{"operation":"document","citation":"CPF 320201011W","title":"PANHANDLE EASTERN PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-10-29","effective_on":null,"summary":"CLOSED warning letter citing 192.919(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320201011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320201011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320201011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320201011W","body":"Warning Letter involving PANHANDLE EASTERN PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.919(c). The case was opened on 2020-10-29 and is reported as closed as of 2020-10-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320201011W_Warning Letter_10292020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201011W/320201011W_Warning%20Letter_10292020.pdf\n\n320201011W_Warning Letter_10292020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201011W/320201011W_Warning%20Letter_10292020_text.pdf\n\n320201011W_Warning Letter_10292020_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC EMAIL TO: Matthew.Ramsey@energytransfer.com ,\nGregory.Mcilwain@energytransfer.com , Jim.Wright@energytransfer.com and\nEric.Amundsen@energytransfer.com\nOctober 29, 2020\nMr. Matt Ramsey\nChief Operating Officer\nEnergy Transfer Partners, LP\nPanhandle Eastern Pipeline Co.\n8111 Westerchester Drive\nDallas, TX 75225\nCPF 3-2020-1011W\nDear Mr. Ramsey:\nFrom March 18 through 22, 2019, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected the records for your Panhandle Eastern Pipe Line Company, LP (PEPL) in Houston,\nTexas.\nAs a result of the inspection, it is alleged that you have committed probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1. §192.919 What must be in the baseline assessment plan?\n(c) A schedule for completing the integrity assessment of all covered segments,\nincluding risk factors considered in establishing the assessment schedule;\n\n\n\nPEPL failed to maintain its Baseline Assessment Plan (BAP) in accordance with\n§192.919. Specifically, PEPL’s BAP did not include an updated schedule for completing\nintegrity assessment for newly discovered high consequence areas (HCAs). As of the\ninspection, the 2016 version was the most current BAP, which did not include the\nnew HCA on the Battle Creek 100 Line that was identified in December 2015.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a\nrelated 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. For violations occurring\nprior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per\nday, with a maximum penalty not to exceed $2,000,000 for a related series of violations.\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 identified in this letter. Failure to do so will result in\nPanhandle Eastern Pipeline 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 3-2020-1011W. 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,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc:\nGreg Mcilwain, SVP Hazardous Liquids, Gregory.Mcilwain@energytransfer.com\nJim Wright, Chief Compliance Officer, Jim.Wright@energytransfer.com\nEric Amundsen, Sr. VP Operations, Eric.Amundsen@energytransfer.com\n2","truncated":false,"body_characters":4302}