{"operation":"document","citation":"CPF 220171006W","title":"TENNESSEE GAS PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-10-05","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220171006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220171006W","body":"Warning Letter involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.709(c). The case was opened on 2017-10-05 and is reported as closed as of 2017-10-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220171006W_Warning Letter_10052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171006W/220171006W_Warning%20Letter_10052017.pdf\n\n220171006W_Warning Letter_10052017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220171006W/220171006W_Warning%20Letter_10052017_text.pdf\n\n220171006W_Warning Letter_10052017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 5, 2017\nMr. Kenneth W. Grubb\nChief Operating Officer\nKinder Morgan Natural Gas Pipelines\nTennessee Gas Pipeline Company\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF 2-2017-1006W\nDear Mr. Grubb:\nFrom June 19 to June 23, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, inspected Tennessee Gas Pipeline\nCompany (TGP) facilities in Mississippi, pursuant to Chapter 601 of 49 United States Code\n(U.S.C.).\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §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.\n\n\n\nTGP failed to meet the regulation because it did not follow its procedure to document\ninspection and partial operation of each transmission line valve that might be required\nduring any emergency, as required by §192.745(a).\nTGP Procedure O&M 301, titled “Inspecting and Servicing Emergency Valves,” dated\nApril 1, 2016, prescribes actions required to ensure compliance with §192.745(a). This\nprocedure requires completion of TGP Form OM300-03, titled “Valve Inspection Service\nReport,” revision date April 1, 2016, to demonstrate conformance with the procedure.\nForm OM300-03 includes a field (field named “Operation”) to document either a\n“partial” or “full” valve operation. This “Operation” field was left blank on records\ndocumenting valve inspections in 2015 and 2016 for Valves 54-2ABD1 D/S BO and\n54-2ABD U/S BO at TGP’s Station 54. Furthermore, 2016 inspections for the above-\nreferenced valves were not documented using TGP Form OM300-03, as required by\nTGP’s procedure – the inspections were documented using an outdated form with a\ndifferent format and content fields. The inspections were conducted in October 2016,\nafter the revision dates of both the referenced TGP procedure and Form OM300-03.\nTGP personnel produced work orders indicating that the inspection had been completed,\nbut the operation of these valves was not documented in any of the work orders made\navailable for review. TGP personnel stated that both valves were partially operated each\nyear as a part of the valve inspection, but did not produce any supporting evidence.\n2. §192.709 Transmission lines: Recordkeeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n…(c) A record of each patrol, survey, inspection, and test required by subparts L\nand M of this part must be retained for at least 5 years or until the next patrol,\nsurvey, inspection, or test is completed, whichever is longer.\nTGP documented annual valve inspections for valves that do not exist. During records\nreview, the PHMSA Inspector noted documentation of the the following valve\ninspections for valves on its Line 100-1 at Station 54 in Greenville, MS:\n• Valve 54-1A – Inspection Documented in 2013, 2015, and 2016\n• Valve 54-1AL – Inspected Documented in 2013 and 2016\nThese valves do not appear on station schematics and were not observed during the field\ninspection of Station 54. Section 11, Step A of TGP’s Greenville Procedure, titled\n“Annual Valve Inspection and Maintenance,” requires Operator personnel to “Verify the\nDistrict valve identification numbers and re-tag if necessary.” This procedure was last\nrevised on August 2, 2016, approximately 3 months prior to the 2016 valve inspection.\n2\n\n\n\nAdditionally, TGP did not consistently document the pipeline’s odorization status on the\nleakage survey report. Records reviewed during the inspection indicated that Line 100-1\nPatrol Segment 53-1+11.36 to 53-1+11.45 was odorized in 2014, as documented on TGP\nForm OM200-10. Records documenting the 2015 leakage survey for the same patrol\nsegment did not indicate whether the line was odorized or unodorized. TGP stated that\nthe line was not odorized during this period. It should be noted that this line is not\nrequired to be odorized per §192.625.\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\nitems identified in this letter. Failure to do so will result in TGP 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 2-2017-1006W. 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\n3","truncated":false,"body_characters":6715}