{"operation":"document","citation":"CPF 420171008W","title":"CAMERON INTERSTATE PIPELINE — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-29","effective_on":null,"summary":"CLOSED warning letter citing 192.603(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420171008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420171008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420171008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420171008W","body":"Warning Letter involving CAMERON INTERSTATE PIPELINE. PHMSA's enforcement data identifies the cited regulation as 192.603(b). The case was opened on 2017-06-29 and is reported as closed as of 2017-06-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420171008W_Warning Letter_06292017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171008W/420171008W_Warning%20Letter_06292017.pdf\n\n420171008W_Warning Letter_06292017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171008W/420171008W_Warning%20Letter_06292017_text.pdf\n\n420171008W_Warning Letter_06292017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 29, 2017\nSempra US Gas & Power\nAttn: Mr. John Pirraglia\nVice President, Cameron Interstate Pipeline\n2925 Briarpark Dr, Suite 850\nHouston, TX 77042\nCPF 4-2017-1008W\nDear Mr. Pirraglia:\nDuring the month of February, 2016, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nCameron Interstate Pipeline (“Cameron”) procedures for Operations and Maintenance (O&M),\nrecords and field visit in Ragley, LA.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation is:\n1.§192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures established\nunder §192.605.\n§192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety during\nmaintenance and operations.\n\n\n\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness, and adequacy of the procedures used in normal operation and maintenance\nand modifying the procedures when deficiencies are found.\nCameron failed to keep records necessary to administer procedures established under §192.605.\nDuring the inspection, PHMSA requested Cameron to provide the three years (2013, 2014 and\n2015) records of periodic review of the work done by operator personnel to determine the\neffectiveness, and adequacy of the procedures used in normal operation and maintenance\nand modifying the procedures when deficiencies are found. Cameron provided the Forms\nOM000-01- Change request. PHMSA reviewed the forms and identified that the forms do not\ndemonstrate whether the periodic review of work was exercised or not. When asked, Cameron\nfield personnel agreed with the findings. Cameron created a new form, Form OM000-02A-Field\nObservation Effectiveness Review, and assured PHMSA that periodic review of work will\nbe documented properly in the future.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Cameron 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 4-2017-1008W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nJon Manning\nActing Director, SW Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4416}