{"operation":"document","citation":"CPF 22023008WL","title":"SOUTHERN NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-07-28","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.709, 192.745(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22023008wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22023008wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22023008wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22023008WL","body":"Warning Letter involving SOUTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.709,  192.745(a). The case was opened on 2023-07-28 and is reported as closed as of 2023-07-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22023008WL_Warning Letter_07282023_(20-181668).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22023008WL/22023008WL_Warning%20Letter_07282023_(20-181668).pdf\n\n22023008WL_Warning Letter_07282023_(20-181668)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22023008WL/22023008WL_Warning%20Letter_07282023_(20-181668)_text.pdf\n\n22023008WL_Warning Letter_07282023_(20-181668)_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 28, 2023\nTed Meinhold\nVice President, Operations\nSouthern Natural Gas Co.\n1001 Louisiana Street\nSuite 1000\nHouston, Texas 77002\nCPF 2-2023-008-WL\nDear Mr. Meinhold:\nFrom May 17 to May 21, 2021, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nyour written procedures, records, and facilities in northern Louisiana.\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 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.\nThis manual must be prepared before operations of a pipeline system commence.\n\n\n\n(b) Appropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nSNG failed to meet the regulation because it did not follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities. Specifically, SNG\nfailed to follow its manual of written procedures which required it to document each gas and\nfire detection system test which are required at least 4 times each year, not to exceed 4.5\nmonths per Kinder Morgan Procedure O&M 550. SNG uses Kinder Morgan (KM)\nprocedures to comply with 49 CFR Part 192.\nKM Procedure O&M 550, titled \"Testing Gas and Fire Detection Systems,\" dated January 1,\n2017, prescribes actions to ensure each gas detection and alarm system are maintained to\nfunction properly, as required by 192.736(c). O&M 550, Section 5 “Documentation”,\nrequires personnel to “Record each calibration test date and results in the daily log or the\nI&M system.” O&M 550 references KM procedure O&M 1700, titled “Inspection and\nMaintenance”, dated November 1, 2019, which provides an outline to schedule inspections\nand maintenance for company facilities. O&M 1700 references KM procedure IM1700, titled\n“Inspection and Maintenance Procedures (O&M 1700 Matrix)” which lists various inspection\nand maintenance intervals for various components in company facilities. IM1700 contains\nI&M Procedure #I-0551.00, last revised 03/12/1999, which requires the frequency to test and\ncalibrate each gas and fire detection system to be “at least 4 times each year, not to exceed\n4.5 months”.\nRecords reviewed during the inspection demonstrate that SNG documented the test and\ncalibration of each gas and fire detection system only 3 times per year during the following\nyears:\n• Bear Creek Storage Compressor Station: 2017, 2018, 2019, 2020\n• Logansport Compressor Station: 2018, 2019, 2020\n• Bienville Compressor Station: 2017, 2019, 2020\nFurthermore, records reviewed during inspection demonstrate that SNG did not document the\ntest and calibration of each gas and fire detection system within the required 4.5-month\ninterval:\n• Bear Creek Storage Compressor Station:\no 2018, 02/23/2018 to 07/31/2018 (5 months 8 days)\n• Logansport Compressor Station:\no 2017, 06/26/2017 to 11/13/2017 (4 months 18 days)\no 2018, 01/24/2018 to 10/01/2018 (8 months 7 days)\no 2020, 01/30/2020 to 09/21/2020 (7 months 22 days)\n\n\n\n2. § 192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(a)…\n(c) A record of each patrol, survey, inspection, and test required by subparts L and M\nof this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\nSNG failed to meet the regulation because it did not maintain a record of each patrol, survey,\ninspection, and test required by subparts L and M of this part. Specifically, SNG failed to\nmaintain records for inspection and testing each remote-control shutdown device at intervals\nnot exceeding 15 months, but at least once each calendar year, as required by 192.731(c).\nRecords reviewed during the inspection demonstrated the ESD system at the Bear Creek\nStorage Compressor Station had been tested on 04/22/2017 and 10/18/2018, an interval of 17\nmonths 26 days. SNG did not have a record to demonstrate that they had not exceeded the\n15-month requirement.\n3. § 192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency must be\ninspected and partially operated at intervals not exceeding 15 months, but at least once\neach calendar year.\nSNG failed to meet the regulation because it did not inspect and partially operate each\ntransmission line valve that might be required during any emergency at intervals not\nexceeding 15 months, but at least once each calendar year. Specifically, SNG records\ndemonstrate 54 instances where valves were not at least partially operated during the 2019\ncalendar year.\nRecords reviewed for Bear Creek Storage and SNG Unit 614, called “Valve Inspection\nService Reports”, specified certain valves had not been operated during the 2019 calendar\nyear by writing “Did not operate” or “DNO” in the “comments” column and did not indicate\neither full or partial operation in the “Operated” column. The previous inspections where the\nvalves were at least partially operated occurred between 08/27/2018 and 09/06/2018. The\nnext inspections where the valves were at least partially operated occurred between\n11/03/2020 and 11/18/2020. The interval between operated valve inspections ranged from 26\nmonths 5 days to 26 months 12 days.\nSNG explained that some of the valves in Bear Creek storage that were not operated were in\nLock-out-tag-out due to recent incidents, and therefore could not be operated. Bear Creek\nstorage accounts for 24 of the 54 valves not operated in 2019.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a\nrelated series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty 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 you to correct the items identified in this letter. Failure to do so will result in\nSouthern Natural Gas Company 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 2-2023-008-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\nthe redacted 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":9665}