TENNESSEE GAS PIPELINE COMPANY — Warning Letter

party submissionOfficial PDF220101005W_operator response_04122010.pdf#

220101005W_Warning Letter_03112010_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 11, 2010 Mr. William Cope Vice President, Eastern Operations Tennessee Gas Pipeline 569 Brookwood Village Room 766 Birmingham, AL 35209 CPF 2-2010-1005W Dear Mr. Cope: On September 14-18, 21-24, and November 2-6, 2009, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Tennessee Gas Pipeline (TGP) procedures and records in Catlettsburg, Clay City, Greenup and Morehead, Kentucky and Batesville and Greenville, Mississippi; and TGP’s pipeline facilities in Arkansas, Kentucky, Mississippi, and Ohio. As a result of the inspection, it appears that TGP has committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation is: §192.479 Atmospheric corrosion control; General. (a) Each operator must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section. At TGP’s Compressor Station 63 in Batesville, Mississippi, the compressor unit suction and discharge piping in the basements of Compressor Buildings A and B had numerous areas where the paint had disbanded from the pipe exposing the pipe. Several of the areas with disbanded paint have extensive surface rust.#

220101005W_Warning Letter_03112010_text.pdf, page 2Under 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 identified in this letter. Failure to do so will result in TGP 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 2-2010-1005W. 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, Linda Daugherty Director, Southern Region Pipeline and Hazardous Materials Safety Administration 2#