{"operation":"document","citation":"CPF 520181003M","title":"RATON GAS TRANSMISSION CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-03-16","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(2), 192.615(a)(1), 192.615(a)(2), 192.615(a)(3)(i), 192.615(a)(4), 192.615(a)(5), 192.615(a)(6), 192.615(a)(7), 192.615(a)(8), 192.615(a)(9), 192.615(b)(2), 192.615(c)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520181003M","body":"Notice of Amendment involving RATON GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(2),  192.615(a)(1),  192.615(a)(2),  192.615(a)(3)(i),  192.615(a)(4),  192.615(a)(5),  192.615(a)(6),  192.615(a)(7),  192.615(a)(8),  192.615(a)(9),  192.615(b)(2),  192.615(c)(4). The case was opened on 2018-03-16 and is reported as closed as of 2019-09-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520181003M_Closure Letter_09302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181003M/520181003M_Closure%20Letter_09302019.pdf\n\n520181003M_Closure Letter_09302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181003M/520181003M_Closure%20Letter_09302019_text.pdf\n\n520181003M_Notice of Amendment_03162018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181003M/520181003M_Notice%20of%20Amendment_03162018.pdf\n\n520181003M_Notice of Amendment_03162018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181003M/520181003M_Notice%20of%20Amendment_03162018_text.pdf\n\n520181003M_Operator Response to Notice_04202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181003M/520181003M_Operator%20Response%20to%20Notice_04202018.pdf\n\n520181003M_Closure Letter_09302019_text.pdf\n\nVIA FED EX – TRACKING NO. 7763 6972 4115\nSeptember 30, 2019\nMs. Patricia P. Link\nPresident\nRaton Gas Transmission\n223 N Guadalupe St., Suite 306\nSanta Fe, NM 87501\nCPF 5-2018-1003M\nClosure Letter\nDear Ms. Link:\nOn June 19 through 23, and June 26 through 29, 2017, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Raton Gas Transmission’s\n(RGT) procedures in Raton, New Mexico. As a result of the inspection, RGT was issued a\nNotice of Amendment on March 16, 2018, which proposed amendment of your procedures.\nRGT submitted a letter of amended procedures and changes dated April 20, 2018, received by\nPHMSA on April 24, 2018. On August 13, 2018, a PHMSA representative met with you and\nyour consultant in the Raton Gas Transmission offices, located in Raton, New Mexico, to\ndiscuss remaining inadequacies in the April 24, 2018 submittal. RGT submitted amended\nprocedures and changes dated November 12, 2018. A meeting was held on May 15, 2019, at\nRGT's Raton, NM office to discuss RGT's revised submittal, dated November 12, 2018.\nDuring the meeting, specific inadequacies within RGT's Damage Prevention Program and\nEmergency Plan were discussed.\nRGT submitted its amended procedures on August 19, 2019. PHMSA staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\n\n\n\nyou for your cooperation.\nSincerely,\nDustin B. Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#155181)\n\n520181003M_Notice of Amendment_03162018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 16, 2018\nMs. Patricia Link\nPresident\nRaton Gas Transmission\n223 N. Guadalupe St #306\nSanta Fe, NM 87501\nCPF 5-2018-1003M\nDear Ms. Link:\nOn June 19 through 23, and June 26 through 29, 2017, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Raton Gas Transmission procedures for operations and maintenance in\nRaton, New Mexico, and Trinidad, Colorado.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nRaton Gas Transmission plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\nRaton Gas Transmission (RGT) did not establish adequate written procedure for inspecting\nand testing of pressure limiting and regulating stations in accordance with §192.739.\n\n\n\nInterviews of RGT personnel revealed that they inspect and test each of the devices\ndifferently than their written procedural manual. In addition, it appears that the procedure\ncombines testing for relief devices and testing for regulator stations. Therefore, RGT must\nmodify their written procedure to provide details on how to inspect and test each device as\nrequired by §192.739.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\nRGT did not establish adequate written Operations and Maintenance Manual to include a\nwritten procedure for line locating, which is identified as a covered task in RGT’s Operator\nQualifications (OQ) Program.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and subpart M of this part.\nRGT did not establish adequate written Operations and Maintenance (O&M) Manual to\ninclude a written procedure for damage prevention programs in accordance with §192.614(c).\nRGT’s O&M Manual, Section 1 – General, which covers damage prevention, is code\nparaphrased without actual procedures, and it appears to be confused with the Public\nAwareness requirements in accordance with §192.616. RGT’s damage prevention section\nstates that, “This activity is not a covered task under the RGT Operator Qualification Plan”,\nhowever, the tasks associated with damage prevention are covered tasks. Therefore, RGT\nmust modify their written procedure to provide details on how to comply with the damage\nprevention program as required by §192.614(c).\n4. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\nRGT did not establish adequate written corrosion control procedures for inspecting each\npipeline or portion of pipeline that is exposed to the atmosphere in accordance with §192.481.\nTherefore, RGT must modify their procedure to provide details on how to inspect each\npipeline or portion of pipeline that exposed to the atmosphere for evidence of atmospheric\ncorrosion as required by §195.481.\n2\n\n\n\n5. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(1) Receiving, identifying, and classifying notices of events which require\nimmediate response by the operator.\nRGT did not establish adequate written procedure for identifying and classifying major and\nminor leaks of events which require immediate response by the operator. RGT fails to clearly\ndefine what constitutes a major leak versus a minor leak. Therefore, RGT must modify their\nprocedure to provide details on how to identify and classify major and minor leaks of events\nwhich require immediate response by operator as required by §192.615(a)(1).\n6. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(2) Establishing and maintaining adequate means of communication with\nappropriate fire, police, and other public officials.\nRGT did not establish adequate written Emergency Liaison Program for identifying public\nofficials or utility owners, nor does it state how the operator will maintain contacts to ensure\nthat liaisons haven't changed.\n7. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(3) Prompt and effective response to a notice of each type of emergency, including\nthe following:\n(i) Gas detected inside or near a building.\nRGT did not establish an adequate written Emergency Plan to demonstrate RGT will take\nprompt and effective response to a notice of each type of emergency, such as: gas detected\ninside of near a building, or fire/explosion near or directly involving a pipeline facility.\n8. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(4) The availability of personnel, equipment, tools, and materials, as needed at\nthe scene of an emergency.\nRGT’s Procedure #180 includes a list of equipment and materials available from contractors\nfor use during an emergency. However, RGT did not establish adequate written procedure to\ninclude a process ensuring the availability of the equipment and/or tools, as needed at the\n3\n\n\n\nscene of an emergency.\n9. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(5) Actions directed toward protecting people first and then property.\nRGT did not establish adequate written Emergency Plan to demonstrate how RGT will take\nactions directed toward protecting people first and then property.\n10. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(6) Emergency shutdown and pressure reduction in any section of the operator’s\npipeline system necessary to minimize hazards to life or property.\nRGT did not establish an adequate written Emergency Plan to describe the method for\nemergency shutdown or pressure reduction necessary to minimize hazards to life or property.\n11. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(7) Making safe any actual or potential hazard to life or property.\nRGT did not establish an adequate written Emergency Plan to describe the method for making\nsafe any actual or potential hazard to life or property.\n12. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(8) Notifying appropriate fire, police, and other public officials of gas pipeline\nemergencies and coordinating with them both planned responses and actual\nresponses during an emergency.\nRGT did not establish an adequate written Emergency Plan to demonstrate how the operator\nwill maintain appropriate contacts with fire, police, and other public officials of gas pipeline\nemergencies.\n13. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\n4\n\n\n\nprovide for the following:\n(9) Safely restoring any service outage.\nRGT did not establish an adequate written Emergency Plan to describe the method for safely\nrestoring any service outage.\n14. §192.615 Emergency plans.\n(b) Each operator shall:\n(2) Train the appropriate operating personnel to assure that they are\nknowledgeable of the emergency procedures and verify that the training is\neffective.\nRGT did not establish an adequate written emergency training process to adequately describe\na continuing training program to assure that their operating personnel are knowledgeable of\nemergency procedures and verify that the training is effective.\n15. §192.615 Emergency plans.\n(c) Each operator shall establish and maintain liaison with appropriate fire,\npolice, and other public officials to:\n(4) Plan how the operator and officials can engage in mutual assistance to\nminimize hazards to life or property.\nRGT did not establish an adequate written Emergency Plan to demonstrate how RGT will\nplan and engage in mutual assistance with officials in the event of an emergency.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\n5\n\n\n\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\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §\n190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within sixty (60) days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have\nbeen addressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Raton Gas Transmission maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Kim West, Acting Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2018-1003M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#155181)\n6","truncated":false,"body_characters":15775}