{"operation":"document","citation":"CPF 520140004W","title":"CPN PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-11-12","effective_on":null,"summary":"CLOSED warning letter citing 192.917(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520140004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520140004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520140004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520140004W","body":"Warning Letter involving CPN PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.917(a). The case was opened on 2014-11-12 and is reported as closed as of 2014-11-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520140004W_warning letter_11122014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520140004W/520140004W_warning%20letter_11122014.pdf\n\n520140004W_warning letter_11122014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520140004W/520140004W_warning%20letter_11122014_text.pdf\n\n520140004W_warning letter_11122014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 12, 2014\nMr. Lyle Fedje\nDirector, Pipeline Operations\nCPN Pipeline Company\n60 River Road\nRio Vista, CA 94571\nCPF 5-2014-0004W\nDear Mr. Fedje:\nOn May 5-9, 2014, June 9-12, 2014, and July 21-25, 2014, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your natural gas transmission pipeline system in Rio Vista, CA.\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(s) are:\n1. §192.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(a) Threat identification. An operator must identify and evaluate all potential\nthreats to each covered pipeline segment. Potential threats that an operator must\nconsider include, but are not limited to, the threats listed in ASME/ANSI B31.8S\n(incorporated by reference, see §192.7), section 2, which are grouped under the\nfollowing four categories:\n(1) Time dependent threats such as internal corrosion, external corrosion, and\nstress corrosion cracking;\n\n\n\n(2) Static or resident threats, such as fabrication or construction defects;\n(3) Time independent threats such as third party damage and outside force\ndamage; and\n(4) Human error.\nCPN Pipeline Company (CPN) failed to document consideration of potential interactive threats\nin its threat identification analysis. CPN’s Integrity Management Program (IMP) procedures,\nSection 3.3 in regards to “Threats, Data integration and Risk Analysis”, described consideration\nof potential interactive threats as part of its analysis. A review of IMP Meeting Notes used in\nCPN’s annual IMP reviews, however, did not show documented evidence that potential\ninteractive threats were considered for each covered pipeline segment listed. CPN must ensure\nthat multiple threats on the same pipeline segment are evaluated for interrelated effects.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\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 letter.\nFailure to do so will result in CPN Pipeline Company being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2014-0004W. 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 C. Ishikawa (#145425)","truncated":false,"body_characters":4350}