{"operation":"document","citation":"CPF 520101007W","title":"COLORADO INTERSTATE GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-12-14","effective_on":null,"summary":"CLOSED warning letter citing 192.807(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520101007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520101007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520101007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520101007W","body":"Warning Letter involving COLORADO INTERSTATE GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.807(b). The case was opened on 2010-12-14 and is reported as closed as of 2010-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520101007W_warning letter_12142010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101007W/520101007W_warning%20letter_12142010.pdf\n\n520101007W_warning letter_12142010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101007W/520101007W_warning%20letter_12142010_text.pdf\n\n520101007W_warning letter_12142010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 14, 2010\nMr. Michael Catt\nVice President of Operations\nEl Paso Natural Gas (Colorado Interstate Gas Company)\n2 North Nevada Avenue\nColorado Springs, CO 80903\nDear Mr. Catt:\nCPF 5-2010-1007W\nOn December 8, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nOperator Qualification Records for construction of the Ruby Pipeline near Salt Lake City, Utah.\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. §192.807 Recordkeeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\n(b) Records supporting an individual’s current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior qualification\nand records of individuals no longer performing covered tasks shall be retained for\na period of five years.\n\n\n\nAt the time of the inspection, El Paso could not provide documentation that all covered tasks\nbeing performed on the Ruby Pipeline construction project were being performed by Operator\nQualified personnel. Numerous inspector daily reports dated from September 11, 2010 to\nNovember 20, 2010 were reviewed and compared to the master list of qualified personnel for the\nproject. As a result several people listed on the daily reports as performing covered tasks were\nnot on the master list of qualified personnel. Examples of covered tasks preformed by personnel\nnot on the master list of qualified persons include 008PIP (Identify, mark, and locate pipelines),\n036COR (Install test leads and test stations), 022PIP (Monitor excavation), 050PIP (Observe\nmachine excavation), 011COR (Inspection application of coating), and 005WEL (Perform\npipeline welding).\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 identified in this letter.\nFailure to do so will result in El Paso Natural Gas Transmission 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 5-2010-1007W. 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\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Haddow (#128588)\n2","truncated":false,"body_characters":4269}