# SOUTHERN STAR CENTRAL GAS PIPELINE, INC — Warning Letter

- **operation:** document
- **citation:** CPF 32023034WL
- **title:** SOUTHERN STAR CENTRAL GAS PIPELINE, INC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2023-11-29
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.161(d)(2), 192.317(a).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023034wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023034wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32023034WL
**body:**

Warning Letter involving SOUTHERN STAR CENTRAL GAS PIPELINE, INC. PHMSA's enforcement data identifies the cited regulations as 192.161(d)(2),  192.317(a). The case was opened on 2023-11-29 and is reported as closed as of 2023-11-29. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32023034WL_Warning Letter_11292023_(22-233365).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023034WL/32023034WL_Warning%20Letter_11292023_(22-233365).pdf

32023034WL_Operator Response to Notice_12112023_(22-233365).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023034WL/32023034WL_Operator%20Response%20to%20Notice_12112023_(22-233365).pdf

32023034WL_Warning Letter_11292023_(22-233365)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023034WL/32023034WL_Warning%20Letter_11292023_(22-233365)_text.pdf

32023034WL_Warning Letter_11292023_(22-233365)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: shawn.patterson@southernstar.com;
Craig.Thomas@southernstar.com
November 29, 2023
Shawn Patterson
President and CEO
Southern Star Central Gas Pipeline, Inc.
4700 State Route 56
Owensboro, KY 42301
CPF No. 3-2023-034-WL
Dear Mr. Patterson:
On September 28, 2022, of the on-site investigation, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code (U.S.C.), inspected Southern Star Central Gas Pipeline, Inc.’s (Southern Star) Nash
Compressor Station in Nash, Oklahoma.
As a result of the inspection, it is alleged that Southern Star has committed probable violations of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violation(s) are:
1. § 192.161 Supports and anchors.
(a) . . . .
(d) Each support on an exposed pipeline operated at a stress level of 50 percent or
more of SMYS must comply with the following:
(1) . . . .
(2) The support must be provided by a member that completely encircles the pipe.
Southern Star failed to provide supports that completely encircle the pipeline on an
exposed pipeline. During a field inspection conducted in Nash, Oklahoma on September



28, 2022, PHMSA observed that the above ground piping between the compressor station
suction block valve and the compressor filter did not have supports that fully encircle the
pipe.
Southern Star confirmed, via email on September 28, 2023, that the pipeline supports
would be replaced.
2. § 192.317 Protection from hazards.
(a) The operator must take all practicable steps to protect each transmission line or
main from washouts, floods, unstable soil, landslides, or other hazards that may
cause the pipeline to move or to sustain abnormal loads. In addition, the
operator must take all practicable steps to protect offshore pipelines from
damage by mud slides, water currents, hurricanes, ship anchors, and fishing
operations.
Southern Star failed to take all practicable steps to protect its transmission line from a
hazard that could cause the pipeline to move or sustain an abnormal load. During a field
inspection conducted in Nash, Oklahoma on September 28, 2022, PHMSA observed that
the above ground piping between the compressor station suction block valve and the
compressor filter was supported by foundations that did not extend below the surface
grade. Nash, Oklahoma is located in a temperate climate where the soil may freeze and
cause the soil to expand. This expansion causes and abnormal load on the pipe it
supports.
Southern Star confirmed, via email on September 28, 2023, that the pipeline supports
would be replaced with supports that extend below the surface grade.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to 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. For violation occurring on or after November 2,
2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per
violation per day, with a maximum penalty not to exceed $2,090,022.



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 items identified in this letter. Failure to do so will result in
Southern Star Central Gas Pipeline, Inc. being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
3-2023-034-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,
Gregory Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Craig Thomas (Craig.Thomas@southernstar.com)
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