# EL PASO NATURAL GAS CO — Warning Letter

**Citation:** CPF 520095008W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2009-02-19

CLOSED warning letter citing 192.625(f)(1).

## Document text

Warning Letter involving EL PASO NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.625(f)(1). The case was opened on 2009-02-19 and is reported as closed as of 2009-02-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095008W_warning letter_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095008W/520095008W_warning%20letter_02192009.pdf

520095008W_warning letter_02192009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095008W/520095008W_warning%20letter_02192009_text.pdf

520095008W_warning letter_02192009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 19, 2009
Mr. Daniel B. Martin
Senior Vice President of Operations
El Paso Corporation
1001 Louisiana St.
Houston, TX 77002
CPF 5-2009-5008W
Dear Mr. Martin:
From September 29, 2008 to October 3, 2008, representatives of the Arizona Corporation
Commission acting as an agent for the Pipeline and Hazardous Materials Safety Administration
(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected records pertaining to the
operation and maintenance of your Arizona natural gas pipelines in Phoenix, Arizona.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
1. §192.625 Odorization of gas
(e) Equipment for odorization must introduce the odorant without wide variations
in the level of odorant.
(f) To assure the proper concentration of odorant in accordance with this section,
each operator must conduct periodic sampling of combustible gases using an
instrument capable of determining the percentage of gas in air at which the odor
becomes readily detectable. Operators of master meter systems may comply with
this requirement by–



(1) Receiving written verification from their gas source that the gas has the proper
concentration of odorant.
The percentage of gas in air results for odorant tests conducted on pipeline 2025 on
9-16-2008 and pipeline 2026 on 1-14-2008 were improperly calculated.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. 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. We advise you to correct the item(s) identified in this
letter. Failure to do so will result in El Paso Corporation being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2009-5008W. 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,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Haddow (#120760)
Arizona Corporation Commission-Mr. Robert Miller
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520095008W>
- Source ID: `phmsa-enforcement`
- SHA-256: `a7e7119d193bd3323b7c5ab2fc3fdffd30a1057f1bfc5b9714a9fcec7a77dcfb`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T12:51:13.615Z
- Document slug: `phmsa-enforcement-520095008w`

### Source metadata

```json
{
  "cpf": "520095008W",
  "operator": "EL PASO NATURAL GAS CO",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.625(f)(1)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520095008W_warning letter_02192009.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520095008W/520095008W_warning%20letter_02192009.pdf",
      "bytes": 144456,
      "category": "agency_document"
    },
    {
      "name": "520095008W_warning letter_02192009_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520095008W/520095008W_warning%20letter_02192009_text.pdf",
      "bytes": 13069,
      "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"
}
```