{"operation":"document","citation":"CPF 22024016WL","title":"COLORADO INTERSTATE GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-10-10","effective_on":null,"summary":"CLOSED warning letter citing 192.706.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024016wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024016wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024016wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22024016WL","body":"Warning Letter involving COLORADO INTERSTATE GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.706. The case was opened on 2024-10-10 and is reported as closed as of 2024-10-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22024016WL_Operator Response to Notice _11052024_(23-266073).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024016WL/22024016WL_Operator%20Response%20to%20Notice%20_11052024_(23-266073).pdf\n\n22024016WL_Warning Letter_10102024_(23-266073).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024016WL/22024016WL_Warning%20Letter_10102024_(23-266073).pdf\n\n22024016WL_Warning Letter_10102024_(23-266073)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024016WL/22024016WL_Warning%20Letter_10102024_(23-266073)_text.pdf\n\n22024016WL_Warning Letter_10102024_(23-266073)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: Kenneth grubb@kindermorgan.com\nTom Otjen@kindermorgan.com; Jaime Hernandez@kindermorgan.com\nOctober 10, 2024\nKenneth Grubb\nChief Operating Officer\nColorado Interstate Gas Co.\n1001 Louisiana St.\nSuite 1000\nHouston, TX 77002\nCPF 2-2024-016-WL\nDear Mr. Grubb:\nFrom June 4, 2023, to July 14, 2023, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Colorado Interstate Gas (CIG) procedures, records, and facilities in Kansas.\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. § 192.706 Transmission lines: Leakage surveys.\nLeakage surveys of a transmission line must be conducted at intervals not exceeding\n15 months, but at least once each calendar year. However, in the case of a\ntransmission line which transports gas in conformity with § 192.625 without an odor\nor odorant, leakage surveys using leak detector equipment must be conducted—\n(a) In Class 3 locations, at intervals not exceeding 7 1⁄2 months, but at least twice\neach calendar year; and\n\n\n\n(b) In Class 4 locations, at intervals not exceeding 4 1⁄2 months, but at least four\ntimes each calendar year.\nCIG failed to meet 49 C.F.R. § 192.706 because it did not perform leakage surveys of a\ntransmission line at the required intervals. During the inspection, CIG could not produce\nrecords demonstrating that leak surveys were conducted between 2019 and 2023 for the\nline 226 railroad crossing located at Highway 54 and 17th Avenue. Additionally, CIG\npersonnel confirmed in a subsequent email on August 10, 2023, that “…we did not\ncomplete the Highway and Railroad Leakage Survey Class 1 and 2 on the Cheyenne\nPlains line 226 A from Valve 22 to the end of the line for second period in 2022.”\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a\nrelated series of violations. For violation occurring on or after January 6, 2023 and before\nDecember 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the\nviolation persists, up to a maximum of $2,576,627 for a related series of violations. For violation\noccurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not\nexceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for\na related series of violations. For violation occurring on or after May 3, 2021 and before March\n21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation\noccurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not\nexceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for\na related series of violations. For violation occurring on or after July 31, 2019 and before\nJanuary 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the\nviolation persists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\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 item(s) identified in this letter. Failure to do so will result in\nColorado Interstate Gas Co. 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 2-2024-016-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).\n\n\n\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":5626}