{"operation":"document","citation":"CPF 520131003W","title":"EL PASO NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-02-27","effective_on":null,"summary":"CLOSED warning letter citing 192.465(d), 192.707(a)(1), 192.743(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520131003W","body":"Warning Letter involving EL PASO NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.465(d),  192.707(a)(1),  192.743(b). The case was opened on 2013-02-27 and is reported as closed as of 2013-02-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520131003W_Operator Response_04042013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131003W/520131003W_Operator%20Response_04042013.pdf\n\n520131003W_warning letter_02272013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131003W/520131003W_warning%20letter_02272013.pdf\n\n520131003W_warning letter_02272013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131003W/520131003W_warning%20letter_02272013_text.pdf\n\n520131003W_warning letter_02272013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 27, 2013\nMr. Dwayne Burton\nVice President, Engineering/Operations\nKMI Pipeline\n500 Dallas Street, Suite 1000\nHouston, TX 77002\nCPF 5-2013-1003W\nDear Mr. Burton:\nPursuant to our Interstate Agent Agreement with the Arizona Corporation Commission\n(ACC), the ACC as representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an\nannual inspection of El Paso Natural Gas/KMI Pipeline. This inspection was conducted\nbetween July 2012 and December 2012 at El Paso Natural Gas field offices located in\nFlagstaff, Phoenix, Thatcher, Ehrenberg, and Tucson, Arizona; and Gallup, New Mexico.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The probable violations\nare:\n1. §192.465(d) External corrosion control: Monitoring.\n(d) Each operator shall take prompt remedial action to correct any deficiencies\nindicated by the monitoring.\n\n\n\nDuring the records review of item #13C of the Consent Agreement, it was noted that Kinder\nMorgan did not update their maps and/or records in a timely manner. Specifically, the 2008\ninstallation of Electrolysis Test Station (ETS) on the CalNev 8-inch between Bracken\nJunction and Las Vegas was not included on Kinder Morgan’s maps and records after more\nthan three (3) years. Therefore, we consider the maps reviewed not to be current.\n2. §192.743(b) Pressure limiting and regulating stations: Capacity of relief device\n(b) If review and calculations are used to determine if a device has sufficient\ncapacity, the calculated capacity must be compared with the rated or\nexperimentally determined relieving capacity of the device for the conditions\nunder which it operates. After the initial calculations, subsequent calculations\nneed not be made if the annual review documents that parameters have not\nchanged to cause the rated or experimentally determined relieving capacity to be\ninsufficient.\nDocumentation provided during this inspection for the 2009 and 2010 inspections of the\nSomerton City Gate station demonstrated that the capacity of the regulators exceeded the\nrelief capacity of the relief valve installed on this station. In addition, the capacity of the\nrelief valve and regulator on records dated 4-21-10 and 5-16-12 were incorrectly entered.\nFurthermore, the 2009 records for this station failed to include any capacity information.\nThe relief valve at the Duncan No. 2 station is set at the station’s documented MAOP of 75\npsi. According to the station inspection report for the 2012 calendar year, the relief valve\ncapacity listed on the report is 60 MCFH, which is greater than the regulator’s capacity of\n24.6 MCFH. However, according to the relief valve manufacturer’s bulletin, the capacity\nlisted in the inspection report only happens at the set point of 75 psi plus 25 psi buildup\npressure. Therefore, the capacity only takes place when the relief valve inlet pressure is 100\npsi. Based on the above information, without conducting a full flow test there exists the\npossibility of an over pressure on the downstream pipeline. KMI cannot currently ensure the\nDuncan #2 station has a relief device with adequate capacity.\n3. §192.707 Line markers for mains and transmission lines\n(a) Buried pipelines. Except as provided in paragraph (b) of this section, a line\nmarker must be placed and maintained as close as practical over each buried\nmain and transmission line:\n(1) At each crossing of a public road and railroad\nThere were no line markers on the 2103 line where the pipeline crossed underneath\nRoadrunner and Bilby Roads in the South Tucson area.\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in El Paso Natural Gas/KMI\nPipeline Partners being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2013-1003W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Finch (#141919 & 138177)\nMr. Robert Miller, Arizona Corporation Commission\nMr. Reji George, El Paso Natural Gas (Kinder Morgan/KMI Pipeline)","truncated":false,"body_characters":6132}