{"operation":"document","citation":"CPF 520191009W","title":"TRANSCOLORADO GAS TRANSMISSION COMPANY LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-09-18","effective_on":null,"summary":"CLOSED warning letter citing 192.459, 192.475(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520191009W","body":"Warning Letter involving TRANSCOLORADO GAS TRANSMISSION COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 192.459,  192.475(b). The case was opened on 2019-09-18 and is reported as closed as of 2019-09-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520191009W_Operator Response to Notice_11062019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191009W/520191009W_Operator%20Response%20to%20Notice_11062019.pdf\n\n520191009W_Warning Letter_09182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191009W/520191009W_Warning%20Letter_09182019.pdf\n\n520191009W_Warning Letter_09182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191009W/520191009W_Warning%20Letter_09182019_text.pdf\n\n520191009W_Warning Letter_09182019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 18, 2019\nMr. Kenneth Grubb\nChief Operating Officer\nTransColorado Gas Transmission Co., LLC\n1001 Louisiana St., Suite 1000\nHouston, TX 77002\nCPF 5-2019-1009W\nDear Mr. Grubb:\nFrom July 22 through August 2, 2019, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected your TransColorado Gas Transmission (TCGT) pipeline in Colorado and New\nMexico.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violations are:\n1. § 192.459 External corrosion control: Examination of buried pipeline when\nexposed.\nWhenever an operator has knowledge that any portion of a buried pipeline is\nexposed, the exposed portion must be examined for evidence of external corrosion\nif the pipe is bare, or if the coating is deteriorated. If external corrosion requiring\n\n\n\nremedial action under §§192.483 through 192.489 is found, the operator shall\ninvestigate circumferentially and longitudinally beyond the exposed portion (by\nvisual examination, indirect method, or both) to determine whether additional\ncorrosion requiring remedial action exists in the vicinity of the exposed portion.\nIn September 2017, TransColorado replaced 180 feet of pipeline—the TCGT Blanco to El\nPaso Interconnect Replacement project. At the time of PHMSA’s inspection, there was no\nrecord of an external inspection record in a TransColorado Pipe Examination Report as\nrequired by 192.491 and 192.459. The removed pipe was still available for inspection, so\nduring the inspection, TransColorado personnel performed an external inspection per 192.459\nthat appears to be adequate and no significant corrosion was found.\n2. § 192.475 Internal corrosion control: General.\n(b) Whenever any pipe is removed from a pipeline for any reason, the internal\nsurface must be inspected for evidence of corrosion. If internal corrosion is\nfound—\n(1) The adjacent pipe must be investigated to determine the extent of internal\ncorrosion;\n(2) Replacement must be made to the extent required by the applicable\nparagraphs of §§192.485, 192.487, or 192.489; and\n(3) Steps must be taken to minimize the internal corrosion.\nIn September 2017, TransColorado replaced 180 feet of pipeline—the TCGT Blanco to El\nPaso Interconnect Replacement project. At the time of PHMSA’s inspection, there was no\nrecord of an internal inspection record in a TransColorado Pipe Examination Report as\nrequired by 192.491 and 192.475(b). The removed pipe was still available for inspection, so\nduring the inspection, TransColorado personnel performed an internal inspection per\n192.475(b) that appears to be adequate and no significant corrosion was found.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465\nfor a related series of violations. For violation occurring on or after November 27, 2018 and\nbefore July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day,\nwith a maximum penalty not to exceed $2,132,679. For violation occurring on or after\nNovember 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For\nviolations occurring prior to November 2, 2015, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 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 items identified in this\nletter. Failure to do so will result in TransColorado Gas Transmission Co. being subject to\nadditional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2019-1009W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Allen (#165452)","truncated":false,"body_characters":5748}