# COLORADO INTERSTATE GAS CO — Warning Letter

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

Official case documents:

22024016WL_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

22024016WL_Warning Letter_10102024_(23-266073).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024016WL/22024016WL_Warning%20Letter_10102024_(23-266073).pdf

22024016WL_Warning Letter_10102024_(23-266073)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024016WL/22024016WL_Warning%20Letter_10102024_(23-266073)_text.pdf

22024016WL_Warning Letter_10102024_(23-266073)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: Kenneth grubb@kindermorgan.com
Tom Otjen@kindermorgan.com; Jaime Hernandez@kindermorgan.com
October 10, 2024
Kenneth Grubb
Chief Operating Officer
Colorado Interstate Gas Co.
1001 Louisiana St.
Suite 1000
Houston, TX 77002
CPF 2-2024-016-WL
Dear Mr. Grubb:
From June 4, 2023, to July 14, 2023, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected Colorado Interstate Gas (CIG) procedures, records, and facilities in Kansas.
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. § 192.706 Transmission lines: Leakage surveys.
Leakage surveys of a transmission line must be conducted at intervals not exceeding
15 months, but at least once each calendar year. However, in the case of a
transmission line which transports gas in conformity with § 192.625 without an odor
or odorant, leakage surveys using leak detector equipment must be conducted—
(a) In Class 3 locations, at intervals not exceeding 7 1⁄2 months, but at least twice
each calendar year; and



(b) In Class 4 locations, at intervals not exceeding 4 1⁄2 months, but at least four
times each calendar year.
CIG failed to meet 49 C.F.R. § 192.706 because it did not perform leakage surveys of a
transmission line at the required intervals. During the inspection, CIG could not produce
records demonstrating that leak surveys were conducted between 2019 and 2023 for the
line 226 railroad crossing located at Highway 54 and 17th Avenue. Additionally, CIG
personnel confirmed in a subsequent email on August 10, 2023, that “…we did not
complete the Highway and Railroad Leakage Survey Class 1 and 2 on the Cheyenne
Plains line 226 A from Valve 22 to the end of the line for second period in 2022.”
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a
related series of violations. For violation occurring on or after January 6, 2023 and before
December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the
violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation
occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not
exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for
a related series of violations. For violation occurring on or after May 3, 2021 and before March
21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation
persists, up to a maximum of $2,251,334 for a related series of violations. For violation
occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not
exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for
a related series of violations. For violation occurring on or after July 31, 2019 and before
January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the
violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation
occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may
not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.
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(s) identified in this letter. Failure to do so will result in
Colorado Interstate Gas Co. 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 2-2024-016-WL. 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, Southern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
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