{"operation":"document","citation":"CPF 220151002","title":"TEXAS GAS TRANSMISSION, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-04-24","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.167(a)(2), 192.199(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220151002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220151002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220151002","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220151002","body":"Notice of Probable Violation involving TEXAS GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.167(a)(2),  192.199(e). The case was opened on 2015-04-24 and is reported as closed as of 2015-05-27. Proposed civil penalty: $72,300. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220151002_NOPV PCP PCO_04242015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151002/220151002_NOPV%20PCP%20PCO_04242015.pdf\n\n220151002_NOPV PCP PCO_04242015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151002/220151002_NOPV%20PCP%20PCO_04242015_text.pdf\n\n220151002_Operator Response to Notice_05222015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151002/220151002_Operator%20Response%20to%20Notice_05222015.pdf\n\n220151002_Region Withdrawal of Notice_05272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151002/220151002_Region%20Withdrawal%20of%20Notice_05272015.pdf\n\n220151002_Region Withdrawal of Notice_05272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151002/220151002_Region%20Withdrawal%20of%20Notice_05272015_text.pdf\n\n220151002_Region Withdrawal of Notice_05272015_text.pdf\n\nWITHDRAWAL of NOTICE LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 27, 2015\nMr. Richard Keyser\nSr. Vice President Operations\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF 2-2015-1002\nDear Mr. Keyser:\nOn April 24, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA),\nSouthern Region, Office of Pipeline Safety (OPS) issued Texas Gas Transmission, LLC\n(TGT) a Notice of Probable Violation (NOPV) for probable violations of the federal pipeline\nsafety regulations in 49 CFR Part 192.\nThe NOPV pertained to TGT’s Fayetteville Lateral in Mississippi and Arkansas. It cited TGT\nunder §192.167 for failing to properly configure the blowdown piping for the emergency\nshutdown system (ESD) at its Bald Knob compressor station and §192.199 for failing to\nproperly configure blowdown discharge stacks for its meter stations along the pipeline.\nOn May 22, 2015, TGT responded to the NOPV in writing. With regards to the probable\nviolation of §192.167, TGT explained that during the inspection its personnel did not properly\nexplain to the OPS inspector that the blowdown piping stacks cited were to vent air, not gas,\nduring an ESD activation. While TGT did not contest the probable violation of §192.199, the\nSouthern Region reviewed the issue and determined that the regulation cited did not pertain\nthe blowdown discharge stack at the tap valve cited in the probable violation.\nAccordingly, the PHMSA Southern Region withdraws the NOPV and this case is now closed.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220151002_NOPV PCP PCO_04242015_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 24, 2015\nMr. Richard Keyser\nSr. Vice President Operations\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF 2-2015-1002\nDear Mr. Keyser:\nOn March 9-12, 2015, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the\nTexas Gas Transmission, LLC (TGT) Fayetteville Lateral in Mississippi and Arkansas,\npursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that TGT has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are as follows:\n1. §192.167 Compressor stations: Emergency shutdown.\n(a) Except for unattended field compressor stations of 1,000 horsepower (746\nkilowatts) or less, each compressor station must have an emergency shutdown system\nthat meets the following:\n. . . (2) It must discharge gas from the blowdown piping at a location where the gas\nwill not create a hazard.1\n1 Note that §192.167 was last amended on July 13, 1998\n\n\n\n2. TGT did not configure the emergency shutdown system (ESD) at its Bald Knob\ncompressor station so as to discharge gas from the blowdown piping at a location where\nthe gas will not create a hazard.\nDuring the PHMSA inspection, the inspector observed and took pictures of ESD trip\nstation vents near the compressor building and other locations at the compressor station.\nThe vents were oriented vertically and would discharge natural gas at an elevation of\napproximately 3 to 5 feet above the ground in the event of an ESD activation. The\ndischarge of natural gas at these locations in this configuration could create a hazard to\nindividuals.\n§192.199 Requirements for design of pressure relief and limiting devices. Except for\nrupture discs, each pressure relief or pressure limiting device must:\n… (e) Have discharge stacks, vents, or outlet ports designed to prevent accumulation\nof water, ice, or snow, located where gas can be discharged into the atmosphere\nwithout undue hazard;2\nTGT’s blowdown discharge stacks for its meter stations were not located so as to\ndischarge gas into the atmosphere without undue hazard.\nDuring the PHMSA inspection, the inspector observed and took pictures of blowdown\ndischarge stacks at the Midge #2 and Southeast Rainbow #1 meter stations. The\nblowdown discharge stacks at the tap valve were oriented vertically to discharge gas at an\nelevation of approximately 3 to 5 feet above the ground. Vented natural gas could create\nan undue hazard to individuals near the discharge stack in the event the discharge stacks\nwere activated.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, TGT 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. The Compliance Officer has reviewed\nthe circumstances and supporting documentation involved in the above probable violations\nand has recommended that TGT be preliminarily assessed a civil penalty of $72,300 as\nfollows:\nItem number Penalty\n1 $ 36,000\n2 $ 36,300\n2 Note that §192.199 was last amended on November 17, 1970\n2\n\n\n\nProposed Compliance Order\nWith respect to items 1 and 2, pursuant to 49 United States Code § 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to Texas\nGas Transmission, LLC. Please refer to the Proposed Compliance Order, which is enclosed\nand made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Compliance Proceedings. Please refer to this document and note the response\noptions. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not\nrespond within 30 days of receipt of this Notice, this constitutes a waiver of your right to\ncontest the allegations in this Notice and authorizes the Associate Administrator for Pipeline\nSafety to find facts as alleged in this Notice without further notice to you and to issue a Final\nOrder.\nIn your correspondence on this matter, please refer to CPF 2-2015-1002 and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n3\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Texas Gas Transmission, LLC (TGT) a\nCompliance Order incorporating the following remedial requirements to ensure the\ncompliance of TGT with the pipeline safety regulations:\n1. 2. In regard to Item Number 1 of the Notice pertaining to the improperly configured\nemergency shutdown system (ESD) blowdown piping vents at the Bald Knob compressor\nstation, TGT must complete the following:\na. No later than 30 days after issuance of the Compliance Order,\ni. Conduct a survey of all compressor stations on the Fayetteville Lateral and\nGreenville Lateral pipelines to identify all improperly configured ESD blowdown\npiping vents where the discharge of gas from the vents could create a hazard.\nii. Provide written documentation to the Director, Office of Pipeline Safety, PHMSA\nSouthern confirming that all the compressor stations on the Fayetteville Lateral\nand Greenville Lateral pipelines were surveyed and that all improperly configured\nESD blowdown piping vents were identified.\nb. No later than 45 days after issuance of the Compliance Order, provide to the Director,\nOffice of Pipeline Safety, PHMSA Southern Region a written schedule for modifying\nall the improperly configured ESD blowdown piping vents at all the compressor\nstations on the Fayetteville Lateral and Greenville Lateral pipelines.\nc. No later than 60 days after issuance of the Compliance Order,\ni. Modify all the improperly configured ESD blowdown piping vents at all the\ncompressor stations on the Fayetteville Lateral and Greenville Lateral pipelines so\nthat any discharged gas will not create a hazard if an ESD is activated.\nii. Provide documentation to the Director, Office of Pipeline Safety, PHMSA\nSouthern Region demonstrating that TGT has completed the modifications\nrequired by Item 1.c.i.\nIn regard to Item 2 of the Notice pertaining to the improperly configured blowdown stacks\non the Fayetteville Lateral line, TGT must complete the following:\na. No later than 30 days after issuance of the Compliance Order,\ni. Conduct a survey of its pipeline facilities along the Fayetteville Lateral and\nGreenville Lateral pipelines to identify all improperly configured discharge stacks,\nvents, or outlet ports where vented natural gas could create an undue hazard in the\nevent the discharge stacks, vents, or outlet ports were activated.\nii. Provide written documentation to the Director, Office of Pipeline Safety, PHMSA\nSouthern confirming that all pipeline facilities were surveyed and that all\ndischarge stacks, vents, or outlet ports were identified.\nb. No later than 45 days after issuance of the Compliance Order provide to the Director,\nOffice of Pipeline Safety, PHMSA Southern Region a written schedule for modifying4\n\n\n\n3. c. all improperly configured discharge stacks, vents, or outlet ports on the Fayetteville\nLateral and Greenville Lateral pipelines.\nNo later than 60 days after issuance of the Compliance Order,\ni. Modify all improperly configured discharge stacks, vents, or outlet ports on the\nFayetteville Lateral and Greenville Lateral pipelines so that any discharged gas\nwill not create a hazard if any gas is discharged.\nii. Provide documentation to the Director, Office of Pipeline Safety, PHMSA\nSouthern Region demonstrating that TGT has completed the modifications\nrequired by Item 2.c.i.\nIt is requested (not mandated) that TGT maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the total\nto Wayne T. Lemoi, Director, Southern Region – Office of Pipeline Safety, Pipeline and\nHazardous Materials Safety Administration. It is requested that these costs be reported in\ntwo categories: 1) total cost associated with preparation/revision of plans, procedures,\nstudies and analyses, and 2) total cost associated with replacements, additions and other\nchanges to pipeline infrastructure.\n5","truncated":false,"body_characters":12180}