CPF 520131006M
CPF 520131006M
party submissionOfficial PDF520131006M_Operator Response_05232013.pdf#
520131006M_closure letter_05282013_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED May 28, 2013 Mr. Robert Checketts Vice President – Operations, IT and Engineering Kern River Gas Transmission Company 2755 East Cottonwood Parkway Salt Lake City, UT 84121 CPF 5-2013-1006M Dear Mr. Checketts: On April 9-11, 2013, representatives from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Kern River Gas Transmission (KRGT) procedures in Salt Lake City, UT. As a result of the inspection, KRGT was issued a Notice of Amendment on April 25, 2013, which proposed amendment of your procedures. KRGT submitted its amended procedures on May 23, 2013. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 D. Mulligan#
520131006M_notice of amendment_04252013_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 25, 2013 Mr. Robert Checketts Vice President – Operations, IT and Engineering Kern River Gas Transmission Company 2755 East Cottonwood Parkway Salt Lake City, UT 84121 CPF 5-2013-1006M Dear Mr. Checketts: On April 9-11, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Kern River Gas Transmission Company’s procedures for operations, maintenance, and emergency response in Salt Lake City, UT. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Kern River Gas Transmission Company’s (KRGT) plans or procedures, as described below: 1. §192.605 Procedural manual for operations, maintenance, and emergencies. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (2) Controlling corrosion in accordance with the operations and maintenance requirements of Subpart I of this part. §192.463 External corrosion control: Cathodic protection. (a) Each cathodic protection system required by this subpart must provide a level of cathodic protection that complies with one or more of the applicable criteria contained in Appendix D of this part. If none of these criteria is applicable, the cathodic protection system must provide a level of cathodic protection at least equal to that provided by compliance with one or more of these criteria.#
520131006M_notice of amendment_04252013_text.pdf, page 2At the time of the inspection, KRGT’s Establishing Cathodic Protection Criteria, Corrosion Control Procedures 20.06.03, did not include IR drop consideration in accordance with Appendix D, Section II. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance 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). 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 a Final Order. If, after opportunity for a hearing, 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. § 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 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 KRGT maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2013-1006M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 D. Mulligan (#142073) 2#
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