{"operation":"document","citation":"CPF 420182003W","title":"NORTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-19","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420182003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420182003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420182003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420182003W","body":"Warning Letter involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2018-11-19 and is reported as closed as of 2018-11-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420182003W_Warning Letter_11192018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420182003W/420182003W_Warning%20Letter_11192018.pdf\n\n420182003W_Warning Letter_11192018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420182003W/420182003W_Warning%20Letter_11192018_text.pdf\n\n420182003W_Warning Letter_11192018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 19, 2018\nRoyce Ramsay\nVice President of Operations\nNorthern Natural Gas Co.\n1111 South 103rd Street\nOmaha, Nebraska 68124\nCPF-4-2018-2003W\nDear Mr. Ramsay:\nOn multiple occasions between December 12, 2017 to August 18, 2018, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected your Matagorda Offshore Pipeline System in Texas.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by\nthe operator at intervals not exceeding 15 months, but at least one each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nNorthern Natural Gas failed to follow its written Operations and Maintenance procedures for\ncompleting Form 80.408a - Record of In Place Facility Abandonment’, during the abandonment\n\n\n\nof its Matagorda Offshore Pipeline System (MOPS). The abandonment of this system was\nperformed over a period of time from 1991-2014.\nThe PHMSA inspectors reviewed the 80.408 Abandonment of Facilities procedures; Section 5\npage 2-3 Rev 16 12/31/2015 and 0190 Engineering Standard Disposition of Abandoned Facilities;\nSection 6 page 2 Rev 5 12/10/2013. Records show that documentation was completed properly\nfor 2 out of 9 abandoned segments since 2013.\nAdditionally, abandonment certifications submitted to PHMSA, failed to capture all the required\nelements of 192.727 (g)(1). Out of the 9 abandoned segments, certifications were submitted for\nonly 5 segments. Of the 5 submitted, only 1 certification (dated 3/16/2015) was properly\ndocumented.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related 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 identified in this letter.\nFailure to do so will result in Northern Natural Gas being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2018-2003W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nMary L. McDaniel, P. E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4524}