COLORADO INTERSTATE GAS CO — Warning Letter

520101007W_warning letter_12142010_text.pdf, page 1Official PDFWARNING 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.#

520101007W_warning letter_12142010_text.pdf, page 2At 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#