{"operation":"document","citation":"CPF 420201007M","title":"NORTHERN NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-10-30","effective_on":null,"summary":"CLOSED notice of amendment citing 191.5(a), 192.303, 192.605(a), 192.615(c), 192.715(c), 192.907(a), 192.911(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420201007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420201007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420201007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420201007M","body":"Notice of Amendment involving NORTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 191.5(a),  192.303,  192.605(a),  192.615(c),  192.715(c),  192.907(a),  192.911(c). The case was opened on 2020-10-30 and is reported as closed as of 2021-03-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420201007M_Closure Letter_03182021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420201007M/420201007M_Closure%20Letter_03182021.pdf\n\n420201007M_Closure Letter_03182021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420201007M/420201007M_Closure%20Letter_03182021_text.pdf\n\n420201007M_Notice of Amendment_10302020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420201007M/420201007M_Notice%20of%20Amendment_10302020.pdf\n\n420201007M_Notice of Amendment_10302020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420201007M/420201007M_Notice%20of%20Amendment_10302020_text.pdf\n\n420201007M_Operator Response to Notice_11202020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420201007M/420201007M_Operator%20Response%20to%20Notice_11202020.pdf\n\n420201007M_Closure Letter_03182021_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nMarch 18, 2021\nTom Correll\nVice President of Pipeline Safety and Risk\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, Nebraska 68124\nCPF 4-2020-1007M\nDear Mr. Correll:\nFrom September 9, 2019 through February 07, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Northern Natural Gas Company’s (NNGC) operations, maintenance, and emergency\nprocedures for its natural gas transmission pipeline systems located in Texas, New Mexico, and\nOklahoma. As a result of the inspection, NNGC was issued a Notice of Amendment on October\n30, 2020, which proposed amendment of your procedures.\nNNGC submitted its final amended procedures on March 1, 2021. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: John Gormley, Sr Pipeline Safety Specialist, Northern Natural Gas Company,\njohn.gormley@nngco.com\n\n420201007M_Notice of Amendment_10302020_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nOctober 30, 2020\nTom Correll\nVice President of Pipeline Safety and Risk\nNorthern Natural Gas Company\n1111 South 103rd Street\nOmaha, Nebraska 68124\nCPF 4-2020-1007M\nDear Mr. Correll:\nFrom September 09, 2019 through February 07, 2020, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Northern Natural Gas Company’s (NNGC) operations, maintenance, and\nemergency procedures for its natural gas transmission pipeline systems located in Texas, New\nMexico, and Oklahoma.\nBased on the inspection, PHMSA has identified the apparent inadequacies found within NNGC’s\nplans or procedures as described below:\n1. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nNNGC’s written construction procedures do not require the operator to document the coating\nthickness and voltages used to detect holidays on pipeline coating during installation of bored pipe\nconsistent with industry standards and practice.\nDuring the inspection, PHMSA inspectors reviewed records of bored pipeline, TXB85301.\nInspectors noted that NNGC had not recorded dry film thickness measurements of applied coating\nand voltages used to detect holidays. Upon further procedural review, NNGC did not have\ncomprehensive written coating procedures that require the operator to document the coating\nthickness and voltages used to detect holidays on pipe coating.\n\n\n\n2\nNNGC must amend its written construction procedures to include coating applications and\nevaluation procedures.\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once 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.\n§ 192.715 Transmission lines: Permanent field repair of welds.\n(a) . . .\n(c) A defective weld which cannot be repaired in accordance with paragraph (a) or\n(b) of this section must be repaired by installing a full encirclement welded split sleeve\nof appropriate design.\nNNGC’s written procedure for the permanent field repair of welds failed to properly address all\npotential repair methods in accordance with § 192.715(c).\nNNGC’s Operating Procedure, 80.201, Repair of In-Service Pipelines (Rev. 19, 08/28/2019)\nidentified “Mechanical Sleeve” and “Other method as determined by pipeline safety through\nreliable engineering test and analysis” as its permanent repair methods for leaking and non-leaking\ndefects. However, mechanical sleeve has not been qualified as a permanent weld repair method.\nSection 5.9.3 Standard Repair Methods for Girth Weld Defects, (Page 11 of 16) states:\nGirth Weld Defects Leak Non-\nLeaking\nRepair Method Standard\nCylinder Replacement 0075 X X\nType B Pressure Containing\n8354 X X\nSleeve\nWeld Repair 8362 - X\nMechanical Sleeve - X X\nOther method as determined by pipeline safety through reliable engineering test and\nanalysis\nNNGC must amend its written procedure to address the use of a mechanical sleeve as a temporary\nweld repair method, or submit an Engineering Test and Analysis Report of Mechanical Sleeve to\ndemonstrate an acceptable method of permanent repair of girth weld defects in accordance with §\n192.715(c).\n\n\n\n3\n3. § 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\n§ 192.911 What are the elements of an integrity management program?\nAn operator's initial integrity management program begins with a framework (see §\n192.907) and evolves into a more detailed and comprehensive integrity management\nprogram, as information is gained and incorporated into the program. An operator\nmust make continual improvements to its program. The initial program framework\nand subsequent program must, at minimum, contain the following elements. (When\nindicated, refer to ASME/ANSI B31.8S (incorporated by reference, see §192.7) for\nmore detailed information on the listed element.)\n(a) . . .\n(c) An identification of threats to each covered pipeline segment, which must include\ndata integration and a risk assessment. An operator must use the threat identification\nand risk assessment to prioritize covered segments for assessment (§ 192.917) and\nto evaluate the merits of additional preventive and mitigative measures (§ 192.935)\nfor each covered segment.\nNNGC’s writtenIntegrity Management Program procedures were inadequate because they did not\ninclude right-of-way patrol data as part of the data collection and integration required by\nASME/ANSI B31.8S.\nDuring the inspection, PHMSA inspectors reviewed aerial patrol data records and aerial patrol\ngenerated Maintenance Job Tickets. Additionally, PHMSA inspectors requested to review\ndocumentation of data integration of the Maintenance Job Tickets and associated corrective actions\ninto its Integrity Management Program. However, NNGC was not able to provide evidence of data\ncollection and integration of patrol data in its Integrity Management Program in accordance with\nASME/ANSI B31.8S at time of inspection.\nNNGC must amend its written Integrity Management Program procedures to include a process for\nintegrating data collected from its right-of-way patrols into the Integrity Management Program.\n\n\n\n4\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once 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.\n§ 191.5 Immediate notice of certain incidents.\n(a) At the earliest practicable moment following discovery, but no later than one hour\nafter confirmed discovery, each operator must give notice in accordance with\nparagraph (b) of this section of each incident as defined in § 191.3.\nNNGC’s written procedure is inadequate because it does not provide a definition for the term\n“confirmed discovery” which is defined in § 191.3. Section 191.3 defines confirmed discovery as\n“when it can be reasonably determined, based on information available to the operator at the time\na reportable event has occurred, even if only based on a preliminary evaluation.”\nNNGC’s Operating Procedure, 10.101, Reporting and Notification of Pipeline, LNG &\nUnderground Storage Events (Rev. 35, 08/21/2019), Section 5.3.2 (Page 5 of 10) states:\n“5.3.2 Report incidents to Federal and State safety and environmental regulatory agencies\nusing telephone and/or written reports as applicable. For pipeline safety incidents, a\ntelephonic report is required to be made to the National Response Center (NRC) *at 1-800-\n424-8802* within one hour after confirmed discovery. Provide an update to the NRC\nwithin 48 hours of the original notification and reference the original NRC number. See\nappendix B of operating procedure 10.101 for the telephonic report form.”\nNNGC’s written procedure must be revised to include a definition for “confirmed discovery” to\nestablish clear guidelines when reporting pipeline safety incidents following “confirmed\ndiscovery.”\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once 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.\n\n\n\n5\n§ 192.615 Emergency plans.\n(c) Each operator shall establish and maintain liaison with appropriate fire, police,\nand other public officials to: Learn the responsibility and resources of each\ngovernment organization that may respond to a gas pipeline emergency; Acquaint\nthe officials with the operator's ability in responding to a gas pipeline emergency;\nIdentify the types of gas pipeline emergencies of which the operator notifies the\nofficials; and Plan how the operator and officials can engage in mutual assistance to\nminimize hazards to life or property.\nNNGC’s written procedures for handling abnormal operations and emergencies for pipeline\nsystems were inadequate because they did not address coordinating with electric and other utilities\nowners in the vicinity of the pipeline in the event of an emergency. The operations of utilities in\nthe vicinity of NNGC’s pipelines may provide sources of ignition for the product released from a\npipeline, may increase the burning time of fires that have already started, or may delay responders\nwho are attempting to make the situation safe.\nDuring the inspection, PHMSA inspectors reviewed NNGC’s Operating Procedure, 10.102,\nEmergencies (Rev. 28, 03/05/2019), and found that it did not include maintaining a liaison with\nelectric and other utilities owners as per API 1162.\nNNGC must amend the written procedure to include maintaining liaison with electric and other\nutilities owners in the vicinity of the pipeline.\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 Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document, you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 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 Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\n\n\n\n6\nIt is requested (not mandated) that NNGC maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Mary L. McDaniel, P.E., Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2020-1007M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":16044}