{"operation":"document","citation":"CPF 220121003W","title":"SOUTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-01-23","effective_on":null,"summary":"CLOSED warning letter citing 192.709(c), 192.735(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220121003W","body":"Warning Letter involving SOUTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.709(c),  192.735(a). The case was opened on 2012-01-23 and is reported as closed as of 2012-01-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220121003W_Warning letter_01232012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121003W/220121003W_Warning%20letter_01232012.pdf\n\n220121003W_warning letter_01232012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121003W/220121003W_warning%20letter_01232012_text.pdf\n\n220121003W_warning letter_01232012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 23, 2012\nMr. William G. Cope\nVice President – Eastern Operations\nSouthern Natural Gas Company\n569 Brookwood Village, Suite 501\nBirmingham, AL 35209\nCPF 2-2012-1003W\nDear Mr. Cope:\nFrom August 29 to October 27, 2011, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected the Southern Natural Gas Company (SNG) natural gas pipeline system throughout\nsouthern Georgia and northern Florida. SNG is a subsidiary of El Paso.\nAs a result of the inspection, it appears that SNG has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n.... (c) A record of each patrol, survey, inspection, and test required by Subparts L\nand M of this part must be retained for at least 5 years or until the next patrol,\nsurvey, inspection, or test is completed, whichever is longer.\nSouthern Natural Gas (SNG) did not maintain adequate records to document the CY 2010\nannual inspection of each transmission line valve that might be required during an\nemergency as required by Subpart M, §192.745(a).\nDue to an error in SNG’s work-planning software, the records documenting the CY 2010\nannual valve inspections were not properly annotated for 17 valves along portions of\nLine 3 and along the entirety of Lines 12, 13, 22, and 32 (laterals off of Line 3).\nSNG’s work plan is generated based on a standard task description. In 2010, the required\ntask description was altered for the referenced pipelines, which led the right-of-way\ntechnician to perform maintenance on valves but that maintenance was not documented as\n\n\n\na DOT-compliant annual valve inspection. Therefore, SNG’s records do not adequately\ndocument the annual inspection of the 17 above referenced valves.\n2. §192.735 Compressor stations: Storage of combustible materials.\n(a) Flammable or combustible materials in quantities beyond those required for\neveryday use, or other than those normally used in compressor buildings, must be\nstored a safe distance from the compressor building.\nSNG stored flammable or combustible materials in quantities beyond those required for\neveryday use, or other than those normally used in compressor buildings, inside a\ncompressor building.\nDrums containing lubrication oil for the compressor turbine were observed inside the\nHoly Trinity Compressor Station. Several of the drums had labels indicating that their\ncontents were unused lubricating oil, while several more were labeled “empty” or “non-\nhazardous waste.” The operator’s personnel confirmed that the volume present in the\ncompressor station at the time of the PHMSA inspection exceeded the quantity required\nfor everyday use.\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\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in SNG being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-1003W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n2","truncated":false,"body_characters":4932}