# COLORADO INTERSTATE GAS CO — Warning Letter

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

Official case documents:

520101007W_warning letter_12142010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101007W/520101007W_warning%20letter_12142010.pdf

520101007W_warning letter_12142010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101007W/520101007W_warning%20letter_12142010_text.pdf

520101007W_warning letter_12142010_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 14, 2010
Mr. Michael Catt
Vice President of Operations
El Paso Natural Gas (Colorado Interstate Gas Company)
2 North Nevada Avenue
Colorado Springs, CO 80903
Dear Mr. Catt:
CPF 5-2010-1007W
On December 8, 2010, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Operator Qualification Records for construction of the Ruby Pipeline near Salt Lake City, Utah.
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. §192.807 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with this
subpart.
(a) Qualification records shall include:
(1) Identification of qualified individual(s);
(2) Identification of the covered tasks the individual is qualified to perform;
(3) Date(s) of current qualification; and
(4) Qualification method(s).
(b) Records supporting an individual’s current qualification shall be maintained
while the individual is performing the covered task. Records of prior qualification
and records of individuals no longer performing covered tasks shall be retained for
a period of five years.



At the time of the inspection, El Paso could not provide documentation that all covered tasks
being performed on the Ruby Pipeline construction project were being performed by Operator
Qualified personnel. Numerous inspector daily reports dated from September 11, 2010 to
November 20, 2010 were reviewed and compared to the master list of qualified personnel for the
project. As a result several people listed on the daily reports as performing covered tasks were
not on the master list of qualified personnel. Examples of covered tasks preformed by personnel
not on the master list of qualified persons include 008PIP (Identify, mark, and locate pipelines),
036COR (Install test leads and test stations), 022PIP (Monitor excavation), 050PIP (Observe
machine excavation), 011COR (Inspection application of coating), and 005WEL (Perform
pipeline welding).
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
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 identified in this letter.
Failure to do so will result in El Paso Natural Gas Transmission 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 5-2010-1007W. 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,
Chris Hoidal
Director, Western
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Haddow (#128588)
2
- **truncated:** false
- **body characters:** 4269