{"operation":"document","citation":"CPF 520181008W","title":"SOUTHWEST GAS TRANSMISSION COMPANY A LIMITED PARTNERSHIP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-19","effective_on":null,"summary":"CLOSED warning letter citing 192.805(a), 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520181008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520181008W","body":"Warning Letter involving SOUTHWEST GAS TRANSMISSION COMPANY A LIMITED PARTNERSHIP. PHMSA's enforcement data identifies the cited regulations as 192.805(a),  192.805(b). The case was opened on 2018-11-19 and is reported as closed as of 2018-11-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520181008W_Operator Response to Notice_12202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181008W/520181008W_Operator%20Response%20to%20Notice_12202018.pdf\n\n520181008W_Warning Letter_11192018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181008W/520181008W_Warning%20Letter_11192018.pdf\n\n520181008W_Warning Letter_11192018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520181008W/520181008W_Warning%20Letter_11192018_text.pdf\n\n520181008W_Warning Letter_11192018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 19, 2018\nMr. Jeffrey W. Shaw\nVice President of Regulation & Public Affairs\nSouthwest Gas Corporation\n5241 Spring Mountain Road\nP.O. Box 98510\nLas Vegas, Nevada 89193-8510\nCPF 5-2018-1008W\nDear Mr. Shaw:\nOn April 24 through 28, 2017, a representative of the Arizona Corporation Commission (ACC),\npursuant to Chapter 601 of 49 United States Code, inspected and reviewed records for Southwest\nGas Transmission Company’s (SGTC), an affiliate of Southwest Gas Corporation, pipeline. This\nis a 9.5-mile, 20-inch interstate natural gas pipeline in Mohave County, Arizona. The pipeline\nstarts at a connection to El Paso Gas in Arizona and terminates at the Arizona-Nevada border\nwhere a SGTC intrastate segment begins.\nAs a result of the inspection, it is alleged the following probable violation of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations (CFR) has been committed:\n1. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) Identify covered tasks;\n(b) Ensure through evaluation that individuals performing covered tasks are\nqualified;\nSGTC’s Operator Qualification (OQ) Program pursuant to its procedures and covered task list,\nidentified the Control Room Supervisor as being required to have the same covered task\nqualifications as the Gas Control Technician. The OQ covered tasks for both the Control Room\nSupervisor and the Gas Control Technician included SCADA Monitoring, Starting, Operating,\n\n\n\nShut Down, Alarm Management, Opening & Closing Valves, Abnormal Operating Conditions\nand Communication Plan for Manual Operation.\nThe ACC representative reviewed the OQ records and discovered that the Control Room\nSupervisor did not have the proper qualifications according to the procedures and covered task\nlist. During discussions with Control Room personnel, it was disclosed that the Control Room\nSupervisors are not being OQ qualified on the covered tasks listed above. Based on this\ninformation, SGTC was not following its OQ Program.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2018-1008W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nKim West\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H.M. Flaherty (#161967)\nJames Lantto, Southwest Gas Corporation, Administrator/Compliance, Engineering\nService\n2","truncated":false,"body_characters":4317}