{"operation":"document","citation":"CPF 220171003W","title":"SOUTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-07-27","effective_on":null,"summary":"CLOSED warning letter citing 192.161(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220171003W","body":"Warning Letter involving SOUTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.161(c). The case was opened on 2017-07-27 and is reported as closed as of 2017-07-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220171003W_Operator Response to Notice_03212018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171003W/220171003W_Operator%20Response%20to%20Notice_03212018.pdf\n\n220171003W_Warning Letter_07272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171003W/220171003W_Warning%20Letter_07272017.pdf\n\n220171003W_Warning Letter_07272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171003W/220171003W_Warning%20Letter_07272017_text.pdf\n\n220171003W_Warning Letter_07272017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 27, 2017\nMr. Kenneth Grubb\nChief Operating Officer\nKinder Morgan Natural Gas Pipelines\nSouthern Natural Gas Company\n1001 Louisiana Street\nHouston, TX 77002\nCPF 2-2017-1003W\nDear Mr. Grubb:\nFrom February 13 to February 17 and from February 27 to March 2, 2017, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety,\ninspected Southern Natural Gas Company (SNG) facilities in Louisiana, pursuant to Chapter 601\nof 49 United States Code.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1. §192.161 Support and anchors.\n…(c) Each support or anchor on an exposed pipeline must be made of durable,\nnoncombustible material and must be designed and installed as follows:\nSNG failed to meet the regulation because it did not ensure that each support of an exposed\npipline was made of noncombustible material.\n\n\n\nDuring an on-site inspection of SNG’s facility at Air Products Tap (M.P 68.202 on the\n20-inch Main Pass-Franklinton), PHMSA inspectors observed supports of the exposed\npipeline made, in part, of wood. Please note that, absent a definition in §192.3 of the Code\nof Federal Regulations or other incorporated references, Webster’s defines “support” as\n“something that serves as a foundation, prop, brace, or stay.” While the support components\nin immediate contact with the exposed pipe is made of steel, the entire load-bearing platform\nconveying the load to a solid foundation is wood, a combustible material.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 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 the\nitem identified in this letter. Failure to do so will result in SNG being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2017-1003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n2","truncated":false,"body_characters":3844}