{"operation":"document","citation":"CPF 420161002W","title":"NORTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-03-23","effective_on":null,"summary":"CLOSED warning letter citing 192.479(a), 192.479(c), 192.615(b)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420161002W","body":"Warning Letter involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.479(a),  192.479(c),  192.615(b)(3). The case was opened on 2016-03-23 and is reported as closed as of 2016-03-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420161002W_Operator Response to Notice_04292016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161002W/420161002W_Operator%20Response%20to%20Notice_04292016.pdf\n\n420161002W_Warning Letter_03232016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161002W/420161002W_Warning%20Letter_03232016.pdf\n\n420161002W_Warning Letter_03232016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161002W/420161002W_Warning%20Letter_03232016_text.pdf\n\n420161002W_Warning Letter_03232016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 23, 2016\nMr. Royce Ramsay, Vice President of Operations\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, NE 68214\nCPF 4-2016-1002W\nDear Mr. Ramsay:\nFrom March through November 2015, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nNorthern Natural Gas Company’s (NNG) pipelines and facilities in Nebraska, Kansas, Oklahoma\nand Texas.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n\n\n\n1. § 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(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.\nThe Burdet block valve 1 risers on line M610B in Kansas did not have an adequate soil-to-air\ninterface coating for prevention of atmospheric corrosion.\nWhile performing atmospheric coating inspections of NNG’s above ground block valve settings,\nit was observed that the area around the block valve risers had become covered with soil up to\nthe top of the connection flanges. The connection flanges did not have an appropriate coating to\nprevent corrosion at the soil-air interface.\nIn regards to Item 1 above, NNG submitted to PHMSA documentation and photographs that the\nsoil-air interface was repaired by removing soil from the connection flanges and coating the riser\nand flanges with an appropriate coating. PHMSA reviewed the correspondence and determined\nthe repair to be acceptable.\n2. § 192.615 Emergency plans.\n(b) Each operator shall:\n(3) Review employee activities to determine whether the procedures were effectively\nfollowed in each emergency.\nNNG did not review employee’s activities performed during the emergency response on line\nTXM15501-M880B to determine if procedures were effectively followed.\nWhile performing a review of emergency response activity, it was observed from NRC report\nNo. 20140051 that on April 11, 2014 NNG personnel responded to an emergency of an\nunintentional release of gas that was determined to be a leaking relief valve on line TXM15501-\nM880B. NNG could not produce documentation that following the emergency response activity\na review was conducted to determine if the procedures were effectively followed by their\npersonnel.\n2\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\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 items identified in this letter.\nFailure to do so will result in Norther Natural Gas Company 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 4-2016-1002W. 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\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5326}