# Colorado Interstate Gas Company, LLC — Pipeline Special Permit

**Citation:** PHMSA-2022-0038  
**Type / status:** permit / current  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** 2023-07-24  
**Published:** 2023-07-24

PHMSA-2022-0038, issued 2023-07-24 for Colorado Interstate Gas Company, LLC's gas transmission system.

## Document text

PHMSA pipeline special permit PHMSA-2022-0038. Operator: Colorado Interstate Gas Company, LLC. System: Gas Transmission. Issue date: 2023-07-24.

<<<PAGE 1>>>

U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
Special Permit Analysis and Findings
Class 1 to 3 Location
Special Permit Information:
Docket Number: PHMSA-2022-0038
Requested By: Colorado Interstate Gas Company, LLC
Operator ID#: 2564
Original Date Requested: March 1, 2022
Original Issuance Date: July 24, 2023, to July 24, 2033
Code Section(s): 49 CFR 192.611(a) and (d) and 192.619(a)
Purpose:
The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS),
1 provides this information to describe the facts of the subject special permit application
submitted by Colorado Interstate Gas Company, LLC (CIG)2 to discuss any relevant public comments
received with respect to the application, to present the engineering and safety analysis of the special
permit application, and to make findings regarding whether the requested special permit should be
granted and, if so, under what conditions. CIG requested that PHMSA waive compliance from the 49
Code of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for a natural gas transmission
pipeline segment, where the class location has changed from Class 1 to a Class 3 location.
Pipeline System Affected:
This special permit application by CIG requests a waiver from the class location change requirements
in 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 1.40 miles of the 24-inch diameter
1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s
Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.
2 CIG is a wholly owned subsidiary of Kinder Morgan, Inc.
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 1 of 10

<<<PAGE 2>>>

Denver-Rock Springs Loop Pipeline located in Adams County, Colorado.
Pipe specifications including outside diameter, year installed, seam type, coating type, pipe grade, wall
thickness, maximum allowable operating pressure (MAOP), minimum pressure test pressure, and
pressure test factor based on the minimum test pressure are detailed in Table 1 – Pipe Specifications
by Line Name.
Table 1 – Pipe Specifications by Line Name
Minimum
Outside
Line Name
Diameter
Year
Installed Seam Type Coating Type Grade Wall Thickness
(inches)
MAOP
Test
Pressure
(psig)
Pressure
Test Factor
(inches)
Denver-Rock
Springs Loop 24 1978 ERW-HF Tape X60 0.25 850 (psig)
1,112 1.31
Without this special permit, 49 CFR 192.611(a) would require CIG to replace the special permit
segment with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location change.
Special Permit Request:
On March 1, 2022, CIG applied to PHMSA for a special permit seeking relief from 49 CFR 192.611(a)
and (d) and 192.619(a) for the below-listed special permit segment, where a class location change
occurred from the original Class 1 to a Class 3 on the 24-inch diameter Denver-Rock Springs Loop
Pipeline located in Adams County, Colorado.
CIG’s special permit applies to the special permit segment and special permit inspection area
described and defined as follows, using the CIG survey station references:
Special Permit Segment:
This special permit applies to the special permit segment in Table 2 – Special Permit Segment and
are identified using the CIG mile post (MP) and survey station (SS) references.
Table 2 – Special Permit Segment
Special
Outside
Permit
Diameter
Line Name Length
(feet)
Start Survey
Station
End Survey
Station
County,
State
No.
Year
Seam
MAOP
Segment
Number
Dwellings
Installed
Type
(psig)
(inches)
(MP - SS)
(MP -SS)
650 24 Denver-Rock
Springs Loop 7,387 004 - 3085 005 - 5192 Adams, CO 9 1978 ERW-
HF 850
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 2 of 10

<<<PAGE 3>>>

Special Permit Inspection Areas:
The special permit inspection area is defined as the area that extends 220 yards on each side of the
centerline as listed in Table 3 – Special Permit Inspection Area.
Table 3 – Special Permit Inspection Area
Special
Special
Outside
Permit
Permit
Diameter
Line Name Inspection
Start Survey Station
(MP - SS)
End Survey Station
(MP - SS)
Length3
(miles)
Area Number
Segment(s)
Included
(inches)
1 650 24 Denver-Rock
Springs Loop 004 - 2161.73 085 - 3469 81
Public Notice:
On May 27, 2022, PHMSA posted a notice of this special permit request in the Federal Register (87 FR
32235) with a closing date of June 27, 2022. PHMSA received no public comments concerning this
special permit request through June 27, 2022.
The CIG special permit application letter, Federal Register notice, FEA, Finding of No Significant
Impact, and all other pertinent documents are available for review in Docket No. PHMSA-2022-0034
in the Federal Docket Management System (FDMS) located at www.Regulations.gov.
Analysis:
Background: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the criteria
it uses for the consideration of applications for class location change waivers, now being granted or
denied through a special permit. First, certain threshold requirements should be met on a pipeline
special permit segment for a class location change special permit to be granted. Second, the age and
manufacturing process of the pipe; system design, and construction; environmental, operating and
maintenance histories; and integrity management program elements are evaluated as significant criteria.
These significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket No.
PHMSA–RSPA-2004-17401. Third, special permits will only be granted when pipe conditions and
active integrity management provide a level of safety greater than or equal to a pipe replacement or
3 If the special permit inspection area footage does not extent from launcher to receiver, then the special permit
inspection area would need to be extended.
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 3 of 10

<<<PAGE 4>>>

pressure reduction. The operator’s Federal pipeline safety regulation compliance history is also
evaluated as part of the criteria matrix for acceptability prior to issuance of a special permit.
Threshold Requirements: Each of the threshold requirements published by PHMSA in the June 29,
2004, Federal Register notice is discussed below regarding the CIG special permit request.
• No pipeline segment in a class location changing to Class 4 location will be considered.
• This special permit request is for one (1) special permit segment where a change has occurred
from a Class 1 location to a Class 3 location.
• CIG meets this requirement.
• No bare pipe will be considered.
• The special permit segment is externally coated with polyethylene tape.
• CIG meets this requirement.
• No pipe containing wrinkle bends will be considered.
• There are no reported wrinkle bends in the special permit segment.
• CIG meets this requirement.
• No pipe segment operating above 72% of the specified minimum yield strength (SMYS) will be
considered for a Class 3 special permit.
• The special permit segment operates at or below 72% SMYS.
• CIG meets this requirement.
• Records must be produced that show a hydrostatic test to at least 1.25 time the MAOP. The records
should include test pressure, year of the test, test duration, and pressure test percent of MAOP for
each pipeline:
• CIG has communicated that the special permits segment has been tested to at least 1.25 times
the MAOP.
• CIG meets this requirement.
• In-line inspection (ILI) must have been performed with no significant anomalies identified that
indicate systemic problems such as stress corrosion cracking (SCC).
• CIG ran a high-resolution magnetic flux leakage (HR-MFL) ILI for corrosion and
deformation ILI for denting.
• CIG meets this requirement.
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 4 of 10

<<<PAGE 5>>>

• Criteria for consideration of a class location change waiver, being considered through the special
permit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver inspection
area (special permit inspection area) as up to 25 miles of pipe on either side of the waiver segment
(special permit segment).
• CIG has identified longer segment surrounding each special permit segment as the special
permit inspection area. This segment has been extended to the entire segment length between
the upstream launcher and downstream receiver for the ILI segment that contains the special
permit segment.
Criteria Matrix: The data submitted by CIG for the special permit segment have been compared to the
class location change special permit criteria matrix.
• The following special permit segment fall in the probable acceptance column of the criteria
matrix for:
o Design stress, depth of pipe cover, test pressure, test failures, local geology, type of
service, pressure fluctuations, safety related conditions, direct assessment, ILI type, and
damage prevention program.
• The following special permit segment fall in the possible acceptance column of the criteria
matrix for:
o Pipe manufactured in 1978, class location change, coating type (polyethylene tape
coating may shield CP when disbanded and lead to SCC4)
Operational Integrity Compliance:
To inform PHMSA’s decision about whether a special permit could provide a level of safety greater
than or equal to a pipe replacement or pressure reduction and is consistent with pipeline safety,
PHMSA reviewed this special permit request to understand the known type of integrity threats that are
in the special permit segment and special permit inspection area. This integrity information was used
to consider special permit conditions to provide a systematic program to review and remediate the
pipeline for safety concerns. Additional operational integrity review and remediation requirements are
required by this special permit to ensure that the operator has an ongoing program to locate and
4 Two (2) types of SCC are found on pipelines: high pH (9 to 11) SCC and near-neutral pH (6 to 8) SCC. Polyethylene tape
coatings that are disbonded are more prone to have SCC.
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 5 of 10

<<<PAGE 6>>>

remediate safety threats. These threats to integrity and safety include any issues with the pipe coating
quality, cathodic protection effectiveness, operations damage prevention program, pipe depth of soil
cover, weld seam and girth weld integrity, anomalies in the pipe steel and welds, and material and
structures either along or near the pipeline that could cause the cathodic protection system to be
ineffective. PHMSA has carefully designed a comprehensive set of conditions that CIG must
implement to comply with this special permit.
Past Enforcement History – January 1, 2012, through January 22, 2023:
During January 1, 2012, through January 22, 2023, CIG was cited in five (5) enforcement actions with a total
of $154,800 in assessed civil penalties. PHMSA issued one (1) Notice of Amendment, one (1) Notice of
Probable Violation, and three (3) Warning Letters to CIG. Tables 4 and 5 below shows PHMSA’s
enforcement actions and civil penalties for CIG:
Table 4 - CIG Enforcement Matters from
January 1, 2012, through January 22, 2023
Notice of
Status Corrective
Action Order
Notice of
Probable
Amendment
Safety
Order
Warning
Letter Total
Violation
CLOSED 0 1 1 0 3 5
OPEN 0 0 0 0 0 0
Total 0 1 1 0 3 5
Table 5 - CIG Enforcement Civil Penalty Status
January 1, 2012, through January 22, 2023
Proposed Awaiting Order Assessed Withdrawn/Reduced Collected
$198,000 $154,800 $43,200 $154,800
Summary of Enforcement Findings for CIG includes:
• Corrosion Control: Records; Integrity Management: High Consequence Area – Integrity Actions
and Preventative and Mitigative Measures; OME Procedural Manual: General and Maintenance
and Normal Operations; Operations and Maintenance: Overpressure safety devices and overfill
protection systems, Valve Maintenance, and General; Reporting: Immediate Reporting Incident;
Transportation of Gas: Conversion to Service.
• 49 CFR 191.5, 191.14, 192.461, 192.475, 192.491, 192.603, 192.605, 192.745, and 192.935.
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 6 of 10

<<<PAGE 7>>>

Table 6 below shows PHMSA’s enforcement actions and civil penalties for CIG and the specific 49 CFR
Parts 191 and 192 violations:
Table 6 - Summary of Enforcement Findings from CIG
January 1, 2012, through January 22, 2023
Notice of Amendment
OME Procedural Manual 1 Reporting 1 Transportation of Gas 1
Notice of Amendment Total: 3
Notice of Probable Violation
Integrity Management 3 Operation and/or Maintenance 2
Notice of Probable Violation Total: 5
Warning Letter
Corrosion Control 1 Integrity Management 1 OME Procedural Manual 1
Operation and/or Maintenance 1
Warning Letter Total: 4
Grand Total: 12
Summary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG, EPNG,
NGPL, SNG, Tejas, and CIG:
From January 1, 2012, through January 22, 2023, Kinder Morgan, the operator of CIG, was cited in 64
enforcement actions with a total of $979,900 in assessed civil penalties on its Colorado Interstate Gas
Company (CIG), El Paso Natural Gas Company (EPNG), Natural Gas Pipeline of America (NGPL),
Southern Natural Gas Company (SNG), Tejas Pipeline (Tejas), and Tennessee Gas Pipeline Company (CIG)
pipeline systems. PHMSA issued seven (7) Corrective Action Orders, 15 Notice of Amendments, 20 Notices
of Probable Violations, and 22 Warning Letters to Kinder Morgan.
Tables 7 and 8 below show PHMSA’s enforcement actions and civil penalties for Kinder Morgan on
these pipeline systems – CIG, EPNG, NGPL, SNG, Tejas, and CIG - with operator identification
numbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160.
Table 7 - Kinder Morgan Enforcement Matters from
January 1, 2012, through January 22, 2023
Notice of
Status Corrective
Action Order
Notice of
Safety
Probable
Amendment
Order
Warning
Letter Total
Violation
CLOSED 3 15 20 0 22 60
OPEN 4 0 0 0 0 4
Total 7 15 20 0 22 64
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 7 of 10

<<<PAGE 8>>>

Table 8 - Kinder Morgan Enforcement Civil Penalty Status
January 1, 2012, through January 22, 2023
Proposed Awaiting Order Assessed Withdrawn/Reduced Collected
$1,363,600 $0 $979,900 $383,700 $979,900
The type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline
systems from January 1, 2012, through January 22, 2023, were as follows:
Summary of Enforcement Findings for CIG, EPNG, NGPL, SNG, Tejas, and CIG includes:
• Atmospheric Corrosion Control: General and Monitoring; Construction: Compliance with
Standards; Control Room Management: Alarm Management and Fatigue Mitigation; Design:
Supports and Anchors; External Corrosion Control: Cathodic Protection, Examination of Buried
Pipe, Monitoring, and Test Stations; Gas Transportation: Conversion of Service and Underground
Natural Gas Storage; Internal Corrosion Control: Inspection Internal Surface; Integrity
Management: Addressing Integrity Issues, Continual IM Baseline Assessment, Continual Process
of Evaluation and Assessment, High Consequence Area (HCA) Identification, HCAs – Integrity
Actions, Preventative and Mitigative Measures, and Threat Identification; Maintenance:
Compressor Stations-Gas Detection, Compressor Stations-Inspection and Testing of Relief Devices,
Compressor Stations-Storage of Combustible Materials, Line Markers, Leak Surveys, Pressure
Limiting and Regulating Stations Inspection and Testing, Relief Devices, Patrolling, Record
Keeping, and Valve Maintenance; OME Procedural Manual: General and Maintenance and
Normal Operations; Operations and Maintenance: Overpressure safety devices and overfill
protection systems and Valve Maintenance; Operations: Change in Class Location, Continual
Surveillance, Emergency Plans, General, MAOP, and Odorization of Gas; Operator Qualification:
Qualification Program and Recordkeeping; Public Awareness: Develop and Implement Public
Awareness, Documentation available for Review, Follow API RP 1162, Justification for not
following API RP 1162, Language Used, and Specifics addressing the Public; Reporting: Filing
SRCR, Incident Reports, Immediate Reporting Incident, National Registry of Pipeline and LNG
Operators, Offshore Pipeline Condition Report; Welding: Limitations on Welders and Procedures.
• 49 CFR 191.3, 191.5, 191.15, 191.22, 191.23, 191.25, 191.27, 192.3, 192.12, 192.14, 192.161,
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 8 of 10

<<<PAGE 9>>>

192.201, 192.225, 192.227, 192.229, 192.303, 192.459, 192.461, 192.463, 192.465, 192.469,
192.475, 192.479, 192.481, 192.603, 192.605, 192.611, 192.613, 192.615, 192.616, 192.619,
192.625, 192.631, 192.705, 192.706, 192.707, 192.709, 192.713, 192.731, 192.735, 192.736,
192.739, 192.743, 192.745, 192.805, 192.807, 192.905, 192.917, 192.921, 192.933, 192.935,
and 192.937.
Table 6 below gives a complete summary of the findings and the specific 49 CFR Parts 191 and 192
violations:
Table 9 - Summary of Enforcement Findings for
CIG, EPNG, NGPL, SNG, Tejas, and CIG
January 1, 2012, through January 22, 2023
Notice of Amendment
Construction 1 Control Room Management 4 Integrity Management 2
OME Procedural Manual 6 Operation and/or Maintenance 2 Operator Qualification 3
Public Awareness 8 Reporting 3 Transportation of Gas 5
Welding of Steel in Pipelines 1
Notice of Amendment Total: 35
Notice of Probable Violation
Corrosion Control 6 Integrity Management 9 OME Procedural Manual 11
Operation and/or Maintenance 14 Operator Qualification 8 Public Awareness 2
Reporting 4 Welding of Steel in Pipelines 2
Notice of Probable Violation Total: 56
Warning Letter
Corrosion Control 13 Design 1 Integrity Management 1
OME Procedural Manual 13 Operation and/or Maintenance Public Awareness 4 Reporting 43 Warning Letter Total: Operator Qualification 4
4 Transportation of Gas 1
84
Grand Total: 167
Findings:
Based on the information submitted by CIG and PHMSA’s analysis of the technical, operational, and
safety issues, PHMSA finds that granting this special permit with conditions that requires CIG to
operate the special permit segment on 24-inch diameter Denver-Rock Springs Loop Pipeline located in
Adams County, Colorado at its current MAOP for a Class 1 to Class 3 location change would not be
inconsistent with pipeline safety.
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 9 of 10

<<<PAGE 10>>>

PHMSA has designed the special permit conditions to effectively assess and remediate threats to the
special permit segment and special permit inspection area, including pressure testing, obtaining pipe
material records, and conducting assessments to evaluate pipe girth welds that have not been non-
destructively tested, any pipe with missing material records, and SCC. To ensure CIG properly
implements the special permit conditions, CIG will be required to give PHMSA an annual review of
their compliance with the special permit.
PHMSA finds the issuance and full implementation of this special permit that waives the requirements
of 49 CFR 192.611(a) and (d) and 192.619(a) for a class location change to a Class 3 location is not
inconsistent with pipeline safety. This special permit requires CIG to implement the special permit
conditions that include safety requirements on the operations, maintenance, and integrity management
of the special permit segment and the special permit inspection area. CIG will be required to
implement the special permit conditions along the special permit segment and special permit
inspection area in pipeline segments that are not high consequence areas and would not normally be
required by 49 CFR Part 192 to be assessed on a periodic interval for threats.
Completed in Washington DC on: July 24, 2023
Prepared by: PHMSA - Engineering and Research Division
PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado
Page 10 of 10

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
July 24, 2023
Kenneth W. Grubb
Chief Operating Officer
Kinder Morgan Natural Gas Division
1001 Louisiana Street, Suite 1000
Houston, Texas 77002
Re: Docket No. PHMSA-2022-0038
Special Permit from July 24, 2023, to July 24, 2033
Dear Mr. Grubb:
On March 1, 2022, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Colorado
Interstate Gas Company, LLC (CIG)1 applied to the Pipeline and Hazardous Materials Safety
Administration (PHMSA) for a special permit. CIG requested a special permit to waive compliance
with 49 CFR §§ 192.611(a) and (d), and 192.619(a) for Class 1 to Class 3 location changes on one
(1) pipeline segment for approximately 1.40 miles of 24-inch diameter gas transmission pipeline
(Pipeline) located in Adams County, Colorado. A gas transmission pipeline operator is required by
49 CFR § 192.611 to confirm or revise the maximum allowable operating pressure of a pipeline
segment where the class location has changed as defined in 49 CFR § 192.5.
On May 27, 2022, PHMSA published a Federal Register notice (87 FR 32235) announcing the
Special Permit Request. The Special Permit Request letter, Final Environmental Assessment
(FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings
(SPAF), and all other pertinent documents for this special permit are available in Docket No.
PHMSA-2022-0038 in the Federal Docket Management System located at www.regulations.gov.
2
Subject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based on
the information provided by CIG and the findings set forth in the SPAF, FEA, and FONSI. This
special permit provides relief from certain provisions of the Federal pipeline safety regulations for
the Pipeline and requires CIG to comply with conditions and limitations designed to maintain
pipeline safety as defined in the special permit. Note that in accordance with 49 CFR § 190.341(j),
1 Colorado Interstate Gas Company, LLC is owned by Kinder Morgan, Inc.
2 https://www.regulations.gov/docket?D=PHMSA-2022-0038.

<<<PAGE 2>>>

PHMSA reserves the right to revoke, suspend, or modify this special permit if circumstances occur
in which its continuance would be inconsistent with pipeline safety. If CIG elects not to implement
the special permit conditions, CIG must notify PHMSA within 60 days and comply with 49 CFR
§ 192.611 within 18 months of the date of this letter.
My staff is available to discuss this special permit or any other regulatory matter with you. Mary
McDaniel, Acting Director of PHMSA Engineering and Research Division, may be contacted at
713-272-2847, on technical matters; and James Urisko, Director, Office of Pipeline Safety,
Southern Region, may be contacted at 404-832-1150, for operational matters specific to this
special permit.
Sincerely,
Alan K. Mayberry
Associate Administrator for Pipeline Safety
Enclosure: Special Permit – PHMSA-2022-0038
Special Permit: PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Letter of Decision – Class 1 to 3 Location – Colorado
Page 2 of 2

## Provenance

- Official: Yes
- Source: <https://www.regulations.gov/docket/PHMSA-2022-0038>
- Source ID: `phmsa-special-permits`
- SHA-256: `913c6508d4110d2145c6a43f71c679d36ea71b1c1252b9ce18fdbd5d1ffa290e`
- Retrieved: 2026-08-20T01:06:17.853Z
- Exported: 2026-08-23T19:23:36.899Z
- Document slug: `phmsa-special-permit-phmsa-2022-0038`

### Source metadata

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