RATON GAS TRANSMISSION CO — Notice of Amendment

party submissionOfficial PDF520181003M_Operator Response to Notice_04202018.pdf#

520181003M_Closure Letter_09302019_text.pdf, page 1Official PDFVIA FED EX – TRACKING NO. 7763 6972 4115 September 30, 2019 Ms. Patricia P. Link President Raton Gas Transmission 223 N Guadalupe St., Suite 306 Santa Fe, NM 87501 CPF 5-2018-1003M Closure Letter Dear Ms. Link: On June 19 through 23, and June 26 through 29, 2017, a representative 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 Raton Gas Transmission’s (RGT) procedures in Raton, New Mexico. As a result of the inspection, RGT was issued a Notice of Amendment on March 16, 2018, which proposed amendment of your procedures. RGT submitted a letter of amended procedures and changes dated April 20, 2018, received by PHMSA on April 24, 2018. On August 13, 2018, a PHMSA representative met with you and your consultant in the Raton Gas Transmission offices, located in Raton, New Mexico, to discuss remaining inadequacies in the April 24, 2018 submittal. RGT submitted amended procedures and changes dated November 12, 2018. A meeting was held on May 15, 2019, at RGT's Raton, NM office to discuss RGT's revised submittal, dated November 12, 2018. During the meeting, specific inadequacies within RGT's Damage Prevention Program and Emergency Plan were discussed. RGT submitted its amended procedures on August 19, 2019. PHMSA 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#

520181003M_Closure Letter_09302019_text.pdf, page 2you for your cooperation. Sincerely, Dustin B. Hubbard Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 D. Fehling (#155181)#

520181003M_Notice of Amendment_03162018_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 16, 2018 Ms. Patricia Link President Raton Gas Transmission 223 N. Guadalupe St #306 Santa Fe, NM 87501 CPF 5-2018-1003M Dear Ms. Link: On June 19 through 23, and June 26 through 29, 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Raton Gas Transmission procedures for operations and maintenance in Raton, New Mexico, and Trinidad, Colorado. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Raton Gas Transmission 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. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part. Raton Gas Transmission (RGT) did not establish adequate written procedure for inspecting and testing of pressure limiting and regulating stations in accordance with §192.739.#

520181003M_Notice of Amendment_03162018_text.pdf, page 2Interviews of RGT personnel revealed that they inspect and test each of the devices differently than their written procedural manual. In addition, it appears that the procedure combines testing for relief devices and testing for regulator stations. Therefore, RGT must modify their written procedure to provide details on how to inspect and test each device as required by §192.739. 2. §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. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part. RGT did not establish adequate written Operations and Maintenance Manual to include a written procedure for line locating, which is identified as a covered task in RGT’s Operator Qualifications (OQ) Program. 3. §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. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and subpart M of this part. RGT did not establish adequate written Operations and Maintenance (O&M) Manual to include a written procedure for damage prevention programs in accordance with §192.614(c). RGT’s O&M Manual, Section 1 – General, which covers damage prevention, is code paraphrased without actual procedures, and it appears to be confused with the Public Awareness requirements in accordance with §192.616. RGT’s damage prevention section states that, “This activity is not a covered task under the RGT Operator Qualification Plan”, however, the tasks associated with damage prevention are covered tasks. Therefore, RGT must modify their written procedure to provide details on how to comply with the damage prevention program as required by §192.614(c). 4. §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. RGT did not establish adequate written corrosion control procedures for inspecting each pipeline or portion of pipeline that is exposed to the atmosphere in accordance with §192.481. Therefore, RGT must modify their procedure to provide details on how to inspect each pipeline or portion of pipeline that exposed to the atmosphere for evidence of atmospheric corrosion as required by §195.481. 2#

520181003M_Notice of Amendment_03162018_text.pdf, page 35. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (1) Receiving, identifying, and classifying notices of events which require immediate response by the operator. RGT did not establish adequate written procedure for identifying and classifying major and minor leaks of events which require immediate response by the operator. RGT fails to clearly define what constitutes a major leak versus a minor leak. Therefore, RGT must modify their procedure to provide details on how to identify and classify major and minor leaks of events which require immediate response by operator as required by §192.615(a)(1). 6. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (2) Establishing and maintaining adequate means of communication with appropriate fire, police, and other public officials. RGT did not establish adequate written Emergency Liaison Program for identifying public officials or utility owners, nor does it state how the operator will maintain contacts to ensure that liaisons haven't changed. 7. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (3) Prompt and effective response to a notice of each type of emergency, including the following: (i) Gas detected inside or near a building. RGT did not establish an adequate written Emergency Plan to demonstrate RGT will take prompt and effective response to a notice of each type of emergency, such as: gas detected inside of near a building, or fire/explosion near or directly involving a pipeline facility. 8. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (4) The availability of personnel, equipment, tools, and materials, as needed at the scene of an emergency. RGT’s Procedure #180 includes a list of equipment and materials available from contractors for use during an emergency. However, RGT did not establish adequate written procedure to include a process ensuring the availability of the equipment and/or tools, as needed at the 3#

520181003M_Notice of Amendment_03162018_text.pdf, page 4scene of an emergency. 9. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (5) Actions directed toward protecting people first and then property. RGT did not establish adequate written Emergency Plan to demonstrate how RGT will take actions directed toward protecting people first and then property. 10. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (6) Emergency shutdown and pressure reduction in any section of the operator’s pipeline system necessary to minimize hazards to life or property. RGT did not establish an adequate written Emergency Plan to describe the method for emergency shutdown or pressure reduction necessary to minimize hazards to life or property. 11. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (7) Making safe any actual or potential hazard to life or property. RGT did not establish an adequate written Emergency Plan to describe the method for making safe any actual or potential hazard to life or property. 12. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (8) Notifying appropriate fire, police, and other public officials of gas pipeline emergencies and coordinating with them both planned responses and actual responses during an emergency. RGT did not establish an adequate written Emergency Plan to demonstrate how the operator will maintain appropriate contacts with fire, police, and other public officials of gas pipeline emergencies. 13. §192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must 4#

520181003M_Notice of Amendment_03162018_text.pdf, page 5provide for the following: (9) Safely restoring any service outage. RGT did not establish an adequate written Emergency Plan to describe the method for safely restoring any service outage. 14. §192.615 Emergency plans. (b) Each operator shall: (2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective. RGT did not establish an adequate written emergency training process to adequately describe a continuing training program to assure that their operating personnel are knowledgeable of emergency procedures and verify that the training is effective. 15. §192.615 Emergency plans. (c) Each operator shall establish and maintain liaison with appropriate fire, police, and other public officials to: (4) Plan how the operator and officials can engage in mutual assistance to minimize hazards to life or property. RGT did not establish an adequate written Emergency Plan to demonstrate how RGT will plan and engage in mutual assistance with officials in the event of an emergency. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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). 5#

520181003M_Notice of Amendment_03162018_text.pdf, page 6Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If 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. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within sixty (60) 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 Raton Gas Transmission maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Kim West, Acting Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2018-1003M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Kim West Acting 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. Fehling (#155181) 6#