# COLORADO INTERSTATE GAS CO — Warning Letter - **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:** Not available - **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. Official case documents: 520151001W_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 520151001W_warning letter_01152015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_warning%20letter_01152015.pdf 520151001W_warning letter_01152015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_warning%20letter_01152015_text.pdf 520151001W_withdrawal of notice letter_03172015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_withdrawal%20of%20notice%20letter_03172015.pdf 520151001W_withdrawal of notice letter_03172015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151001W/520151001W_withdrawal%20of%20notice%20letter_03172015_text.pdf 520151001W_withdrawal of notice letter_03172015_text.pdf WITHDRAWAL of NOTICE LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 17, 2015 Mr. Jorge Torres Vice President Engineering Colorado Interstate Gas 1001 Louisiana Street Houston, TX 77002 CPF 5-2015-1001W Dear Mr. Torres: On January 15, 2015, Pipeline and Hazardous Materials Safety Administration (PHMSA) issued Colorado Interstate Gas (CIG) a Warning letter for the case number referenced above. This Notice cited CIG for a violation of Section 192.935(a), for failing to conduct the required risk analysis and implement additional P&M (preventive and mitigative) measures to protect HCAs (high consequence areas) in a timely manner. CIG responded to the Notice by letter dated February 20, 2015. In its response, CIG noted that §192.935(a) does not specify a deadline by which compliance must be achieved, and stated that it had voluntarily updated its analysis of all valves protecting HCAs in 2012 and scheduled installation of valves where response time to an HCA exceeded one hour. The company also provided information regarding automatic shut-off valves and remote control valves that it had installed in 2014. PHMSA hereby withdraws the Notice and the case is now closed. PHMSA will review CIG’s integrity management plan, schedule for implementation, and P&M measures related to this risk assessment at a future inspection. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: Jessica Toll, Esq. Gary Buchler, Vice President, Engineering and Operations of KMI Pipeline Benjamin Fred, PHMSA Hearing Officer 2 520151001W_warning letter_01152015_text.pdf WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 15, 2015 Mr. Gary Buchler Vice President Engineering and Operations of KMI Pipeline Colorado Interstate Gas 1001 Louisiana Street Houston, TX 77002 CPF 5-2015-1001W Dear Mr. Buchler: During the weeks of April 8, 2013 and April 28, 2014, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Colorado Interstate Gas (CIG) facilities in the Pueblo Area of Colorado. 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. §192.935 What additional preventive and mitigative measures must an operator take? (a) General requirements. An operator must take additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area. An operator must base the additional measures on the threats the operator has identified to each pipeline segment. (See § 192.917) An operator must conduct, in accordance with one of the risk assessment approaches in ASME/ANSI B31.8S (incorporated by reference, see § 192.7), section 5, a risk analysis of its pipeline to identify additional measures to protect the high consequence area and enhance public safety. Such additional measures include, but are not limited to, installing Automatic Shut-off Valves [ASO] or Remote Control Valves [RCV], installing computerized monitoring and leak detection systems, replacing pipe segments with pipe of heavier wall thickness, providing additional training to personnel on response procedures, conducting drills with local emergency responders and implementing additional inspection and maintenance programs. CIG failed to implement the ASV and RCV study in a timely manner for adding protection to a high consequence area. The effective date of the Integrity Management regulations was December 2003. Part 192.935(a) requires a risk analysis be conducted per Section 5, ASME B31.8S to identify additional measures for protecting the high consequence area. Subsequently, CIG conducted the "ASV and RCV Study." At the time of inspection, interviews CIG personnel revealed that CIG added either ASV or RCV as a preventive and mitigative (P&M) measures for seven (7) high consequence areas (HCAs) within the Pueblo Area in March 2012 and one (1) HCA in December 2006. However, time period for implementing the ASV and RCV study was too long to enhance public safety. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a 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(s) identified in this letter. Failure to do so will result in Colorado Interstate Gas 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 5-2015-1001W. 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. 2 552(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 Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 C. 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