{"operation":"document","citation":"CPF 120091002W","title":"TENNESSEE GAS PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-03-25","effective_on":null,"summary":"CLOSED warning letter citing 192.603(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120091002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120091002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120091002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120091002W","body":"Warning Letter involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.603(b). The case was opened on 2009-03-25 and is reported as closed as of 2009-03-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120091002W Warning Letter_03252009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091002W/120091002W%20Warning%20Letter_03252009_text.pdf\n\n120091002W_Warning Letter_03252009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091002W/120091002W_Warning%20Letter_03252009.pdf\n\n120091002w_warning letter_03252009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091002W/120091002w_warning%20letter_03252009_text.pdf\n\n120091002W Warning Letter_03252009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 25, 2009\nMr. Dan Martin\nExecutive Vice President\nEl Paso Pipeline Group\n1001 Louisiana\nHouston, Texas 77252-2511\nCPF 1-2009-1002W\nDear Mr. Martin:\nBetween June 9 and June 20, 2008, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nAgawam and Hopkinton Divisions of the Tennessee Gas Pipeline Company (Tennessee Gas) in\nMassachusetts, Rhode Island and New Hampshire.\nAs a result of the inspections, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. § 192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under § 192.605\nDuring the inspection of its overprotection devices, Tennessee presented annual test records in\norder to demonstrate compliance with § 192.739(a)(3) and § 192.201(a)(2)(i). The records for\nthe overpressure protection which include relief valves, regulators and pressure switches did not\n\n\n\ninclude the actual test pressures at which the overpressure protection relieved or entered control\nmode. The operator’s Maximo test record listed the set point for each overprotection device, but\nthere was no actual pressure listed in the record to confirm the result was within the tolerances\nspecified by the procedures. Apparently, quantitative test data would be entered into the test\nrecord only if the device failed to test satisfactorily. The actual pressure should be a part of the\nofficial record.\nDocuments reviewed during the inspection consisted of:\n1. OPP Device Inspection checklist (Pressure control valves/regulators)\n2. OPP Device Inspection checklist (Relief valves)\n3. Guidance document for OPP Device Inspection Process\n4. DOT Reg/RV Inspection Document Report (CY 2007 Regulator Tests at Main Line\nValve 354-1, Holyoke and Westfield)\n5. DOT Reg/RV Inspection Document Report (CY 2007 Pressure switches at Station 261)\n6. DOT Reg/RV Inspection Document Report (CY 2007 Relief Valve at Main Line Valve\n261)\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in Tennessee Gas being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2009-1002W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron E. Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n2\n\n120091002w_warning letter_03252009_text.pdf\n\no\nU S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n409 3rd Street, SW, Suite 300\nWashington, DC 20024\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nMarch 25, 2009\nMr. Dan Martin\nExecutive Vice President\nEl Paso Pipeline Group\n1001 Louisiana\nHouston, Texas 77252-2511\nCPF I-2009-1002W\nDear Mr. Martm:\nBetween June 9 and June 20, 2008, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nAgawam and Hopkinton Divisions of the Tennessee Gas Pipeline Company (Tennessee Gas) in\nMassachusetts, Rhode Island and New Hampshire.\nAs a result of the mspections, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. g 192. 603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under g 192. 605\nDuring the inspection of its overprotection devices, Tennessee presented annual test records in\norder to demonstrate compliance with $ 192. 739(a)(3) and $ 192. 201(a)(2)(i). The records for\nthe overpressure protection which include relief valves, regulators and pressure switches did not\n\n\n\n1. g 192. 603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under g 192. 605\nDuring the inspection of its overprotection devices, Tennessee presented annual test records in\norder to demonstrate compliance with $ 192. 739(a)(3) and $ 192. 201(a)(2)(i). The records for\nthe overpressure protection which include relief valves, regulators and pressure switches did not\ninclude the actual test pressures at which the overpressure protection relieved or entered control\nmode. The operator's Maximo test record listed the set point for each overprotection device, but\nthere was no actual pressure listed in the record to confirm the result was within the tolerances\nspecified by the procedures. Apparently, quantitative test data would be entered into the test\nrecord only if the device failed to test satisfactorily. The actual pressure should be a part of the\nofficial record.\nDocuments reviewed during the inspection consisted of:\n1. OPP Device Inspection checklist (Pressure control valves/regulators)\n2. OPP Device Inspection checklist (Relief valves)\n3. Guidance document for OPP Device Inspection Process\n4. DOT Reg/RV Inspection Document Report (CY 2007 Regulator Tests at Main Line\nValve 354-1, Holyoke and Westfield)\n5. DOT Reg/RV Inspection Document Report (CY 2007 Pressure switches at Station 261)\n6. DOT Reg/RV Inspection Document Report (CY 2007 Relief Valve at Main Line Valve\n261)\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in Tennessee Gas being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2009-1002W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\n\n\n\nSincerely,\nB n E. Coy, PE\nD ctor, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8475}