# EL PASO NATURAL GAS CO — Warning Letter

**Citation:** CPF 420141006W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2014-05-13

CLOSED warning letter citing 192.619(a).

## Document text

Warning Letter involving EL PASO NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.619(a). The case was opened on 2014-05-13 and is reported as closed as of 2014-05-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420141006W_Operator Response to Notice_07172014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Operator%20Response%20to%20Notice_07172014.pdf

420141006W_Warning Letter_05132014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Warning%20Letter_05132014.pdf

420141006W_Warning Letter_05132014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Warning%20Letter_05132014_text.pdf

420141006W_Warning Letter_05132014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 13, 2014
Mr. Gary Buchler
Vice President Engineering/Operations
KMI Pipeline
1001 Louisiana Street
Houston, Texas 77002-5089
CPF 4-2014-1006W
Dear Mr. Buchler:
Between October 16, 2012 and March 31, 2014, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
reviewed Safety Related Condition Report 2012-0088 submitted on October 12, 2012, by El
Paso Natural Gas Company for a safety related incident that occurred in El Paso County, Texas.
As a result of the review, it appears that you have committed a probable violation of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable
violation is:
1. § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.
(a) No person may operate a segment of steel or plastic pipeline at a pressure that
exceeds a maximum allowable operating pressure determined under paragraph (c)
or (d) of this section…
As indicated in your Safety Related Condition Report, El Paso Natural Gas Company
experienced an overpressure condition that met the reporting criteria for a safety related
condition as described in Advisory Bulletin (ADB-2012-11). On four (4) occasions in 2012, the
La Tuna Prison lateral, a portion of your El Paso-Pecos River Unit, was operated at a pressure
that exceeded the maximum allowable operating pressure plus allowable buildup. The
established MAOP for the line, at the time of the event and report was 700 PSIG. The maximum
pressures exceeded 110% of the MAOP of the line on:



• April 25, 2012 787 psig max. 6+ hrs.
• August 11, 2012 771 psig max 5+ hrs.
• October 6, 2012 779 psig max 10+ hrs.
• October 7, 2012 793 psig max 12+ hrs.
The pipeline continued to exceed the MAOP of 700 psig for the complete 24 hour daily record as
furnished to the investigator.
This event is reflected in the Safety Related Condition Report you filed with PHMSA, as well as
provided SCADA documentation related to the event.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to conduct additional enforcement action or penalty assessment proceedings at this
time.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2014-1006W. 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).
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420141006W>
- Source ID: `phmsa-enforcement`
- SHA-256: `de818d87afec79bf088a7268fd568b083cca659cdd24f7bfcdaf67284d8663e0`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-27T13:15:50.137Z
- Document slug: `phmsa-enforcement-420141006w`

### Source metadata

```json
{
  "cpf": "420141006W",
  "operator": "EL PASO NATURAL GAS CO",
  "region": "Southwest",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.619(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
  "attachments": [
    {
      "name": "420141006W_Operator Response to Notice_07172014.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Operator%20Response%20to%20Notice_07172014.pdf",
      "bytes": 70235,
      "category": "party_submission"
    },
    {
      "name": "420141006W_Warning Letter_05132014.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Warning%20Letter_05132014.pdf",
      "bytes": 91301,
      "category": "agency_document"
    },
    {
      "name": "420141006W_Warning Letter_05132014_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Warning%20Letter_05132014_text.pdf",
      "bytes": 14815,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "EL PASO NATURAL GAS CO"
}
```
