[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-351871-105":53,"doc-detail-351871-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","response-to-cpf-3-2021-1002-notice-of-probable-violation-updated-april-2-2021","Response to CPF 3-2021-1002, Notice of Probable Violation - Updated April 2, 2021","","Formal correspondence from Northern Natural Gas responding to a Notice of Probable Violation issued March 30, 2021, updated April 2, 2021, addressing multiple regulatory requirements under 49 CFR Part 192. The letter explains failures and remediation actions involving the operator’s procedural manual for operations, maintenance, emergencies, internal communication plan testing, controller alarm management records, and permanent field repair methods for transmission line pipe anomalies. It describes specific engineering standard references, revised procedures, training, attachments, and corrective repair at the Dent 30 site.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/response-to-cpf-3-2021-1002-notice-of-probable-violation-updated-april-2-2021/351871/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/response-to-cpf-3-2021-1002-notice-of-probable-violation-updated-april-2-2021/351871.png","ImageObject",442,249,{"name":88,"@type":89},"Aurelia","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-08","2026-09-22",true,{"@type":98,"interactionType":99,"userInteractionCount":9},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"What is the purpose of the letter and which notice is it responding to?","Question",{"text":108,"@type":109},"The letter provides Northern Natural Gas’ response to the items in the Notice of Probable Violation identified as CPF 3-2021-1002, dated March 30, 2021, with an update dated April 2, 2021.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"How does Northern Natural Gas address the cited failure related to the procedural manual for operations, maintenance, and emergencies (§ 192.605)?",{"text":113,"@type":109},"Northern states it has been replacing or readjusting flange bolts systemwide to meet the referenced engineering standard, and that all specified locations listed in the notice have been repaired. A separate response on this issue will be submitted in relation to the compliance order.",{"name":115,"@type":106,"acceptedAnswer":116},"What corrective actions are described for internal communication plan testing and controller alarm-related compliance records (§ 192.631)?",{"text":117,"@type":109},"Northern reports revising procedures and providing training. It amends Operating Procedure 50.204 by using a new internal communication plan template with a checklist for incident response and internal communication, and it revises Operating Procedure 50.400 to collect and analyze alarm-related data and document compliance through monthly review and annual reporting.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},351871,1791489270,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":76,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":76,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":139,"read_time":9},1099514068365,"https://ap-avatar.wpscdn.com/avatar/10000253d8d9f28188e?_k=1776742907772140068","Northern Natural Gas Company P.O. Box 3330  \nOmaha, NE 68103-0330 402 398-7200  \nMarch 30, 2021  \nUpdated April 2, 2021  \nGregory A. Ochs  \nDirector, Central Region  \nPipeline and Hazardous Materials Safety Administration  \n901 Locust Street, Suite 480 Kansas City, MO 64106  \nRe: Response to CPF 3-2021-1002, Notice of Probable Violation  \nDear Mr. Ochs:  \nIn accordance with the Notice of Probable Violation, Proposed Civil Penalty and Proposed Compliance Order, dated March 2, 2021, in the above referenced case, this letter contains Northern Natural Gas’ response to the items referenced.  \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 written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted.  \nNorthern Natural failed to follow a written procedure for conducting operations and maintenance activities and for emergency response. Specifically, Northern Natural failed to follow its procedure, Engineering Standard 7570 “Joining of Pipe & Piping Components Other Than by Welding”(Revision 11 8/20/2019). Sections [5.6.1.1](5.6.1.1) and [5.6.1.2](5.6.1.2) of the procedure contains the requirements for bolt and nut engagement for various flange connections at the company’s pipeline facilities.  \nNorthern’s Response: Northern has been replacing or readjusting flange bolts systemwide to meet its engineering standard referenced. Some flange bolts can be remediated while in-service while others must be removed from service or bypassed. Of those specific locations listed in the Notice of Probable Violation, all have been repaired.  \nA separate response on this issue will be submitted in response to the Compliance Order.  \nCPF 3-2021-1002, Notice of Probable Violation March 30, 2021  \nPage 2 of 3  \n2. § 192.631 Control room management.  \n(a) . . . .  \n(c) Provide adequate information. Each operator must provide its controllers with the information, tools, processes, and procedures necessary for the controllers to carry out the roles and responsibilities the operator has defined by performing each of the following:  \n(3) Test and verify an internal communication plan to provide adequate means for manual operation of the pipeline safely, at least once each calendar year, but at intervals not to exceed 15 months;  \nNorthern Natural failed to test and verify their internal communication plan to provide adequate means for manual operation of the pipeline safely, at least once each calendar year, but at intervals not to exceed 15 months, in 2017.  \nNorthern’s response: Northern revised its procedures in September 2019 and provided training to address this issue.  \nOperating procedure 50.204, Internal Communication Plan Testing for Manual Operation of Pipeline, has been amended with additional structure related to the annual testing requirements. The process previously was documented on a mock emergency template but moving forward an Internal Communication Plan template that will include a checklist for following incident response and internal communication processes will be used for this procedure. A copy is attached for your review.  \n3. § 192.631 Control room management.  \n(j) Compliance and deviations. An operator must maintain for review during inspection:  \n(1) Records that demonstrate compliance with the requirements of this section;  \nNorthern Natural failed to have records that demonstrated compliance to monitor the content and volume of general activity being directed t","cbCaia7Ns8mFtgBZ","https://ap.wps.com/l/cbCaia7Ns8mFtgBZ","pdf",33726,"English","# Response Items\n## Procedural manual requirements (§ 192.605)\n## Control room management - internal communication testing (§ 192.631)\n## Control room management - compliance records for alarms (§ 192.631)\n## Transmission line field repair of pipe imperfections (§ 192.713)","[{\"question\":\"What is the purpose of the letter and which notice is it responding to?\",\"answer\":\"The letter provides Northern Natural Gas’ response to the items in the Notice of Probable Violation identified as CPF 3-2021-1002, dated March 30, 2021, with an update dated April 2, 2021.\"},{\"question\":\"How does Northern Natural Gas address the cited failure related to the procedural manual for operations, maintenance, and emergencies (§ 192.605)?\",\"answer\":\"Northern states it has been replacing or readjusting flange bolts systemwide to meet the referenced engineering standard, and that all specified locations listed in the notice have been repaired. A separate response on this issue will be submitted in relation to the compliance order.\"},{\"question\":\"What corrective actions are described for internal communication plan testing and controller alarm-related compliance records (§ 192.631)?\",\"answer\":\"Northern reports revising procedures and providing training. It amends Operating Procedure 50.204 by using a new internal communication plan template with a checklist for incident response and internal communication, and it revises Operating Procedure 50.400 to collect and analyze alarm-related data and document compliance through monthly review and annual reporting.\"}]","Response to CPF 3-2021-1002, Notice of Probable Violation - Updated April 2, 2021 | PDF",1790096364]