{"operation":"document","citation":"CPF 520095008W","title":"EL PASO NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-02-19","effective_on":null,"summary":"CLOSED warning letter citing 192.625(f)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095008W","body":"Warning Letter involving EL PASO NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.625(f)(1). The case was opened on 2009-02-19 and is reported as closed as of 2009-02-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095008W_warning letter_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095008W/520095008W_warning%20letter_02192009.pdf\n\n520095008W_warning letter_02192009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095008W/520095008W_warning%20letter_02192009_text.pdf\n\n520095008W_warning letter_02192009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 19, 2009\nMr. Daniel B. Martin\nSenior Vice President of Operations\nEl Paso Corporation\n1001 Louisiana St.\nHouston, TX 77002\nCPF 5-2009-5008W\nDear Mr. Martin:\nFrom September 29, 2008 to October 3, 2008, representatives of the Arizona Corporation\nCommission acting as an agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected records pertaining to the\noperation and maintenance of your Arizona natural gas pipelines in Phoenix, Arizona.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. §192.625 Odorization of gas\n(e) Equipment for odorization must introduce the odorant without wide variations\nin the level of odorant.\n(f) To assure the proper concentration of odorant in accordance with this section,\neach operator must conduct periodic sampling of combustible gases using an\ninstrument capable of determining the percentage of gas in air at which the odor\nbecomes readily detectable. Operators of master meter systems may comply with\nthis requirement by–\n\n\n\n(1) Receiving written verification from their gas source that the gas has the proper\nconcentration of odorant.\nThe percentage of gas in air results for odorant tests conducted on pipeline 2025 on\n9-16-2008 and pipeline 2026 on 1-14-2008 were improperly calculated.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\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\nletter. Failure to do so will result in El Paso Corporation being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2009-5008W. 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,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Haddow (#120760)\nArizona Corporation Commission-Mr. Robert Miller\n2","truncated":false,"body_characters":3633}