{"operation":"document","citation":"CPF 320101007W","title":"NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-12-21","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.707(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320101007W","body":"Warning Letter involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.707(c). The case was opened on 2010-12-21 and is reported as closed as of 2010-12-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320101007W_Warning Letter_12212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101007W/320101007W_Warning%20Letter_12212010.pdf\n\n320101007W_Warning Letter_12212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101007W/320101007W_Warning%20Letter_12212010_text.pdf\n\n320101007W_Warning Letter_12212010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 21, 2010\nMr. Dwayne Burton, V.P. Pipeline Operations\nNatural Gas Pipeline Company of America\n500 Dallas, Suite 1000\nHouston, Texas 77002\nCPF 3-2010-1007W\nDear Mr. Burton:\nOn June 23, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour Horizon (NGPL) Unit in Chicago, Illinois.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. 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\nmanual of written procedures for conducting operations and maintenance\nactivities and for emergency response.\nNatural Gas Pipeline Company of America (NGPL) did not follow its manual of\nwritten procedures when conducting checks of odorant levels in their pipeline.\n\n\n\nNGPL uses a Heath Consultants Odorator to check the odorant levels at several\nplaces along their pipeline. During the field inspection, a technician demonstrated\nthe use of the Odorator. The demonstration and odor levels detected were\nadequate, but the instrument was last calibrated in 2007. NGPL procedures (O&M\n1860) indicate that they will follow the manufacturer’s recommendations for\nequipment maintenance, and the Heath Consultants manual specifies annual factory\ncalibration.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a\nmanual of written procedures for conducting operations and maintenance\nactivities and for emergency response.\nNatural Gas Pipeline Company of America (NGPL) did not follow its manual of\nwritten procedures when they constructed a new above ground delivery station.\nA newly constructed delivery station (139th Street Station) was enclosed in fencing\nbut had no signs of any kind. NGPL procedures for above ground facilities (O&M\n205) call for a minimum of a sign containing the company name, logo, and\nemergency numbers.\n3. §192.707 Line markers for mains and transmission lines.\n(c) Pipelines above ground. Line markers must be placed and maintained\nalong each section of a main and transmission line that is located above\nground in an area accessible to the public.\nNGPL did not place line markers at all above ground facilities in areas accessible to\nthe public. One above ground facility – the Horizon tap off the Volo system – was\nnot fenced and had no markers of any kind.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any 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\ncorrect the items identified in this letter. Failure to do so will result in Natural Gas\nPipeline Company of America being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 3-2010-1007W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":4728}