# CAMERON INTERSTATE PIPELINE — Warning Letter

- **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:** Not available
- **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.

Official case documents:

420171008W_Warning Letter_06292017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171008W/420171008W_Warning%20Letter_06292017.pdf

420171008W_Warning Letter_06292017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171008W/420171008W_Warning%20Letter_06292017_text.pdf

420171008W_Warning Letter_06292017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 29, 2017
Sempra US Gas & Power
Attn: Mr. John Pirraglia
Vice President, Cameron Interstate Pipeline
2925 Briarpark Dr, Suite 850
Houston, TX 77042
CPF 4-2017-1008W
Dear Mr. Pirraglia:
During the month of February, 2016, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Cameron Interstate Pipeline (“Cameron”) procedures for Operations and Maintenance (O&M),
records and field visit in Ragley, LA.
As a result of the inspection, it appears that you have committed a probable violation of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable
violation is:
1.§192.603 General provisions
(b) Each operator shall keep records necessary to administer the procedures established
under §192.605.
§192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following, if applicable, to provide safety during
maintenance and operations.



(8) Periodically reviewing the work done by operator personnel to determine the
effectiveness, and adequacy of the procedures used in normal operation and maintenance
and modifying the procedures when deficiencies are found.
Cameron failed to keep records necessary to administer procedures established under §192.605.
During the inspection, PHMSA requested Cameron to provide the three years (2013, 2014 and
2015) records of periodic review of the work done by operator personnel to determine the
effectiveness, and adequacy of the procedures used in normal operation and maintenance
and modifying the procedures when deficiencies are found. Cameron provided the Forms
OM000-01- Change request. PHMSA reviewed the forms and identified that the forms do not
demonstrate whether the periodic review of work was exercised or not. When asked, Cameron
field personnel agreed with the findings. Cameron created a new form, Form OM000-02A-Field
Observation Effectiveness Review, and assured PHMSA that periodic review of work will
be documented properly in the future.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations 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 item(s) identified in this letter.
Failure to do so will result in Cameron being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2017-1008W. 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,
Jon Manning
Acting Director, SW Region
Pipeline and Hazardous Materials Safety Administration
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