{"operation":"document","citation":"CPF 220141003W","title":"TENNESSEE GAS PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-09-10","effective_on":null,"summary":"CLOSED warning letter citing 191.22(c)(1)(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220141003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220141003W","body":"Warning Letter involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 191.22(c)(1)(i). The case was opened on 2014-09-10 and is reported as closed as of 2014-09-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220141003W_warning letter_09102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141003W/220141003W_warning%20letter_09102014.pdf\n\n220141003W_warning letter_09102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220141003W/220141003W_warning%20letter_09102014_text.pdf\n\n220141003W_warning letter_09102014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 10, 2014\nMs. Kimberly Watson\nPresident, Gas Pipeline\nTennessee Gas Pipeline Company\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF 2-2014-1003W\nDear Ms.Watson:\nOn September 5, 2014, Tennessee Gas Pipeline Company (TGP) submitted an “Operator\nRegistry Notification” (Form PHMSA F 1000.2) to the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) electronically through the National Registry of Pipeline and\nLNG Operators at http://opsweb.phmsa.dot.gov. The notification advised PHMSA of TGP’s\nintent to modify TGP 200 Station piping for reverse flow conditions. TGP 200 Station is\nlocated in Greenup, Kentucky.\nAs a result of this late submittal, it appears that TGP has committed a probable violation of\nthe Pipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The probable\nviolation is as follows:\n1. § 191.22 National Registry of Pipeline and LNG Operators.\n… (c) Changes. Each operator must notify PHMSA electronically through the\nNational Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of\ncertain events.\n(1) An operator must notify PHMSA of any of the following events not later than 60\ndays before the event occurs:\n(i) Construction or any planned rehabilitation, replacement, modification, upgrade,\nuprate, or update of a facility, other than a section of line pipe, that costs $10 million\nor more. If 60 day notice is not feasible because of an emergency, an operator must\nnotify PHMSA as soon as practicable;…\nTGP did not notify PHMSA of a planned rehabilitation, replacement, modification,\nupgrade, uprate, or update of a facility, other than a section of line pipe, that costs $10\nmillion or more not later than 60 days before the event occurs.\n\n\n\nTGP notified PHMSA electronically on September 5, 2014, through the National Registry\nof Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of its intent to modify the\nTGP 200 Station at a cost of $12 million. The notification stated that the field work\nactivities started on August 1, 2014. This notification was required not later than 60 days\nbefore the event was to occur; i.e. not later than June 1, 2014. TGP’s failure to properly\nnotify PHMSA not later than 60 days prior to August 1, 2014, deprived PHMSA of its\nability to properly plan for the inspection of this construction related activity.\nUnder 49 United States Code, § 60122, TGP is subject to a civil penalty not to exceed\n$ 200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a 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 item identified in this letter. Failure to do so will result in the TGP 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 2-2014-1003W. 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":4559}