CPF 220071013W
CPF 220071013W
220071013w_warning letter_06062007_text.pdf, page 1Official PDFU 5 Department of Transportation Pipeline and Hazardous Materials Safety Administration 233 Peachtree Street Ste 600 Atlanta, GA 30303 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT RE UESTED June 6, 2007 Mr Walter Ferguson Sr Vice President and Chief Operating Officer c/0 Mississippi River Transmission Centerpoiut Energy Gas Transmission 1111 Louisiana, Suite 1120 Houston, TX 77002 CPF 2-2007-1013trV Dear Mr Ferguson Between August 28, 2006 and September 1, 2006, a representative of the Pipehne and Hazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 Umted States Code inspected your Mississippi River Transmission (MRT) facihties and records in the Carlisle Team area m Arkansas As a result of the inspection, it appears that you have committed a probable violation of the Pipehne Safety Regulattons, Title 49, Code of Federal Regulations The ttem inspected and the probable violation is I1192. 605 Procedural manual for operations, maintenance, and emergencies. . . (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must mclude procedures for the followmg, if apphcable, to provide safety durmg maintenance and operations. . . . . . (3) Malang construction records, maps, and operating history evadable to appropriate operatmg personnel.#
220071013w_warning letter_06062007_text.pdf, page 2MRT did not make adequate maps and operating history available to appropriate operating personnel as reqmred of )192 605(b)(3) The following indicates a lack of mamtenance of issued Emergency Plan Books and data - An Emergency Plan Book issued to one of the employees at Carlisle Station was not up to date, the hsted MAOP of Lme A-294 is 1085 psig The correct MAOP is 1, 000 psig - The Line JT-5 MAOP listed on the data sheet provided to the PHMSA inspector is 350 psig The correct MAOP is 1050 psig Under 49 United States Code, $ 60122, you are sublect 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 supportmg 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 tlus letter Failure to do so wdl result in Mississippi River Transmission being sublect to additional enforcement action No reply to this letter is required If you choose to reply, in your correspondence please refer to CPF 2-2007-1013W. Be advised that all material you submit in response to tlus enforcement action is sublect to being made pubhcly avadable If you beheve that any portion of your responsive material quahfies 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 beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted information quahfies for confidential treatment under 5 U S C 552(b) Linda Daugherty Director, Southern Region Pipehne and Hazardous Materials Safety Admnustration Enclosure Response Options for Pipeline Operators m Comphattce Proceedttigs#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.