{"operation":"document","citation":"CPF 420141006W","title":"EL PASO NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-05-13","effective_on":null,"summary":"CLOSED warning letter citing 192.619(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420141006W","body":"Warning Letter involving EL PASO NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.619(a). The case was opened on 2014-05-13 and is reported as closed as of 2014-05-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420141006W_Operator Response to Notice_07172014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Operator%20Response%20to%20Notice_07172014.pdf\n\n420141006W_Warning Letter_05132014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Warning%20Letter_05132014.pdf\n\n420141006W_Warning Letter_05132014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141006W/420141006W_Warning%20Letter_05132014_text.pdf\n\n420141006W_Warning Letter_05132014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 13, 2014\nMr. Gary Buchler\nVice President Engineering/Operations\nKMI Pipeline\n1001 Louisiana Street\nHouston, Texas 77002-5089\nCPF 4-2014-1006W\nDear Mr. Buchler:\nBetween October 16, 2012 and March 31, 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nreviewed Safety Related Condition Report 2012-0088 submitted on October 12, 2012, by El\nPaso Natural Gas Company for a safety related incident that occurred in El Paso County, Texas.\nAs a result of the review, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable\nviolation is:\n1. § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.\n(a) No person may operate a segment of steel or plastic pipeline at a pressure that\nexceeds a maximum allowable operating pressure determined under paragraph (c)\nor (d) of this section…\nAs indicated in your Safety Related Condition Report, El Paso Natural Gas Company\nexperienced an overpressure condition that met the reporting criteria for a safety related\ncondition as described in Advisory Bulletin (ADB-2012-11). On four (4) occasions in 2012, the\nLa Tuna Prison lateral, a portion of your El Paso-Pecos River Unit, was operated at a pressure\nthat exceeded the maximum allowable operating pressure plus allowable buildup. The\nestablished MAOP for the line, at the time of the event and report was 700 PSIG. The maximum\npressures exceeded 110% of the MAOP of the line on:\n\n\n\n• April 25, 2012 787 psig max. 6+ hrs.\n• August 11, 2012 771 psig max 5+ hrs.\n• October 6, 2012 779 psig max 10+ hrs.\n• October 7, 2012 793 psig max 12+ hrs.\nThe pipeline continued to exceed the MAOP of 700 psig for the complete 24 hour daily record as\nfurnished to the investigator.\nThis event is reflected in the Safety Related Condition Report you filed with PHMSA, as well as\nprovided SCADA documentation related to the event.\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.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2014-1006W. 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,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":3860}