{"operation":"document","citation":"CPF 420111011M","title":"SOUTHERN NATURAL GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-10-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(2), 192.911, 192.911(b), 192.911(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111011m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111011m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420111011m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420111011M","body":"Notice of Amendment involving SOUTHERN NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(2),  192.911,  192.911(b),  192.911(e). The case was opened on 2011-10-20 and is reported as closed as of 2013-12-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420111011M_Closure_12182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111011M/420111011M_Closure_12182013.pdf\n\n420111011M_Closure_12182013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111011M/420111011M_Closure_12182013_text.pdf\n\n420111011M_NOA_ 10202011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111011M/420111011M_NOA_%2010202011_text.pdf\n\n420111011M_NOA_10202011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111011M/420111011M_NOA_10202011.pdf\n\n420111011M_Order Directing Amendment_09202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111011M/420111011M_Order%20Directing%20Amendment_09202013.pdf\n\n420111011M_Order Directing Amendment_09202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420111011M/420111011M_Order%20Directing%20Amendment_09202013_text.pdf\n\n420111011M_Order Directing Amendment_09202013_text.pdf\n\nSEPTEMBER 20, 2013\nMs. Kimberly S. Watson\nPresident\nSouthern Natural Gas Company, L.L.C.\n1001 Louisiana St., Suite 1000\nHouston, TX 77002\nRe: CPF No. 4-2011-1011M\nDear Ms. Watson:\nEnclosed please find the Order Directing Amendment issued in the above-referenced case. It\nmakes findings of inadequate procedure, finds that certain procedures have been appropriately\namended to address the inadequacies, and requires that Southern Natural Gas Company, L.L.C.\ncomplete additional amendments to address the remaining inadequacies. When the amendment\nof procedures has been completed, as determined by the Director, Southwest Region, this\nenforcement action will be closed. Service of the Order Directing Amendment by certified mail\nis effective as provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. R. M. Seeley, Director, Southwest Region, OPS\nJessica Toll, Esq., Assistant General Counsel, Kinder Morgan, Inc.,\n370 Van Gordon St., Lakewood, CO 80228-8304\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n______________________________________\nIn the Matter of )\nSouthern Natural Gas Company, L.L.C., ) CPF No. 4-2011-1011M\n)\n)\n)\nRespondent. )\n______________________________________ )\nORDER DIRECTING AMENDMENT\nDuring 2010, representatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), pursuant to 49 U.S.C. § 60117, conducted an\ninspection of the written procedures and records of Southern Natural Gas Company, L.L.C.\n(SNG or Respondent). SNG is a subsidiary of Kinder Morgan Inc. (Kinder Morgan) and\noperates approximately 7,600 miles of natural gas transmission pipeline located primarily in\nGeorgia, Alabama, Mississippi and Louisiana.\n1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued a Notice of\nAmendment (Notice) to Respondent on October 20, 2011. In accordance with 49 C.F.R.\n§ 190.237, the Notice alleged that Respondent’s written procedures were inadequate to assure\nsafe operations and proposed that Respondent revise the procedures.\nSNG responded to the Notice by letter dated November 28, 2011. Respondent requested a\nhearing and requested additional time to respond to the Notice due to its pending acquisition by\nKinder Morgan. After receiving several extensions of time, Respondent submitted a written\nresponse to the Notice on October 15, 2012 (Response) and explained that as a result of the\nacquisition, the SNG integrity management program (IMP) and operating and maintenance\n(O&M) procedures were being reviewed and modified to integrate common requirements for all\nKinder Morgan companies. Respondent also submitted revised procedures, some of which were\nin draft form.\nIn accordance with 49 C.F.R. § 190.211, a hearing was held on October 25, 2012, in Houston,\nTexas, before the Presiding Official from the Office of Chief Counsel, PHMSA. After the\nhearing, Respondent submitted additional information including revised procedures on\n1 SNG has reported its pipeline system information for calendar year 2012 pursuant to 49 C.F.R. § 191.17. SNG\nand its parent, El Paso Corporation, were acquired by Kinder Morgan Inc. during the course of this proceeding.\n\n\n\n2\nNovember 9 and 29, 2012. On January 17, 2013, Respondent submitted further revised\nprocedures to the Director, including some draft procedures.2\nHaving reviewed the revised procedures, I find Respondent has addressed the inadequacies in\nItems 2–5, 7, 8 and 11 of the Notice. Accordingly, the amendments proposed in the Notice for\nthose Items are not included in this Order. For the reasons set forth below, I find Respondent’s\nprocedures remain inadequate with regard to Items 1, 6, 9 and 10 of the Notice. Pursuant to\n49 U.S.C. § 60108(a), Respondent is ordered to revise its procedures to address the inadequacies.\nThe Notice alleged that Respondent’s procedures were inadequate as follows:\nItem 1: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§§ 192.911 and 192.915(b), which state:\n§ 192.911 What are the elements of an integrity management\nprogram?\nAn operator’s initial integrity management program begins with a\nframework (see § 192.907) and evolves into a more detailed and\ncomprehensive integrity management program, as information is gained\nand incorporated into the program . . . .\n§ 192.915 What knowledge and training must personnel have to\ncarry out an integrity management program?\n(a) . . . .\n(b) Persons who carry out assessments and evaluate assessment\nresults. The integrity management program must provide criteria for the\nqualification of any person—\n(1) Who conducts an integrity assessment allowed under this subpart;\nor\n(2) Who reviews and analyzes the results from an integrity assessment\nand evaluation; or\nassessments.\n(3) Who makes decisions on actions to be taken based on these\nThe Notice alleged that SNG’s procedures were inadequate because they did not provide criteria\nfor the qualification of persons who review and analyze the results from an integrity assessment\nand evaluation. Specifically, the Notice alleged the company’s procedures did not require\npersonnel to meet acceptable qualification standards for reviewing and evaluating results from\nexternal corrosion direct assessment (ECDA), pressure testing, and stress corrosion cracking\ndirect assessment (SCCDA).\nIn response to this Item, Respondent submitted the following revised procedures: (1) Kinder\nMorgan procedure O&M 920, External Corrosion Direct Assessment, dated November 1, 2012;\n2 The January 2013 information was not submitted to the Presiding Official, but the Director forwarded the\ninformation for insertion into the official case record.\n\n\n\n3\n(2) Kinder Morgan procedure O&M 919, SCC Direct Assessment, dated October 10, 2012;\n(3) Kinder Morgan procedure O&M 199, Operator Qualification, dated September 1, 2010;\n(4) Section 9 of Kinder Morgan IMP, Continual Evaluation and Assessment, dated December 1,\n2010; and (5) Section 15 of Kinder Morgan IMP, Quality Assurance, labeled “Draft 11/9/2012.”\nHaving reviewed the procedures, I find they address the issue raised in the Notice, with the\nexception of Section 15 of Kinder Morgan IMP. Although the procedure is otherwise adequate,\nsubmission of a draft procedure does not confirm that Respondent has adopted the procedure.\nAccordingly, I find that Respondent’s procedure remains inadequate. Pursuant to 49 U.S.C.\n§ 60108(a) and 49 C.F.R. § 190.237, Respondent is ordered to address this inadequacy.\nItem 2: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§§ 192.911 and 192.915(b)(1), quoted above, because the procedures did not provide criteria for\nthe qualification of contractor personnel who conduct integrity assessments. Specifically, the\nNotice alleged that SNG reviews contractors’ resumes for their experience, but the procedures\ndid not specify the qualification requirements for contractor personnel who perform ECDA and\nSCCDA.\nIn response to this Item, Respondent submitted the following procedures: (1) Kinder Morgan\nprocedure O&M 920, External Corrosion Direct Assessment, dated November 1, 2012;\n(2) Kinder Morgan procedure O&M 919, SCC Direct Assessment, dated October 10, 2012; and\n(3) Kinder Morgan procedure O&M 199, Operator Qualification, dated September 1, 2010.\nHaving reviewed the procedures, I find they address the issue raised in the Notice. Accordingly,\nI find that Respondent’s procedures were inadequate, but Respondent has adopted new\nprocedures to address the inadequacy. It is not necessary to order any further amendment with\nregard to this Item.\nItem 3: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§§ 192.911 and 192.915(b)(2), quoted above, because they did not provide criteria for the\nqualification of contractor personnel who review and analyze the results from an integrity\nassessment and evaluation. Specifically, the Notice alleged that SNG reviews contractors’\nresumes for their experience, but SNG’s procedures did not specify the qualification\nrequirements for contractor personnel who review the results of ECDA methods and perform\ninformation analysis.\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 920, External\nCorrosion Direct Assessment, dated November 1, 2012.\nHaving reviewed the procedure, I find it addresses the issue raised in the Notice. Accordingly, I\nfind that Respondent’s procedures were inadequate, but Respondent has adopted new procedures\nto address the inadequacy. It is not necessary to order any further amendment with regard to this\nItem.\n\n\n\n4\nItem 4: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§§ 192.911(b) and 192.921(a)(1), which state:\n§ 192.911 What are the elements of an integrity management\nprogram?\nAn operator’s initial integrity management program . . . and\nsubsequent program must, at minimum, contain the following elements . . .\n(b) A baseline assessment plan meeting the requirements of\n§§ 192.919 and 192.921.\n§ 192.921 How is the baseline assessment to be conducted?\n(a) Assessment methods. An operator must assess the integrity of the\nline pipe in each covered segment by applying one or more of the\nfollowing methods depending on the threats to which the covered segment\nis susceptible. An operator must select the method or methods best suited\nto address the threats identified to the covered segment (see § 192.917).\n(1) Internal inspection tool or tools capable of detecting corrosion, and\nany other threats to which the covered segment is susceptible. An operator\nmust follow ASME/ANSI B31.8S (incorporated by reference,\nsee § 192.7), section 6.2 in selecting the appropriate internal inspection\ntools for the covered segment.\nThe Notice alleged that Respondent’s procedures were inadequate because the baseline\nassessment plan did not contain sufficient detail for internal integrity assessments. Specifically,\nthe Notice alleged that Respondent’s procedures did not define the actions and processes to be\ntaken if a tool vendor cannot complete a review of the internal inspection results within 180 days\nof the assessment.3\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 916, In-Line\nInspections, dated June 1, 2010.\nHaving reviewed the procedure, I find it addresses the issue raised in the Notice. Accordingly, I\nfind that Respondent’s procedures were inadequate, but Respondent has adopted new procedures\nto address the inadequacy. It is not necessary to order any further amendment with regard to this\nItem.\nItem 5: The Notice alleged that Respondent’s procedures were also inadequate with regard to\n§§ 192.911(b) and 192.921(a)(1), quoted above, because the baseline assessment plan did not\ncontain sufficient detail for validating internal integrity assessment results. Specifically, the\nNotice alleged Respondent’s procedures did not require the person evaluating the assessment\nresults to correlate the reported data with actual in-field measurements to determine whether any\nsignificant discrepancies warrant further analysis or other type of action.\n3 Under § 192.933(b), an operator must promptly, but no later than 180 days after conducting an integrity\nassessment, obtain sufficient information about a condition to determine whether it presents a potential threat to the\nintegrity of the pipeline.\n\n\n\n5\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 916, In-Line\nInspections, dated June 1, 2010, and the Kinder Morgan Action Plan / Closure Report Template\nthat is referenced in O&M 916.\nHaving reviewed the procedures, I find they address the issue raised in the Notice. Accordingly,\nI find that Respondent’s procedures were inadequate, but Respondent has adopted new\nprocedures to address the inadequacy. It is not necessary to order any further amendment with\nregard to this Item.\nItem 6: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§ 192.911, quoted above, and § 192.917(b), which states:\n§ 192.917 How does an operator identify potential threats to\npipeline integrity and use the threat identification in its\nintegrity program?\n(a) . . . .\n(b) Data gathering and integration. To identify and evaluate the\npotential threats to a covered pipeline segment, an operator must gather\nand integrate existing data and information on the entire pipeline that\ncould be relevant to the covered segment. In performing this data\ngathering and integration, an operator must follow the requirements in\nASME/ANSI B31.8S, section 4. At a minimum, an operator must gather\nand evaluate the set of data specified in Appendix A to ASME/ANSI\nB31.8S, and consider both on the covered segment and similar non-\ncovered segments, past incident history, corrosion control records,\ncontinuing surveillance records, patrolling records, maintenance history,\ninternal inspection records and all other conditions specific to each\npipeline.\nThe Notice alleged that Respondent’s procedures were inadequate because they did not provide\nsufficient detail concerning the integration of existing information from the operator’s corrosion\ncontrol program. Specifically, the Notice alleged that procedure POP 306, Section 6, Future\nMitigation, did not include details of how corrosion control information is to be integrated with\nthe internal integrity assessment results.\nIn its Response and at the hearing, Respondent stated that the POP 306 procedure and Kinder\nMorgan O&M Procedure 916 were never intended to cover data integration or evaluation of the\ncorrosion control program. Respondent explained that data integration for the purpose of\nidentifying and evaluating potential threats had been addressed in the SNG IMP, Appendix A,\nbut the procedure would soon be replaced. At the hearing, Respondent agreed to submit a new\nKinder Morgan procedure that would be used to address this issue.\nIn its post-hearing submissions, however, I do not find any further discussion of Item 6 or any\nreference to procedures that were submitted for the purpose of satisfying this issue.\n\n\n\n6\nAccordingly, I find that Respondent’s procedure remains inadequate. Pursuant to 49 U.S.C.\n§ 60108(a) and 49 C.F.R. § 190.237, Respondent is ordered to revise its procedures to address\nthis inadequacy.\nItem 7: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§§ 192.911(e) and 192.933(a)(1) and (d), which state:\n§ 192.911 What are the elements of an integrity management\nprogram?\nAn operator’s initial integrity management program . . . and\nsubsequent program must, at minimum, contain the following elements . . .\n(e) Provisions meeting the requirements of § 192.933 for remediating\nconditions found during an integrity assessment.\n§ 192.933 What actions must be taken to address integrity issues?\n(a) General requirements. An operator must take prompt action to\naddress all anomalous conditions the operator discovers through the\nintegrity assessment . . . .\n(1) Temporary pressure reduction. If an operator is unable to respond\nwithin the time limits for certain conditions specified in this section, the\noperator must temporarily reduce the operating pressure of the pipeline or\ntake other action that ensures the safety of the covered segment . . . .\n(d) Special requirements for scheduling remediation—(1) Immediate\nrepair conditions. An operator’s evaluation and remediation schedule\nmust follow ASME/ANSI B31.8S, section 7 in providing for immediate\nrepair conditions. To maintain safety, an operator must temporarily reduce\noperating pressure in accordance with paragraph (a) of this section or shut\ndown the pipeline until the operator completes the repair of these\nconditions . . . .\nThe Notice alleged that Respondent’s procedures were inadequate because the procedures did\nnot require operating pressure to be reduced or the pipeline to be shut down as soon as\npracticable after an immediate repair condition is identified. Specifically, the Notice alleged that\nRespondent’s procedures allowed five days from discovery of an immediate repair condition to\nexamine the condition before taking any pressure reduction.\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 916, In-Line\nInspections, dated June 1, 2010.\nHaving reviewed the procedure, I find it addresses the issue raised in the Notice. Accordingly, I\nfind that Respondent’s procedures were inadequate, but that Respondent has adopted new\nprocedures to address the inadequacy. It is not necessary to order any further amendment with\nregard to this Item.\nItem 8: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§§ 192.605(b)(2) and 192.455(a)(1), which state:\n\n\n\n7\n§ 192.605 Procedural manual for operations, maintenance, and\nemergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations . . .\n(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of subpart I of this part [§§ 192.451–192.491].\n§ 192.455 External corrosion control: Buried or submerged\npipelines installed after July 31, 1971.\n(a) Except as provided in paragraphs (b), (c), and (f) of this section,\neach buried or submerged pipeline installed after July 31, 1971, must be\nprotected against external corrosion, including the following:\n(1) It must have an external protective coating meeting the\nrequirements of § 192.461.\nThe Notice alleged that Respondent’s procedures were inadequate because they did not provide\nsufficient detail concerning the manner in which personnel must document the condition of\ncoating when pipe is exposed. Specifically, the Notice alleged the procedures required that\ncoating condition be recorded using terms such as “good,” “fair,” and “excellent.” The\nprocedures, however, did not provide criteria for the selection of those terms. Personnel in the\nfield would therefore make their own judgment as to how the terms should be applied.\nIn response to this Item, Respondent submitted Kinder Morgan form OM200-02IMP and\napplicable procedures for completing the forms, dated September 2012.\nHaving reviewed the procedures, I find they address the issue raised in the Notice. Accordingly,\nI find that Respondent’s procedures were inadequate, but Respondent has adopted new\nprocedures to address the inadequacy. It is not necessary to order any further amendment with\nregard to this Item.\nItem 9: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§ 192.605(b)(2), quoted above, and § 192.477, which states:\n§ 192.477 Internal corrosion control: Monitoring.\nIf corrosive gas is being transported, coupons or other suitable means\nmust be used to determine the effectiveness of the steps taken to minimize\ninternal corrosion. Each coupon or other means of monitoring internal\ncorrosion must be checked two times each calendar year, but with\nintervals not exceeding 7 ½ months.\nThe Notice alleged that Respondent’s procedures were inadequate because they did not provide\nsufficient detail for determining the effectiveness of the steps taken to minimize internal\ncorrosion. Specifically, the Notice alleged the procedures did not identify criteria used by the\n\n\n\n8\nmonitoring program to determine if current mitigative measures were adequate or if additional\nmitigative measures were required.\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 906, Internal\nCorrosion Control, dated December 20, 2012, which was labeled “DRAFT.” Although the\nprocedure is otherwise adequate, the submission of a draft procedure does not confirm that\nRespondent has adopted the procedure.\nAccordingly, I find Respondent’s procedure remains inadequate. Pursuant to 49 U.S.C.\n§ 60108(a) and 49 C.F.R. § 190.237, Respondent is ordered to address this inadequacy.\nItem 10: The Notice alleged that Respondent’s procedures were also inadequate with regard to\n§§ 192.605(b)(2) and 192.477, quoted above, because the procedures did not provide details\nconcerning the company’s use of the corrosion control database “TSIMS.” The database\nincludes information about internal tool runs, coupons, and other data. The Notice further\nalleged the corrosion control procedures used for determining when supplemental action is\nneeded did not define a specific corrosion rate that would trigger additional mitigative measures.\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 906, Internal\nCorrosion Control, dated December 20, 2012, which was labeled “DRAFT.” While the revised\nprocedure mentions the TSIMS system, it does not provide sufficient detail concerning specific\ncorrosion rates and other factors that would trigger additional mitigative measures.\nAccordingly, I find that Respondent’s procedures remain inadequate. Pursuant to 49 U.S.C.\n§ 60108(a) and 49 C.F.R. § 190.237, Respondent is ordered to revise its procedure to address the\ninadequacy.\nItem 11: The Notice alleged that Respondent’s procedures were inadequate with regard to\n§ 192.605(b)(2), quoted above, and § 192.485, which states:\n§ 192.485 Remedial measures: Transmission lines.\n(a) General corrosion. Each segment of transmission line with general\ncorrosion and with a remaining wall thickness less than that required for\nthe MAOP of the pipeline must be replaced or the operating pressure\nreduced commensurate with the strength of the pipe based on actual\nremaining wall thickness . . . .\n(b) Localized corrosion pitting. Each segment of transmission line pipe\nwith localized corrosion pitting to a degree where leakage might result\nmust be replaced or repaired, or the operating pressure must be reduced\ncommensurate with the strength of the pipe, based on the actual remaining\nwall thickness in the pits.\n(c) Under paragraphs (a) and (b) of this section, the strength of pipe\nbased on actual remaining wall thickness may be determined by the\nprocedure in ASME/ANSI B31G or the procedure in AGA Pipeline\nResearch Committee Project PR 3–805 (with RSTRENG disk) . . . .\n\n\n\n9\nThe Notice alleged that SNG’s procedures were inadequate because the procedures did not\nrequire reducing operating pressure or replacing pipe that has remaining wall thickness less than\nthat required for the maximum allowable operating pressure (MAOP) of the pipeline.\nSpecifically, the Notice alleged that Respondent’s procedures required reducing pressure or\nreplacing pipe only when metal loss results in a failure pressure (Pfail) less than or equal to 1.10\n* MAOP, which is equivalent to 91% SMYS. This criterion, the Notice alleged, is less stringent\nthan that specified in § 192.485(c), which requires action to be taken when metal loss results in\nremaining wall thickness less than that required for MAOP, or 72% SMYS.\nIn response to this Item, Respondent submitted Kinder Morgan procedure O&M 916, In-Line\nInspections, dated June 1, 2010.\nHaving reviewed the newly adopted procedure, I find it addresses the issue raised in the Notice.\nAccordingly, I find that Respondent’s procedures were inadequate, but Respondent has adopted\nnew procedures to address the inadequacy. It is not necessary to order any further amendment\nwith regard to this Item.\nWithin 45 days following receipt of this Order, Respondent must submit procedures that have\nbeen revised pursuant to Items 1, 6, 9 and 10, above. All documentation demonstrating\ncompliance with this Order must be submitted to the Director, Southwest Region, Office of\nPipeline Safety, Pipeline and Hazardous Materials Safety Administration, 8701 S. Gessner, Suite\n1110, Houston, TX 77074. In your correspondence on this matter, please refer to CPF No.\n4-2011-1011M.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent demonstrating good cause for an extension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000 for each violation for each day the violation continues or referral to the\nAttorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n____________________________ ______________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420111011M_Closure_12182013_text.pdf\n\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nDecember 18, 2013\nMr. Gary Buchler\nVice President, Operations and Engineering\nSouthern Natural Gas Company, LLC\n1011 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF 4-2011-1011M\nDear Mr. Buchler:\nOn October 24, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Southern Natural Gas a Notice of Amendment in the above-referenced case. Based on\nour review of the documentation you provided, it has been determined that you have complied\nwith the terms of the Order Directing Amendment.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":26828}