{"operation":"document","citation":"CPF 520151001W","title":"COLORADO INTERSTATE GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-01-15","effective_on":null,"summary":"CLOSED warning letter citing 192.935(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520151001W","body":"Warning Letter involving COLORADO INTERSTATE GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.935(a). The case was opened on 2015-01-15 and is reported as closed as of 2015-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520151001W_Operator Response to Notice and Request for Hearing_02202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing_02202015.pdf\n\n520151001W_warning letter_01152015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_warning%20letter_01152015.pdf\n\n520151001W_warning letter_01152015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_warning%20letter_01152015_text.pdf\n\n520151001W_withdrawal of notice letter_03172015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_withdrawal%20of%20notice%20letter_03172015.pdf\n\n520151001W_withdrawal of notice letter_03172015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_withdrawal%20of%20notice%20letter_03172015_text.pdf\n\n520151001W_withdrawal of notice letter_03172015_text.pdf\n\nWITHDRAWAL of NOTICE LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 17, 2015\nMr. Jorge Torres\nVice President Engineering\nColorado Interstate Gas\n1001 Louisiana Street\nHouston, TX 77002\nCPF 5-2015-1001W\nDear Mr. Torres:\nOn January 15, 2015, Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued Colorado Interstate Gas (CIG) a Warning letter for the case number referenced above.\nThis Notice cited CIG for a violation of Section 192.935(a), for failing to conduct the required\nrisk analysis and implement additional P&M (preventive and mitigative) measures to protect\nHCAs (high consequence areas) in a timely manner.\nCIG responded to the Notice by letter dated February 20, 2015. In its response, CIG noted\nthat §192.935(a) does not specify a deadline by which compliance must be achieved, and\nstated that it had voluntarily updated its analysis of all valves protecting HCAs in 2012 and\nscheduled installation of valves where response time to an HCA exceeded one hour. The\ncompany also provided information regarding automatic shut-off valves and remote control\nvalves that it had installed in 2014.\n\n\n\nPHMSA hereby withdraws the Notice and the case is now closed. PHMSA will review CIG’s\nintegrity management plan, schedule for implementation, and P&M measures related to this\nrisk assessment at a future inspection.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: Jessica Toll, Esq.\nGary Buchler, Vice President, Engineering and Operations of KMI Pipeline\nBenjamin Fred, PHMSA Hearing Officer\n2\n\n520151001W_warning letter_01152015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 15, 2015\nMr. Gary Buchler\nVice President Engineering\nand Operations of KMI Pipeline\nColorado Interstate Gas\n1001 Louisiana Street\nHouston, TX 77002\nCPF 5-2015-1001W\nDear Mr. Buchler:\nDuring the weeks of April 8, 2013 and April 28, 2014, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected your Colorado Interstate Gas (CIG) facilities in the Pueblo Area of\nColorado.\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\nthe probable violation is:\n\n\n\n1. §192.935 What additional preventive and mitigative measures must an operator\ntake?\n(a) General requirements. An operator must take additional measures beyond\nthose already required by Part 192 to prevent a pipeline failure and to\nmitigate the consequences of a pipeline failure in a high consequence area.\nAn operator must base the additional measures on the threats the operator\nhas identified to each pipeline segment. (See § 192.917) An operator must\nconduct, in accordance with one of the risk assessment approaches in\nASME/ANSI B31.8S (incorporated by reference, see § 192.7), section 5, a risk\nanalysis of its pipeline to identify additional measures to protect the high\nconsequence area and enhance public safety. Such additional measures\ninclude, but are not limited to, installing Automatic Shut-off Valves [ASO] or\nRemote Control Valves [RCV], installing computerized monitoring and leak\ndetection systems, replacing pipe segments with pipe of heavier wall\nthickness, providing additional training to personnel on response procedures,\nconducting drills with local emergency responders and implementing\nadditional inspection and maintenance programs.\nCIG failed to implement the ASV and RCV study in a timely manner for adding protection to\na high consequence area. The effective date of the Integrity Management regulations was\nDecember 2003. Part 192.935(a) requires a risk analysis be conducted per Section 5, ASME\nB31.8S to identify additional measures for protecting the high consequence area.\nSubsequently, CIG conducted the \"ASV and RCV Study.\" At the time of inspection,\ninterviews CIG personnel revealed that CIG added either ASV or RCV as a preventive and\nmitigative (P&M) measures for seven (7) high consequence areas (HCAs) within the Pueblo\nArea in March 2012 and one (1) HCA in December 2006. However, time period for\nimplementing the ASV and RCV study was too long to enhance public safety.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting 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 Colorado Interstate Gas\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-1001W. 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.\n2\n\n\n\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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. Allen (#143216)\n3","truncated":false,"body_characters":7135}