{"operation":"document","citation":"CPF 22022005WL","title":"COLORADO INTERSTATE GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-10","effective_on":null,"summary":"CLOSED warning letter citing 192.491(c)(1), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22022005wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22022005wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22022005wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22022005WL","body":"Warning Letter involving COLORADO INTERSTATE GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.491(c)(1),  192.605(a). The case was opened on 2022-02-10 and is reported as closed as of 2022-02-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22022005WL_Warning Letter_02102022_(20-174966).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22022005WL/22022005WL_Warning%20Letter_02102022_(20-174966).pdf\n\n22022005WL_Warning Letter_02102022_(20-174966)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22022005WL/22022005WL_Warning%20Letter_02102022_(20-174966)_text.pdf\n\n22022005WL_Warning Letter_02102022_(20-174966)_text.pdf\n\nWARNING LETTER\nDELIVERY METHOD – VIA FEDERAL EXPRESS\nFebruary 10, 2022\nMr. Kenneth Grubb\nChief Operating Officer\nColorado Interstate Gas CO\nKinder Morgan, Inc.\n1001 Louisiana St., Suite 1000\nHouston, Texas 77002\nCPF 2-2022-005-WL\nDear Mr. Grubb:\nFrom March 16, 2020 to October 12, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected the Colorado Interstate Gas Company\n(CIG) written procedures, records and facilities in Wyoming, Colorado, Utah, Oklahoma,\nKansas, pursuant to Chapter 601 of 49 United States Code (U.S.C.). CIG is a subsidiary of\nKinder Morgan, Inc.\nAs a result of the inspection, it is alleged that CIG committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the\nprobable 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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year. This\nmanual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nCIG failed to meet the regulation because it did not follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities.\nCIG performed a hot tap on its Line 200A, located in Pueblo West, Colorado, on September 3,\n2019. At the time of PHMSA’s inspection, Section 3.5 of CIG Procedure 224, titled “Pre-\nInstallation Checklist,” required completion, review, and approval by the project manager\nusing O&M Form OM200-27 – Tap/Stopple® Data Sheet. At the time of PHMSA’s\ninspection, CIG personnel were unable to furnish any record confirming that the required pre-\ninstallation check was completed, or that that the project manager reviewed and approved it\nper the referenced CIG procedure.\n2. § 192.491 Corrosion control records.\n(a) …\n(c) Each operator shall maintain a record of each test, survey, or inspection required\nby this subpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that a corrosive condition does not exist. These records must be retained for\nat least 5 years with the following exceptions:\n(1) Operators must retain records related to §192.465 (a) and (e) and 192.475(b) for\nas long as the pipeline remains in service.\nCIG failed to meet the regulation because it did not maintain a record of each test, survey, or\ninspection required by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. Specifically, CIG did\nnot maintain a record of the inspection of the internal surface of its pipeline for evidence of\ncorrosion during a pipe repair/removal project, as required by § 192.475(b).\nCIG performed a hot tap on its Line 200A, located in Pueblo West, Colorado, on\nSeptember 3, 2019. During review of records related to the referenced project, PHMSA\npersonnel requested a copy of CIG’s Pipe Examination Report (PER) No. 193706, the final\nreport referenced in the overall project documentation and the official record of CIG’s\ninspection of the internal surface of the exposed pipe. CIG provided PHMSA with\nPER No. 163434 with a “create date” of October 14, 2019, and no entry for the “finalized date.”\nFurthermore, this report was generally incomplete as 5 of the 11 pages were blank. CIG\ninformed PHMSA that the apparent discrepancy in form numbers was a result of the original\nreport, PER No. 163434, having exceeded the maximum timeframe for input/finalization. CIG\npersonnel created a new report, PER No. 193706, intended to retroactively capture the\nreferenced hot tap, but it reflected “create” and “finalization” dates of October 1, 2021, and\nOctober 8, 2021, respectively – over two years after the pipe examination and subsequent hot\ntap project.1 It should be noted that upon review of additional supporting project documentation,\nit was confirmed that the retroactive data was in fact based on CIG personnel’s field notes taken\n1 Kinder Morgan’s documentation for these regulations is Form OM200-02, Pipeline Examination Report for pipeline\nsystems. Form OM200-02, is intended to document the coating and pipe condition on routine pipeline exposures, during\nconstruction and maintenance activities, integrity assessments and any other activity in which any internal surface of pipe is\nexposed or if the pipe is excavated and the coating or bare pipe is exposed. If any corrosion is identified that has not been\npreviously evaluated and remediated, a corrosion technician or similarly qualified person would evaluate the pipe and\ncomplete Form OM200-02. Pipeline replacement or remediation is also documented on Form OM200-02.\n\n\n\nat the time of the actual hot tap – CIG personnel collected the required information, but failed\nto enter it in a timely manner, leading to the expiration of the original PER (No. 163434).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, CIG is subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise CIG to correct the items identified in this letter. Failure to do so will result in\nCIG being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2022-005-WL. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8267}