{"operation":"document","citation":"CPF 42024040WL","title":"TRUNKLINE GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-08-28","effective_on":null,"summary":"CLOSED warning letter citing 191.5(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024040wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024040wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024040wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024040WL","body":"Warning Letter involving TRUNKLINE GAS CO. PHMSA's enforcement data identifies the cited regulation as 191.5(a). The case was opened on 2024-08-28 and is reported as closed as of 2024-08-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024040WL_Warning Letter_08282024_(24-306806).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024040WL/42024040WL_Warning%20Letter_08282024_(24-306806).pdf\n\n42024040WL_Warning Letter_08282024_(24-306806)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024040WL/42024040WL_Warning%20Letter_08282024_(24-306806)_text.pdf\n\n42024040WL_Warning Letter_08282024_(24-306806)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: thomas.long@energytransfer.com\nAugust 28, 2024\nMr. Thomas Long\nChief Executive Officer\nTrunkline Gas Company\n1300 Main Street\nHouston, Texas, 77002\nCPF 4-2024-040-WL\nDear Mr. Long:\nA representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code (U.S.C.) reviewed Trunkline Gas Company’s\n(Trunkline) incident report that described an unintentional release of 67.68 million cubic feet\n(MMCF) of gas that occurred on April 30, 2024 at the Longville Compressor Station in Longville,\nLouisiana.\nAs a result of the review, it is alleged that Trunkline has committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 191.5 Immediate notice of certain incidents\n(a) At the earliest practicable moment following discovery, but no\nlater than one hour after confirmed discovery, each operator must give\nnotice in accordance with paragraph (b) of this section of each incident\nas defined in § 191.3.\nTrunkline failed to notify the National Response Center (NRC) at the earliest practicable moment\nfollowing the discovery, but no later than one hour after confirmed discovery of the April 30, 2024,\nreportable incident, as defined in § 191.3, at the Longville Compressor Station in accordance with\n§ 191.5(a).\n\n\n\nOn April 30, 2024, at 5:52 pm, Trunkline received an alarm for the Longville Compressor Station.\nTrunkline personnel arrived at the incident site at 6:04 pm and confirmed that the emergency\nshutdown device had been set off and that the station was blowing gas. The station vented gas for\nan additional 43 minutes (until approximately 6:47 pm) until personnel identified the mainline fire\ngate valve that failed to fully close.\nOn May 1, 2024, at 4:15 pm, Trunkline estimated that 67.68 MMCF of gas was released and made\nthe notification to NRC (# 1397797) at 4:29 pm on the same day because the amount of gas\nreleased exceeded 3 MMCF. However, Trunkline waited 21 hours and 42 minutes to estimate the\ngas loss. Trunkline is required to calculate cost and gas volume estimates as soon as practicable\nfollowing the discovery of an unintentional gas release.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related\nseries of violations. For violation occurring on or after January 6, 2023 and before December 28,\n2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,\nup to a maximum of $2,576,627 for a related series of violations. For violation occurring on or\nafter March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142\nper violation per day the violation persists, up to a maximum of $2,391,142 for a related series of\nviolations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the\nmaximum penalty may not exceed $225,134 per violation per day the violation persists, up to a\nmaximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679.\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. We advise you to correct the item identified in this letter. Failure to do so may result in\nTrunkline Gas Company 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 4-2024-040-WL. 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).\n\n\n\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Greg McIlwain, EVP Operations, gregory.mcilwain@energytransfer.com\nEric Amundsen, SVP Operations, eric.amundsen@energytransfer.com\nTodd Stamm, SVP Operations, todd.stamm@energytransfer.com\nJennifer Street, SVP Operations Services, jennifer.street@energytransfer.com\nKeegan Pieper, Assistant General Counsel, keegan.pieper@energytransfer.com\nMatthew Stork, VP Tech Services, matthew.stork@energytransfer.com\nTodd Nardozzi, Director – DOT Compliance, todd.nardozzi@energytransfer.com\nSusie Sjulin, Director – DOT Compliance, susie.sjulin@energytransfer.com","truncated":false,"body_characters":6266}