOA_Notice of Amendment_11062024_(23-264601)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Notice%20of%20Amendment_11062024_(23-264601)_text.pdf\n\n32024070NOA_Operator Response to Notice_01142025_(23-264601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Operator%20Response%20to%20Notice_01142025_(23-264601).pdf\n\n32024070NOA_Closure Letter_01122026_(23-264601)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: brian.mundt@nngco.com; thomas.correll@nngco.com;\nkeith.good@nngco.com;\nJanuary 12, 2026\nMr. Brian Mundt, President\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, NE 68124\nRE: CPF 3-2024-070-NOA\nDear Mr. Mundt:\nFrom March 28 to October 2, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Northern Natural Gas Company’s (NNG) procedures in Omaha, Nebraska. On\nNovember 6, 2024, pursuant to 49 CFR § 190.206, PHMSA issued a Notice of Amendment which\nproposed amendment of NNG’s procedures.\nNNG submitted its amended procedures on January 14, 2025, November 26, 2025, and December\n8, 18, and 22, 2025. PHMSA has reviewed the amended procedures, and it appears that the\ninadequacies outlined in the Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Thomas Correll, VP, Pipeline Safety and Risk, NNG, thomas.correll@nngco.com\nKeith Good, Senior Pipeline Safety Specialist, NNG, keith.good@nngco.com\n\n32024070NOA_Notice of Amendment_11062024_(23-264601)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: mark.hewett@nngco.com; thomas.correll@nngco.com;\nkeith.good@nngco.com; john.gormley@nngco.com\nNovember 6, 2024\nMr. Mark Hewett\nPresident & CEO\nNorthern Natural Gas Company\n1111 S. 103rd Street\nOmaha, NE 68124\nCPF 3-2024-070-NOA\nDear Mr. Hewett:\nFrom March 28 to October 2, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Northern Natural Gas Company’s (NNG) procedures 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. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nNNG’s Operations and Maintenance (O&M) Procedure, entitled “010.108 Procedure Review”\n(O&M 010.108), was inadequate because it did not provide adequate detail regarding the\nperiodic review of work done by operator personnel to determine the effectiveness and adequacy\n\n\n\nof the procedures used in normal operation and maintenance, as required by § 192.605(b)(8).\nSpecifically, the procedure did not: (1) prescribe how to document what work was reviewed and\n(2) did not contain requirements to ensure that each procedure used by NNG would be\nperiodically reviewed.\nFirst, the documentation requirement contained in O&M 010.108 was inadequate because it only\nrequired NNG to generate a list of what procedures were reviewed, and did not prescribe the\ninformation to be captured about what work was reviewed. After reviewing NNG’s records,\nPHMSA confirmed that the result of the review constituted merely generating a list of\nprocedures that were reviewed annually. Per O&M 010.108, and the associated list of procedures\nwhich were reviewed by NNG in 2021, 2022, and 2023, PHMSA found that NNG did not have a\nprocess for documenting work that was performed as part of the review. O&M 010.108 must be\nrevised to include detailed documentation requirements to record what work was performed\nduring the process of reviewing each procedure, such as, but not limited to:\n1. 2. 3. 4. Dates, times, and locations of work reviewed;\nOQ tasks qualifications and training related to the performance of the maintenance or\noperating procedure;\nCritical tools and equipment used in the performance of the activity; and\nRelevant pipeline system component or manufacturer data or guidance used in the\ncourse of the procedure.\nSecond, O&M 010.108 was inadequate because it did not contain requirements regarding when\nto perform a periodic review of each procedure. NNG’s policy was to review a listing of 18\nfrequently used procedures each year, as shown by “Table 1” of O&M 010.108. The chosen\nprocedures are selected based on “number of inquiries received regarding the procedure, the\nnumber of related Maintenance Control System (MCS) tasks, frequency of tasks and any recent\nchanges to the procedure,” per section 5.2.1.1. However, no guidance or timeline was given for\nwhen to review less common procedures. From a review of procedures provided to PHMSA\nduring the inspection, PHMSA determined that NNG had 195 unique procedures of which\nNNG’s records showed that only 22 procedures had been reviewed for effectiveness from 2021\nto 2023. Because O&M 010.108 failed to ensure each procedure is reviewed according to a\ndefined time period, it must be revised to include a maximum period of time for the review of\neach procedure that is performed.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\n\n\n\nNNG’s O&M Procedure, entitled “160.101 Valve Maintenance” (O&M 160.101), was\ninadequate because it did not provide adequate detail regarding partial operation, pursuant to\n§ 192.745(a). Specifically, O&M 160.101, section 5.1, stated only that “NNG personnel must\nensure valves operate partially” and that NNG personnel must ensure that the valve indicator\nmoves. After reviewing this procedure, PHMSA found in practice NNG personnel defined\n“partial operation” to mean a minimal movement of the valve position indicator, which was not\nsufficient to ensure that the valve was unseated from the closed position. NNG must amend the\nprocedure such that each type of valve has a defined partial operation range of movement that\nensures it is operational, per the requirements of § 192.745(a).\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nNNG’s O&M procedure for each alternative equivalent technology, entitled “160.201 Rupture\nMitigation Valves,” was inadequate because it did not include all the requirements specified in\n§ 192.745(d). Following PHMSA’s inspection, NNG amended the procedure and found to be\nacceptable. Therefore, no further action is needed by NNG.\n4. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nNNG’s procedure for maintaining gas detection and alarms in compressor stations, required\nunder § 192.736(c), was inadequate because it failed to provide adequate detail for recording\nperformance tests, as required by § 192.605(a). Specifically, O&M Procedure, entitled “030.102\nCompressor Stations Additional Safety Devices” (O&M 030.102), section 6, specified that NNG\nmust “record data from tests.” However, PHMSA found that not all data was recorded from the\nresults of tests because NNG’s MCS did not include a way to record results from performance\ntests of each specific device. In some instances, multiple device tests in a single compressor\nstation location were recorded only by a single check mark, or signature, on a form created by\nlocal personnel. During PHMSA’s inspection, NNG stated that the procedure and form will be\n\n\n\nrevised in the second half of 2024 for recording the results. NNG must amend its written\nprocedures to comply with the requirements of § 192.736(c) to ensure that all relevant data from\nmaintenance and performance tests are documented.\n5. § 192. 605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nNNG’s O&M Procedure, entitled “010.310 Management of Change” (O&M 010.310), was\ninadequate because it failed to include the requirement for the 30-day notification to PHMSA\nOPS after adopting a substantial change to the program, per the requirements of § 192.909(b).\nSpecifically, O&M 010.310, section 3.2.5, “Communication to affected parties,” stated that NNG\nmust “identify who will make notification of the changes and who will be notified of the\nchanges,\" but failed to include notification to PHMSA OPS within 30 days if the change is\nsubstantial. The procedure was amended after the inspection and found to be acceptable.\nTherefore, no further action is needed by NNG.\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\n5 U.S.C. § 552(b), along with the complete original document you must provide a second copy\nof the 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\n\n\n\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 3-2024-070-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Thomas Correll, Director, Pipeline Safety, Northern Natural Gas,\nthomas.correll@nngco.com\nJohn Gormley, Sr. Corrosion Specialist, Northern Natural Gas,\njohn.gormley@nngco.com\nKeith Good, Pipeline Safety Specialist, Northern Natural Gas,\nkeith.good@nngco.com","truncated":false,"body_characters":15346}