{"operation":"document","citation":"CPF 420091003W","title":"NORTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-02-02","effective_on":null,"summary":"CLOSED warning letter citing 192.317(b), 192.477, 192.479(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420091003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420091003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420091003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420091003W","body":"Warning Letter involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.317(b),  192.477,  192.479(a). The case was opened on 2009-02-02 and is reported as closed as of 2009-02-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420091003W_Operator Response_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091003W/420091003W_Operator%20Response_02192009.pdf\n\n420091003W_warning_02022009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091003W/420091003W_warning_02022009.pdf\n\n420091003W_warning_02022009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420091003W/420091003W_warning_02022009_text.pdf\n\n420091003W_warning_02022009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 2, 2009\nMr. Royce Ramsay\nNorthern Natural Gas Company\n1111 103rd Street\nOmaha, Nebraska 68124-1000\nCPF 4-2009-1003W\nDear Mr. Ramsay:\nOn September 15-19 and 23-26, 2008, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nrecords and procedures of your Spearmen and Spraybury Pipeline Systems at your Amarillo and\nMidland, Texas offices, respectively.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable\nviolation is:\n1. §192.317 Protection from hazards.\n(b) Each above ground transmission line or main, not located offshore or in inland\nnavigable water areas, must be protected from accidental damage by vehicular\ntraffic or other similar causes, either by being placed at a safe distance from the\ntraffic or by installing barricades.\nThe K-B pipeline Crossover facility in Gaines County is located away from regular domestic traffic\nbut still needs protection from possible farm equipment activity. NNG must install a barrier to better\nprotect this above ground piping assembly from being hit and causing possible component\ndamage.\n2. §192.477 Internal corrosion control: Monitoring.\nIf corrosive gas is being transported, coupons or other suitable means must be used\nto determine the effectiveness of the steps taken to minimize internal corrosion.\nEach coupon or other means of monitoring internal corrosion must be checked two\ntimes each calendar year, but with interval not exceeding 7 1/2 months.\n\n\n\nThe most recent scale records at the Brownfield and Sprayberry Stations available during the\ninspection indicated substantial iron and sulfate presence but there were no coupons to\ncorroborate if internal corrosion was present. NNG must develop procedures to monitor for internal\ncorrosion at sites where there is probable occurrence of this pipeline threat. One of these sites is\nthe 24 inch OK 24” OKG 21501 in Ellis County, Texas where a pipeline failure occurred due to\ninternal corrosion.\n3. §192.479 Atmospheric corrosion control; General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, the\noperator need not protect from atmospheric corrosion any pipeline for which the\noperator demonstrates by test, investigation, or experience appropriate to the\nenvironment of the pipeline that corrosion will—\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled inspection.\nVery heavy atmospheric corrosion was evident at the Sunray Compressor Station piping. NNG’s O\nand M procedures state that all above ground piping will be recoated if found to be in need of\nrepair. NNG should review and amend, as necessary, their procedures to specify requirements to\nbe used by operations personnel for making a determination of how and when the maintenance\nwork is to be achieved and completed in a timely fashion.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violations persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nBe advised that failure to do so will result in Noble Energy Inc. being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2009-1003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterial Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n2","truncated":false,"body_characters":5572}