{"operation":"document","citation":"CPF 220081008W","title":"TRUNKLINE GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-10-16","effective_on":null,"summary":"CLOSED warning letter citing 192.13(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220081008W","body":"Warning Letter involving TRUNKLINE GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.13(c). The case was opened on 2008-10-16 and is reported as closed as of 2008-10-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220081008W_warning letter_10162008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081008W/220081008W_warning%20letter_10162008.pdf\n\n220081008w_warning letter_10162008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081008W/220081008w_warning%20letter_10162008_text.pdf\n\n220081008w_warning letter_10162008_text.pdf\n\nU. S. Department\nof rransponation\nPipeline and\nHazardous Materials Safety\nAdministration\n233 Peachtree Street Ste. 600\nAtlanta, GA 30303\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nOctober 16, 2008\nJerry Mohn\nSr, Vice President\nTrunkline Gas Company\n5444 Westheimer Road\nHouston, TX 77056-5306\nCPF 2-2008-1008W\nDear Mr. Mohn:\nOn August 4 thru 8 and 11 thru 14, 2008, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your pipeline facilities in Mississippi, Tennessee, and Kentucky areas and records at\nShaw, Independence (Mississippi) and Dyersburg (Tennessee) district offices.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation is:\ntt 192, 13 General\n(c) Each operator shall maintain, modify as appropriate, and follow the plans, and\nprocedures, and programs that it is required to establish under this part.\nTrunkline Gas Company (TGC) did not conduct a gas leakage detection equipment\nsurvey at its mechanically shorted casing locations at class locations I & 11 on a\nsemi-annual basis as per their procedure no. 1. 22, Table 4.\n1. During the field check on 8/13/08 in the KY area, the casings at the following\nlocations are found mechanically shorted:\n(a) Test Point 124+49, Hwy. 60, line 300, valve section 101: P/S: 1083mv C/S: 1081\nmV (P/S:1094/1091 C/S at 5 feet distance).\n(b) Test Point 250+71, Stone Corner Road, line 300, valve section 101: P/S: 1223 mV,\nC/S: 1211 mV.\n\n\n\n(c) Test Point 298+29, Abandoned Road, line 300, valve section 100: P/S: 1223 mV,\nC/S: 1184 mV.\n2. In Dyersburg district, the test point 146+62, Hwy. 77, AM-3, line 300, showed a\nsuspected shorted casing in 2006 & 2007. No electrical test was performed to verify if\nit v:as an actual shorted casing.\n3. During the field check on 8/I 3/08, the casings at the following locations in Dyersburg\ndistrict were found to be suspected shorted casings.\n(a) Test Point: 40+88, Hwy. 21 E, line 200: P/S: 1688 mV. C/S: 1680 mV.\n(b) Test Point; 442+62, Polk Road (Troy), line 200, P/S: 1304 mV, C/S: 1303 mV.\nThese casings v ere tested on 4/19/99 and found mechanically shorted in 2005 thru\n2008. An accelerated leakage survey with gas leakage detection equipment is required\non a semi-annually basis, not to exceed 71/2 months (SOP 1. 22, effective I/I/07). The\nsemi-annually gas leakage detection survey by instrument is not being carried out from\nthe date the casings are first found mechanically shorted.\nUnder 49 United States Code, ) 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violation. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Failure to do so will result in Trunkline Gas Company being subject to additional\nenforcement action.\nKo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2008-1008W. 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,\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4634}