{"operation":"document","citation":"CPF 320151006W","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":"2015-05-20","effective_on":null,"summary":"CLOSED warning letter citing 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320151006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320151006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320151006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320151006W","body":"Warning Letter involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). PHMSA's enforcement data identifies the cited regulation as 192.709(c). The case was opened on 2015-05-20 and is reported as closed as of 2015-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320151006W_Warning_05202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320151006W/320151006W_Warning_05202015.pdf\n\n320151006W_Warning_05202015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320151006W/320151006W_Warning_05202015_text.pdf\n\n320151006W_Warning_05202015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2015\nMr. Tom Martin\nPresident, Natural Gas Pipelines\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF 3-2015-1006W\nDear Mr. Martin:\nOn August 20-22 and November 5-7, 2013, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to\nChapter 601 of 49 United States Code inspected the implementation of your gas integrity\nmanagement program in Houston, Texas, and records and field operations in Joliet, Illinois,\nrespectively.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and\nthe probable violation is:\n§192.709(c) Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for\nthe periods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts L\nand M of this part must be retained for at least 5 years or until the next patrol,\nsurvey, inspection, or test is completed, whichever is longer.\n\n\n\nDuring the inspection of Natural Gas Pipeline of America, it was determined that set points\n“as found” and “as left” were not documented for certain pressure limiting and regulating\nstations inspections in 2011 and 2012. Specifically, inspection records reviewed revealed\nthat six (6) inspections did not list the “as left” pressure and four (4) inspections did not list\nthe “as found” or “as left” pressures.\nDuring the inspection, it was also determined that partial operation of valves was not\ndocumented in eighty-six (86) valve inspection records that occurred between 2010 and\n2012.\nUnder 49 United States Code, §60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting 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 item(s) identified in this letter. Failure to do so will result in Natural Gas\nPipeline of America being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 3-2015-1006W. 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 treatment\nunder 5 U.S.C. 552(b).\nSincerely,\nAllan C. Beshore\nDirector, Central Region OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Gary Buchler\nVice President Engineering/Operations\nNatural Gas Pipeline Co of America (KMI)\n1001 Louisiana Street\nHouston, Texas 77002","truncated":false,"body_characters":4085}