NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Notice of Amendment

party submissionOfficial PDF120201006M_Operator Response to Notice_01292020.pdf#

120201006M_Closure Letter_02072020_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY February 7, 2020 Mr. Kenneth Grubb Chief Operating Officer Natural Gas Pipeline Co of America (KMI) 1001 Louisiana Street, Suite 1000 Houston, TX 77002 CPF 1-2020-1006M Dear Mr. Grubb: From August 6 - 8, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Natural Gas Pipeline Co of America’s (NGPL) Cairo Storage Fields and its Underground Gas Storage Facility (UNGS) Program in Columbus City, IA. As a result of the inspection, NGPL was issued a Notice of Amendment on January 2, 2020, which proposed amendment of your procedures. NGPL submitted its amended procedures on or about January 30, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

120201006M_Notice of Amendment_01022020_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY January 2, 2020 Mr. Kenneth Grubb Chief Operating Officer Natural Gas Pipeline Co of America (KMI) 1001 Louisiana Street, Suite 1000 Houston, TX 77002 CPF 1-2020-1006M Dear Mr. Grubb: From August 6 - 8, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Natural Gas Pipeline Co of America’s (NGPL) Cairo Storage Fields and its Underground Gas Storage Facility (UNGS) Program in Columbus City, IA. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within NGPL’s plans or procedures, as described below: 1. § 192.12 Underground natural gas storage facilities. (a) …. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. NGPL’s written procedures for implementing the requirements of API RP 1171 were inadequate. Specifically, NGPL failed to establish procedures to evaluate any annular gas occurrence that#

120201006M_Notice of Amendment_01022020_text.pdf, page 2CPF 1-2020-1006M exceeds its established threshold in accordance with API RP 1171, Section 9.3.2 Well Integrity Monitoring. Section 9.3.2 states in part: The operator shall monitor for presence of annular gas by measuring and recording annular pressure and/or annular gas flow. The operator shall evaluate each annular gas occurrence that exceeds operator - or regulatory-defined threshold levels determined from well integrity evaluation and from risk assessment. At the time of the inspection, NGPL procedures failed to address the requirement of API RP 1171, Section 9.3.2, for evaluating each annular gas occurrence that exceeds operator defined thresholds. In addition, it was noted that NGPL had established thresholds that exceeded the MAOP of the storage field. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. 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. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Natural Gas Pipeline Co of America maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2020-1006M on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office. 120201006M_Notice of Amendment_01022020_text Page 2 of 3#

120201006M_Notice of Amendment_01022020_text.pdf, page 3CPF 1-2020-1006M Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings 120201006M_Notice of Amendment_01022020_text Page 3 of 3#