# NORTHERN NATURAL GAS CO — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

32024070NOA_Closure Letter_01122026_(23-264601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Closure%20Letter_01122026_(23-264601).pdf

32024070NOA_Closure Letter_01122026_(23-264601)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Closure%20Letter_01122026_(23-264601)_text.pdf

32024070NOA_Notice of Amendment_11062024_(23-264601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024070NOA/32024070NOA_Notice%20of%20Amendment_11062024_(23-264601).pdf

32024070NOA_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

32024070NOA_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

32024070NOA_Closure Letter_01122026_(23-264601)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
901 Locust Street, Suite 480
Kansas City, MO 64106
VIA ELECTRONIC MAIL TO: brian.mundt@nngco.com; thomas.correll@nngco.com;
keith.good@nngco.com;
January 12, 2026
Mr. Brian Mundt, President
Northern Natural Gas Company
1111 South 103rd Street
Omaha, NE 68124
RE: CPF 3-2024-070-NOA
Dear Mr. Mundt:
From March 28 to October 2, 2023, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected Northern Natural Gas Company’s (NNG) procedures in Omaha, Nebraska. On
November 6, 2024, pursuant to 49 CFR § 190.206, PHMSA issued a Notice of Amendment which
proposed amendment of NNG’s procedures.
NNG submitted its amended procedures on January 14, 2025, November 26, 2025, and December
8, 18, and 22, 2025. PHMSA has reviewed the amended procedures, and it appears that the
inadequacies outlined in the Notice of Amendment have been corrected.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank
you for your cooperation.
Sincerely,
David Barrett
Acting Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Thomas Correll, VP, Pipeline Safety and Risk, NNG, thomas.correll@nngco.com
Keith Good, Senior Pipeline Safety Specialist, NNG, keith.good@nngco.com

32024070NOA_Notice of Amendment_11062024_(23-264601)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: mark.hewett@nngco.com; thomas.correll@nngco.com;
keith.good@nngco.com; john.gormley@nngco.com
November 6, 2024
Mr. Mark Hewett
President & CEO
Northern Natural Gas Company
1111 S. 103rd Street
Omaha, NE 68124
CPF 3-2024-070-NOA
Dear Mr. Hewett:
From March 28 to October 2, 2023, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected Northern Natural Gas Company’s (NNG) procedures in Omaha, Nebraska.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
NNG’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
NNG’s Operations and Maintenance (O&M) Procedure, entitled “010.108 Procedure Review”
(O&M 010.108), was inadequate because it did not provide adequate detail regarding the
periodic review of work done by operator personnel to determine the effectiveness and adequacy



of the procedures used in normal operation and maintenance, as required by § 192.605(b)(8).
Specifically, the procedure did not: (1) prescribe how to document what work was reviewed and
(2) did not contain requirements to ensure that each procedure used by NNG would be
periodically reviewed.
First, the documentation requirement contained in O&M 010.108 was inadequate because it only
required NNG to generate a list of what procedures were reviewed, and did not prescribe the
information to be captured about what work was reviewed. After reviewing NNG’s records,
PHMSA confirmed that the result of the review constituted merely generating a list of
procedures that were reviewed annually. Per O&M 010.108, and the associated list of procedures
which were reviewed by NNG in 2021, 2022, and 2023, PHMSA found that NNG did not have a
process for documenting work that was performed as part of the review. O&M 010.108 must be
revised to include detailed documentation requirements to record what work was performed
during the process of reviewing each procedure, such as, but not limited to:
1. 2. 3. 4. Dates, times, and locations of work reviewed;
OQ tasks qualifications and training related to the performance of the maintenance or
operating procedure;
Critical tools and equipment used in the performance of the activity; and
Relevant pipeline system component or manufacturer data or guidance used in the
course of the procedure.
Second, O&M 010.108 was inadequate because it did not contain requirements regarding when
to perform a periodic review of each procedure. NNG’s policy was to review a listing of 18
frequently used procedures each year, as shown by “Table 1” of O&M 010.108. The chosen
procedures are selected based on “number of inquiries received regarding the procedure, the
number of related Maintenance Control System (MCS) tasks, frequency of tasks and any recent
changes to the procedure,” per section 5.2.1.1. However, no guidance or timeline was given for
when to review less common procedures. From a review of procedures provided to PHMSA
during the inspection, PHMSA determined that NNG had 195 unique procedures of which
NNG’s records showed that only 22 procedures had been reviewed for effectiveness from 2021
to 2023. Because O&M 010.108 failed to ensure each procedure is reviewed according to a
defined time period, it must be revised to include a maximum period of time for the review of
each procedure that is performed.
2. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.



NNG’s O&M Procedure, entitled “160.101 Valve Maintenance” (O&M 160.101), was
inadequate because it did not provide adequate detail regarding partial operation, pursuant to
§ 192.745(a). Specifically, O&M 160.101, section 5.1, stated only that “NNG personnel must
ensure valves operate partially” and that NNG personnel must ensure that the valve indicator
moves. After reviewing this procedure, PHMSA found in practice NNG personnel defined
“partial operation” to mean a minimal movement of the valve position indicator, which was not
sufficient to ensure that the valve was unseated from the closed position. NNG must amend the
procedure such that each type of valve has a defined partial operation range of movement that
ensures it is operational, per the requirements of § 192.745(a).
3. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
NNG’s O&M procedure for each alternative equivalent technology, entitled “160.201 Rupture
Mitigation Valves,” was inadequate because it did not include all the requirements specified in
§ 192.745(d). Following PHMSA’s inspection, NNG amended the procedure and found to be
acceptable. Therefore, no further action is needed by NNG.
4. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
NNG’s procedure for maintaining gas detection and alarms in compressor stations, required
under § 192.736(c), was inadequate because it failed to provide adequate detail for recording
performance tests, as required by § 192.605(a). Specifically, O&M Procedure, entitled “030.102
Compressor Stations Additional Safety Devices” (O&M 030.102), section 6, specified that NNG
must “record data from tests.” However, PHMSA found that not all data was recorded from the
results of tests because NNG’s MCS did not include a way to record results from performance
tests of each specific device. In some instances, multiple device tests in a single compressor
station location were recorded only by a single check mark, or signature, on a form created by
local personnel. During PHMSA’s inspection, NNG stated that the procedure and form will be



revised in the second half of 2024 for recording the results. NNG must amend its written
procedures to comply with the requirements of § 192.736(c) to ensure that all relevant data from
maintenance and performance tests are documented.
5. § 192. 605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
NNG’s O&M Procedure, entitled “010.310 Management of Change” (O&M 010.310), was
inadequate because it failed to include the requirement for the 30-day notification to PHMSA
OPS after adopting a substantial change to the program, per the requirements of § 192.909(b).
Specifically, O&M 010.310, section 3.2.5, “Communication to affected parties,” stated that NNG
must “identify who will make notification of the changes and who will be notified of the
changes," but failed to include notification to PHMSA OPS within 30 days if the change is
substantial. The procedure was amended after the inspection and found to be acceptable.
Therefore, no further action is needed by NNG.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Enforcement Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under
5 U.S.C. § 552(b), along with the complete original document you must provide a second copy
of the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment
under 5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within



90 days of receipt of this Notice. This period may be extended by written request for good cause.
Once the inadequacies identified herein have been addressed in your amended procedures, this
enforcement action will be closed.
It is requested (not mandated) that NNG maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 3-2024-070-NOA and, for each document you submit, please provide a copy in
electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Thomas Correll, Director, Pipeline Safety, Northern Natural Gas,
thomas.correll@nngco.com
John Gormley, Sr. Corrosion Specialist, Northern Natural Gas,
john.gormley@nngco.com
Keith Good, Pipeline Safety Specialist, Northern Natural Gas,
keith.good@nngco.com
- **truncated:** false
- **body characters:** 15346