{"operation":"document","citation":"CPF 220111005","title":"TENNESSEE GAS PIPELINE COMPANY — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-03-31","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220111005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220111005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220111005","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220111005","body":"Notice of Probable Violation involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2011-03-31 and is reported as closed as of 2011-06-24. Proposed civil penalty: $25,000. Assessed civil penalty: $25,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220111005_Final Order_06242011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111005/220111005_Final%20Order_06242011.pdf\n\n220111005_Final Order_06242011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111005/220111005_Final%20Order_06242011_text.pdf\n\n220111005_NOPV_PCP_03312011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111005/220111005_NOPV_PCP_03312011.pdf\n\n220111005_NOPV_PCP_03312011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111005/220111005_NOPV_PCP_03312011_text.pdf\n\n220111005_Operator response_04212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111005/220111005_Operator%20response_04212011.pdf\n\n220111005_Final Order_06242011_text.pdf\n\nJUN 24 2011\nMr. William G. Cope\nVice President, Eastern Operations\nTennessee Gas Pipeline\n569 Brookwood Village, Suite 501\nBirmingham, Alabama 35209\nRe: CPF No. 2-2011-1005\nDear Mr. Cope:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and assesses a civil penalty of $25,000. This is to acknowledge receipt of payment of\nthe full penalty amount, by wire transfer, dated April 21, 2011. This enforcement action is now\nclosed. Service of the Final Order by certified mail is deemed effective upon the date of mailing,\nor as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, Pipeline Safety\nMr. Wayne T. Lemoi, Director, Southern Region, PHMSA\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 1160 0001 0075 9541]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nTennessee Gas Pipeline, ) CPF No. 2-2011-1005\nEl Paso Corporation )\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn October 4 through December 10, 2010, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted on-site safety inspections of the natural gas transmission pipeline facilities and\nrecords of Tennessee Gas Pipeline (TGP or Respondent) in Alabama, Mississippi, Tennessee,\nand Kentucky. TGP is an interstate natural gas transmission system that runs from Louisiana,\nthe Gulf of Mexico and south Texas to the northeastern corridor, including New York City and\nBoston. TGP is one of several wholly owned transmission systems owned by El Paso\nCorporation and consists of 14,100 miles of pipeline.\nAs a result of the inspections, the Director, Southern Region, OPS (Director), issued to\nRespondent, by letter dated March 31, 2011, a Notice of Probable Violation and Proposed Civil\nPenalty (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that TGP\nviolated 49 C.F.R. § 192.605(a) and proposed assessing a civil penalty of $25,000 for the alleged\nviolation.\nTGP responded to the Notice by letter dated April 21, 2011 (Response). The company did not\ncontest the allegation of violation and paid the proposed civil penalty of $25,000, as provided in\n49 C.F.R. § 190.227. Payment of the penalty serves to close the case with prejudice to\nRespondent.\nFINDING OF VIOLATION\nIn its Response, TGP did not contest the allegation in the Notice that it violated 49 C.F.R. Part\n192, as follows:\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a), which states:\n\n\n\n2\n§ 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations\nand maintenance activities and for emergency response. For\ntransmission lines, the manual must also include procedures for\nhandling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but\nat least once each calendar year. This manual must be prepared\nbefore operations of a pipeline system commence. Appropriate\nparts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its\nwritten procedures for conducting operations and maintenance activities and emergency\nresponse. Specifically, the Notice alleged that TGP did not use a locking device, disable, or\nproperly secure a main line block valve, in violation of its operations and maintenance\nprocedures, as outlined in Section 305 Valve Maintenance.\n1 During a field inspection of TGP\nMain Line Valve (MLV) 535-2, located in Jasper County, Mississippi, PHMSA’s inspector\nwas neither secured nor disabled, in violation of Respondent’s Operating and Maintenance\nProcedures. Given that the valve hand-wheel operates the valve, failure to properly secure the\nhand-wheel compromised the integrity of the pipeline. Pipeline damage or product release could\nhave ensued.\nobserved the main line block valve hand-wheel resting against the valve body.2 The hand-wheel\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its\nmanual of written procedures for conducting operations and maintenance activities and for\nemergency response, which requires that main line valves be secured or disabled in order to\nprevent unauthorized operation.\nIn summary, having reviewed the record and considered the assessment criteria, I assess\nRespondent a total civil penalty of $25,000, which has already been paid by Respondent.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n1 TGP O&M Manual (Valve Maintenance), Section 305.1 states “Transmission valves that might be required in an\nemergency . . . may include: (a) Mainline block valves and blowoffs . . . whenever a valve is operated . . . the\nlocking device shall [also] be returned to the valve and secured. Section 305.4(e) Security states “valves covered in\nthis section of the O&M Manual shall: have a locking device to prevent unauthorized operation or be disabled (i.e.\nhave the valves in a condition that would provide security equivalent to, or better than, a lock on the valve or valve\noperator), or be within a secured area.”\n2 See Exhibit A, Pipeline Safety Violation Report (Mar. 30, 2011) (Violation Report), at 8.","truncated":false,"body_characters":7181}