# SOUTHERN NATURAL GAS CO — Warning Letter

- **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:** Not available
- **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.

Official case documents:

220171003W_Operator Response to Notice_03212018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171003W/220171003W_Operator%20Response%20to%20Notice_03212018.pdf

220171003W_Warning Letter_07272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171003W/220171003W_Warning%20Letter_07272017.pdf

220171003W_Warning Letter_07272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171003W/220171003W_Warning%20Letter_07272017_text.pdf

220171003W_Warning Letter_07272017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 27, 2017
Mr. Kenneth Grubb
Chief Operating Officer
Kinder Morgan Natural Gas Pipelines
Southern Natural Gas Company
1001 Louisiana Street
Houston, TX 77002
CPF 2-2017-1003W
Dear Mr. Grubb:
From February 13 to February 17 and from February 27 to March 2, 2017, representatives of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety,
inspected Southern Natural Gas Company (SNG) facilities in Louisiana, pursuant to Chapter 601
of 49 United States Code.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected
and the probable violation is:
1. §192.161 Support and anchors.
…(c) Each support or anchor on an exposed pipeline must be made of durable,
noncombustible material and must be designed and installed as follows:
SNG failed to meet the regulation because it did not ensure that each support of an exposed
pipline was made of noncombustible material.



During an on-site inspection of SNG’s facility at Air Products Tap (M.P 68.202 on the
20-inch Main Pass-Franklinton), PHMSA inspectors observed supports of the exposed
pipeline made, in part, of wood. Please note that, absent a definition in §192.3 of the Code
of Federal Regulations or other incorporated references, Webster’s defines “support” as
“something that serves as a foundation, prop, brace, or stay.” While the support components
in immediate contact with the exposed pipe is made of steel, the entire load-bearing platform
conveying the load to a solid foundation is wood, a combustible material.
As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil
penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of
$2,090,022 for a related series of violations. We have reviewed the circumstances and
supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to correct the
item identified in this letter. Failure to do so will result in SNG being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 2-2017-1003W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region
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