{"operation":"document","citation":"CPF 220151003W","title":"TEXAS GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-11","effective_on":null,"summary":"CLOSED warning letter citing 192.479(b), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220151003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220151003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220151003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220151003W","body":"Warning Letter involving TEXAS GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.479(b),  192.605(a). The case was opened on 2015-06-11 and is reported as closed as of 2015-06-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220151003W_warning letter_06112015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151003W/220151003W_warning%20letter_06112015.pdf\n\n220151003W_warning letter_06112015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151003W/220151003W_warning%20letter_06112015_text.pdf\n\n220151003W_warning letter_06112015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 11, 2015\nMr. Richard Keyser\nSr. Vice President Operations\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF 2-2015-1003W\nDear Mr. Keyser:\nFrom April 20 to May 14, 2015, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), Southern Region\ninspected certain Texas Gas Transmission, LLC (TGT) pipelines in Kentucky and reviewed\nrecords at its West Greenville, Midland, Bowling Green, and Hanson, Kentucky offices,\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. §192.479 Atmospheric corrosion control: General.\n… (b) Coating material must be suitable for the prevention of atmospheric\ncorrosion.\nTGT did not use coating material suitable for the prevention of atmospheric corrosion on\nthe piping at certain soil-to-air interface pipes at the Midland and West Greenville storage\nfields.\nOPS inspectors observed faulty coating, exposed metal, and rust stains on valve #167\n(well #16809 side valve area, line MIGF 16809WT, 4-inch line to Well 16809), and at the\nWest Greenville well #16076 area (WGGF 16076WT, 4-inch Line to Well 16076).\n\n\n\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nTGT did not follow its manual of written procedures for conducting operations and\nmaintenance activities and for emergency response as follows.\n1. TGT’s written procedure in its operations & maintenance (O&M) manual Section\n8020 - External Corrosion Control conveyed that a report would be made to the\nCorrosion System Leader and Area Manager upon determining that a casing was\nelectrically shorted to a pipe so arrangements could be made to clear the short, if\nfeasible.\n2. 3. Notwithstanding the above, TGT did not provide records or any other documentation\nto show that upon determining on September 1, 2010, that the casing on Line W-1 at\nan abandoned railroad crossing was shorted to the pipeline, it determined the\nfeasibility or non-feasibility of clearing the short. Moreover, it did not clear the short.\nInstead, TGT monitored the crossing in a class 1 location area with gas leak detector\nequipment on a semi-annual frequency.\nTGT’s written procedure in its O&M manual Section 8030 – Internal Corrosion\nControl conveyed that a pipeline inspection form (i.e. a Facility Inspection and Repair\nReport or its predecessor a Pipeline Inspection and Repair Report) would be\ncompleted when certain maintenance activities were undertaken.\nNotwithstanding the above, TGT did not provide records or any other documentation\nto show that it completed either a Facility Inspection and Repair Report or its\npredecessor a Pipeline Inspection and Repair Report when it removed pipe at the\nBarkley-Lovell 8-inch facility and at the Lavell-Williams 4-inch line in 2011 or on\ntwo occasions where internal surfaces were exposed when opening filters/separators.\nTGT did not follow its maintenance procedures because it did not correctly document\nthe inspected pipeline when investigating for potential 3rd party damage. Inspection\nreport TXG-0092-7884-13-1 dated 05/14/2013 incorrectly indicated SLG-13-1 was\nthe pipeline inspected. TGT conveyed during the inspection that SLG-12-1 was the\nactual line inspected. Subsequent to the inspection TGT corrected and filed the report.\nUnder 49 United States Code, § 60122, you are 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\n2\n\n\n\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 items identified in this letter. Failure to do so will result in Texas Gas Transmission, LLC\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2015-1003W. 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\n3","truncated":false,"body_characters":6356}