{"operation":"document","citation":"CPF 220101008W","title":"FLORIDA GAS TRANSMISSION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-08-17","effective_on":null,"summary":"CLOSED warning letter citing 192.905(c), 192.911(k), 192.917(a)(1), 192.933(b), 192.933(d)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220101008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220101008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220101008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220101008W","body":"Warning Letter involving FLORIDA GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192.905(c),  192.911(k),  192.917(a)(1),  192.933(b),  192.933(d)(1). The case was opened on 2010-08-17 and is reported as closed as of 2010-08-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220101008W_warning letter_08172010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220101008W/220101008W_warning%20letter_08172010.pdf\n\n220101008W_warning letter_08172010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220101008W/220101008W_warning%20letter_08172010_text.pdf\n\n220101008W_warning letter_08172010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 17, 2010\nJeryl Mohn\nSr. Vice President, Operations and Engineering\nPanhandle Energy\n5444 Westheimer Road\nHouston, Texas 77056-5306\nCPF 2-2010-1008W\nDear Mr. Mohn:\nOn April 12-16 and April 26-30, 2010, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) inspected Panhandle Energy’s Gas Integrity Management\nProgram (IMP) in Houston, Texas. On June 16, 2010, a PHMSA representative inspected\npipeline facilities belonging to Panhandle Energy's subsidiary Trunkline Gas Company, LLC\n(Trunkline) in Victoria County, Texas. Both inspections were conducted pursuant to Chapter\n601 of 49 United States Code.\nAs a result of the inspections, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.905 How does an operator identify a high consequence area?\n(c) Newly identified areas. When an operator has information that the area\naround a pipeline segment not previously identified as a high consequence area\n(HCA) could satisfy any of the definitions in § 192.903, the operator must complete\nthe evaluation using method (1) or (2). If the segment is determined to meet the\ndefinition as a high consequence area, it must be incorporated into the operator's\nbaseline assessment plan as a high consequence area within one year from the date\nthe area is identified.\nPanhandle Energy's subsidiary Trunkline failed to incorporate a new high consequence area\n(HCA) into its baseline assessment program within one year from the date the area was\nidentified. A Best Western hotel was opened in 2006 along Trunkline's Beeville Discharge\n\n\n\nPipeline in Victoria County, Texas. This hotel required Trunkline to evaluate the area using\neither method (1) or (2) [see §192.903] to determine if the area met the definition of an HCA.\nTrunkline's HCA map (T-0410-Beeville-100 Line-19g-3762, dated 6/15/2010) shows that the\nnew HCA was added in April 2009; more than two years past the required time limit.\n2. §192.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(a)Threat identification. An operator must identify and evaluate all potential\nthreats to each covered pipeline segment. Potential threats that an operator must\nconsider include, but are not limited to, the threats listed in ASME/ANSI B31.8S\n(incorporated by reference, see §192.7), section 2, which are grouped under the\nfollowing four categories:\n(1) Time dependent threats such as internal corrosion, external corrosion, and\nstress corrosion cracking;\n(2) Static or resident threats, such as fabrication or construction defects;\n(3) Time independent threats such as third party damage and outside force\ndamage; and\n(4) Human error.\nPanhandle Energy’s threat susceptibility algorithms failed to appropriately determine the\nsusceptibility of its pipeline systems to manufacturing and construction related threats.\nPipeline segments with manufacturing-related defects, weather-related damage and outside\nforce damage were not assigned threat values in the risk analysis and were shown as no risk to\npipeline integrity. This was confirmed at the time of the inspection by reviewing the Panhandle\nEnergy Spreadsheet – SUG: Threat Susceptibility for all Active HCAs.\n3. §192.933 What actions must be taken to address integrity issues?\n(b) Discovery of condition. Discovery of a condition occurs when an operator has\nadequate information about a condition to determine that the condition presents a\npotential threat to the integrity of the pipeline. A condition that presents a\npotential threat includes, but is not limited to, those conditions that require\nremediation or monitoring listed under paragraphs (d)(1) through (d)(3) of this\nsection. An operator must promptly, but no later than 180 days after conducting\nan integrity assessment, obtain sufficient information about a condition to make\nthat determination, unless the operator demonstrates that the 180-day period is\nimpracticable.\nPanhandle Energy's IMP failed to properly define \"discovery of a condition\" [i.e. when an\noperator has obtained adequate information to identify a potential threat to the integrity of the\npipeline] and failed to establish a timeframe and process for the prompt consideration of\npotential immediate repair conditions. Instead, Panhandle Energy's IMP defines discovery of a\ncondition as the acceptance of vendor in-line inspection (ILI) data without consideration of\nestablishing a timeframe and process for the prompt consideration immediate repair conditions.\n4. §192.933 What actions must be taken to address integrity issues?\n(d) Special requirements for scheduling remediation.-\n2\n\n\n\n(1) Immediate repair conditions. An operator's evaluation and remediation\nschedule must follow ASME/ANSI B31.8S, section 7 in providing for immediate\nrepair conditions. To maintain safety, an operator must temporarily reduce\noperating pressure in accordance with paragraph (a) of this section or shut down\nthe pipeline until the operator completes the repair of these conditions. An\noperator must treat the following conditions as immediate repair conditions:\n(i) A calculation of the remaining strength of the pipe shows a predicted failure\npressure less than or equal to 1.1 times the maximum allowable operating pressure\nat the location of the anomaly. Suitable remaining strength calculation methods\ninclude, ASME/ANSI B31G; RSTRENG; or an alternative equivalent method of\nremaining strength calculation. These documents are incorporated by reference\nand available at the addresses listed in appendix A to part 192.\n(ii) A dent that has any indication of metal loss, cracking or a stress riser.\n(iii) An indication or anomaly that in the judgment of the person designated by\nthe operator to evaluate the assessment results requires immediate action.\nPanhandle Energy's IMP did not require the examination of immediate repair conditions (in\naddition to pressure reductions) within 5 days of discovery as required by ASME B31.8S-2004,\nSection 7.2.1 (incorporated by reference). Panhandle Energy's IMP did not include or require a\njustification as to why examination cannot be completed within the 5 days nor does it explain\nhow equivalent safety is assured. Refer to Panhandle Energy's Position Paper E.1.a dated\n3/24/2010, Program Requirements for Discovery, Evaluation and Remediation Scheduling.\n5. §192.911 What are the elements of an integrity management program?\n(k) A management of change process as outlined in ASME/ANSI B31.8S, section\n11.\nPanhandle Energy’s IMP Management of Change (MOC) process failed to provide for the\nreview and analysis of the implications of pipeline or system changes to the IMP prior to\nimplementation. This allowed Panhandle Energy's subsidiary Florida Gas Transmission\nCompany (FGT) to install Supervisory Control and Data Acquisition (SCDA) system\ninstrumentation on its pipeline system without an MOC analysis of IMP implications.\nAdditionally, FGT replaced an 18-inch pipeline and a 24-inch pipeline in Valve Section 21-7\nwith a 36-inch diameter pipeline without an MOC review and analysis to determine the\nimplications on the integrity of the pipeline systems, if any.\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 violations. 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 identified in\nthis letter. Failure to do so will result in Panhandle Energy and Trunkline Gas Company being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2010-1008W. Be advised that all material you submit in response to this enforcement3\n\n\n\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,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n4","truncated":false,"body_characters":9400}