{"operation":"document","citation":"CPF 220061007H","title":"TENNESSEE GAS PIPELINE COMPANY — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2006-07-27","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220061007h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220061007h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220061007h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220061007H","body":"Corrective Action Order involving TENNESSEE GAS PIPELINE COMPANY. The dataset does not identify a cited regulation for this case. The case was opened on 2006-07-27 and is reported as closed as of 2007-06-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220061007H_Corrective Action Order_07272006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220061007H/220061007H_Corrective%20Action%20Order_07272006.pdf\n\n220061007H_Corrective Action Order_07272006.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nJUL 2 7 2006\nMr. David Jones\nVice President, Eastern Operations\nTennessee Gas Pipeline\nAn Affiliate of El Paso Corporation\n2 Brentwood Commons, Suite 190\nBrentwood, TN 37027\nRe: CPF No. 2-2006-3 007 H\nDear Mr. Jones:\nEnclosed is a Corrective Action Order issued by the Acting Associate Administrator for\nPipeline Safety in the above-referenced case. It requires you to take certain corrective actions\nwith respect to the operation of your 24-inch transmission pipeline Line 100-1, which extends\nfrom Campbellsville, Kentucky to Clay City, Kentucky. Service is being made by certified mail\nand facsimile. Your receipt of the enclosed document constitutes service of that document. The\nterms and conditions of this Final Order are effective upon receipt.\nSinc ely,\n/ \"f\nb an^^ Registry\nOffice of Pipeline Safety\nEnclosure\nVIA CERTIFIED MAIL (RETURN RECEIPT REQUESTED) AND TELECOPY\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\nIn the Matter of\nTENNESSEE GAS PIPELINE, An Affiliate of El Paso Corporation\nRespondent\nCPF NO. 2-2006-1007H\n1\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order is being issued, under authority of 49 U.S.C. 5 601 12, to require\nTennessee Gas Pipeline (Respondent), an affiliate of El Paso Corporation (El Paso), to take the\nnecessary corrective action to protect the public and environment from potential hazards\nassociated with its 24-inch natural gas transmission pipeline that extends from Carnpbellsville,\nKentucky to Clay City, Kentucky (hereinafter referred to as Line 100-1).\nOn July 22,2006, a failure occurred on Respondent's 24-inch Line 100-1 pipeline approximately\nsix miles southeast of Clay City, Kentucky, resulting in the release and ignition of natural gas.\nThe cause of the failure is unknown. Pursuant to 49 U.S.C. 5 60 1 17, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety, Southern Region and the\nKentucky Public Service Commission initiated an investigation of this failure.\nPreliminarv Findings\n1. At approximately 12:30 p.m. EDT, on July 22,2006, a segment of Respondent's 24-inch\nLine 100-1 ruptured, resulting in an estimated release of 42,946 MSCF of natural gas\nnear Clay City in Clark County, Kentucky. A fire ensued and was extinguished at 1:33\np.m. EDT.\n2. The rupture and fire occurred at Mile Post 105.1 +3.7, approximately 6 miles southeast of\nClay City, Kentucky, 1 1 miles southeast of Winchester, Kentucky and 1 1 miles northeast\nof Mount Sterling, Kentucky.\n\n\n\n2\nNo injuries or fatalities occurred. Three (3) homes were evacuated and minor damage\noccurred on nearby property.\nThe preliminary investigation indicates external pitting corrosion in an area\napproximately 2 - 3 feet long near the fracture, and within about 2 - 4 inches of the\nlongitudinal seam. The fracture followed the edge of the longitudinal seam in the area of\nthe pitting.\nFollowing the July 22, 2006 failure, Respondent's personnel isolated the segment of\npipeline involved in the failure by closing the nearest upstream mainline block valve\n(MLV 105-1) at 1:26 p.m. and isolation valves at the nearest downstream valve at\nCompressor Station 106 at 1:07 p.m. MLV 105-1 is located approximately four miles\nupstream of the failure site. Compressor Station 106 is located approximately two miles\ndownstream of the failure site.\nThe failure occurred in a 90 mile section between Respondent's Campbellsville,\nKentucky Compressor Station 96 and the Clay City, Kentucky Compressor Station 106,\napproximately 2 miles upstream of the Clay City Station.\nApproximately 25 feet of pipe blew out of the ground and landed about 200 feet on the\nhill from the failure site on or near the Respondent's 800 system right-of-way. The\nsection of pipe was twisted and mangled. External coating was completely burned off the\nsection of pipe that was blown out of the ground.\nThe 84 mile long section of Line 100-1 upstream of the failure valve section is under\npressure. The six miles long failure valve section is currently depressurized and out of\nservice.\nAt the time of the incident, the Line 100-1 pressure at a meter station located 21 miles\nupstream was 721 psig. The estimated failure site pressure was 716 psig. The maximum\nallowable operating pressure (MAOP) of this line segment is 750 psig.\nThe investigation is ongoing. The failed pipe segment along with adjacent pieces was\ntransported to El Paso's metallurgical laboratory located in Dearborn, Michigan for\nfurther analysis.\nThe Line 100-1 pipeline was installed in 1944 and is constructed of 24-inch x 0.250-inch\nw.t., API 5L-X50 pipe manufactured by A.O. Smith. The protective coating is coal tar\nenamel (TGF-2).\nThe pipeline is owned by El Paso's Pipeline Group, which owns and operates\napproximately 48,000 miles of natural gas pipeline. Respondent, an affiliate of El Paso,\noperates nearly 14,000 miles of pipeline, including approximately 1,508 pipeline miles of\ninterstate natural gas transmission lines in the state of Kentucky. Respondent's pipelines\n\n\n\n13. 14. 15. 16. 17. 5\ntraversing Kentucky include the 100 and 800 systems, of which a portion is located in\nshale terrain.\nLine 100- 1 passes through mostly rural areas in Kentucky, with some Class 2 and Class 3\nlocation areas, in addition to other populated areas designated as High Consequence\nAreas (HCAs). The pipeline also passes through large and small communities along the\nroute as well as crossing state and interstate highways, rivers, and streams. The failure\noccurred in a Class 2 location area.\nIn 1986, Respondent internally inspected the failed line section using a Tuboscope low-\nresolution magnetic flux leakage inline inspection (ILI) tool.\nThe pipeline failed in the bottom of a valley in an area of wet shale. Shale terrain in this\npart of Kentucky is known to cause corrosive environments on buried pipelines. A major\npipeline failure occurred on Respondent's 26-inch Line 100-3 on July 23, 1980,\napproximately three miles from the July 22, 2006 failure. The subsequent investigation\nrevealed that several operational and hydrostatic test pipeline failures had occurred on\nRespondents System 100 pipelines in shale terrain near Clay City, and were attributable\nto external bacterial corrosion.\nLine 100-1 was last pressure tested in 1986 at a minimum pressure of 940 psig for eight\nhours with no leaks. In 198 1, Line 100- 1 was pressure tested at a minimum pressure of\n974 psig for eight hours with no leaks. Line 100-1 was also pressure tested in 1971 at a\nminimum pressure of 938 psig for eight hours with two leaks. Line 100-1 was pressure\ntested in 1967 at a minimum pressure of 936 psig for twenty-four hours with two leaks.\nRespondent conveyed that an ILI run was scheduled to be run in the failed section during\nthe week of July 24,2006.\nDetermination of Necessitv for Corrective Action Order and Right to Hearing\nSection 601 12 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action as appropriate. The basis for making the\ndetermination that a pipeline facility is hazardous, requiring corrective action, is set forth both in\nthe above referenced statute and 49 C.F.R. 8190.233, a copy of which is enclosed.\nSection 601 12, and the regulations promulgated thereunder, provide for the issuance of a\nCorrective Action Order without prior opportunity for notice and hearing upon a finding that\nfailure to issue the Order expeditiously will result in likely serious harm to life, property or the\nenvironment. In such cases, an opportunity for a hearing will be provided as soon as practicable\nafter the issuance of the Order.\n\n\n\n4\nAfter evaluating the foregoing preliminary findings of fact, I find that the continued operation of\nthis pipeline without corrective measures would be hazardous to life, property and the\nenvironment. Additionally, after considering the age of the pipe, circumstances surrounding this\nfailure, the proximity of the pipeline to high consequence areas, the nature of the product the\npipeline transports, the pressure required for transporting the material, the uncertainties as to the\ncause of the failure, and the ongoing investigation to determine the cause of the failure, I find\nthat a failure to issue expeditiously this Order, requiring immediate corrective action, would\nresult in likely serious harm to life, property, and the environment.\nAccordingly, this Corrective Action Order mandating needed immediate corrective action is\nissued without prior notice and opportunity for a hearing. The terms and conditions of this Order\nare effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by telecopy at (202) 366-4566. The hearing will be held in Atlanta,\nGeorgia or Washington, D.C. on a date that is mutually convenient to PHMSA and Respondent.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other longer term measures that need to be taken. Tennessee Gas Pipeline will be\nnotified of any additional measures required and amendment of this Order will be considered.\nTo the extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Action\nPursuant to 49 U.S.C. 5 601 12, I hereby order Tennessee Gas Pipeline to immediately take the\nfollowing corrective actions with respect to its 24-inch transmission pipeline Line 100-1 :\n1. The operating pressure on Line 100- 1 at the failure location, including any gas pressure\nrequired to run ILI tools prior to resuming operation, is not to exceed 80 percent of the\noperating pressure in effect immediately prior to the July 22,2006 failure. Specifically, the\noperating pressure at the failure location is not to exceed 572.8 psig. This pressure restriction\nwill remain in effect until written approval to increase the pressure or return the pipeline to\nits pre-failure operating pressure is obtained from the Director, Southern Region, OPS. If the\nresults of any action undertaken pursuant to this Order dictate a reduction in the allowable\noperating pressure below that imposed by this Order, Respondent must further reduce the\noperating pressure accordingly.\n2. Conduct a detailed metallurgical analysis of the pipe that failed on July 22,2006 to determine\nthe cause and contributing factors.\nA. When handling and transporting the failed pipe section and any other evidence from\nthe failure site, document the chain-of-custody;\n\n\n\n3. 4. B. Obtain prior approval of the metallurgical testing protocol from the Director,\nSouthern Region, OPS; and\nC. Prior to commencing the metallurgical testing, provide the Director, Southern Region,\nOPS with the scheduled date, time, and location of the testing to allow a PHMSA\nrepresentative to witness it.\nD. Ensure that the laboratory distributes all resulting metallurgical reports, whether draft\nor final, to OPS at the same time as they are made available to Respondent.\nSubmit a written plan, with a schedule, to verify the integrity of the line segment from the\nCampbellsville Compressor Station 96 and Clay City Compressor Station 106. The plan\nmust provide integrity testing that addresses all known or suspected factors in the failure,\nincluding, but not limited to:\nA. ILI tool surveys and remedial action. The type of internal inspection tools used\nshall be technologically appropriate for assessing the system based on the type of\nfailure that occurred on July 22,2006, with emphasis on identifying and\nevaluating the following: 1) anomalies associated with dents, gouges and\ngrooves; 2) metal loss due to corrosion; 3) the orientation of the longitudinal\nseam of the pipe; 4) pipe deformation, and 5) longitudinal cracks, mill defects\nand stress corrosion cracking.\nB. A detailed description of the inspection and repair criteria that will be used in the\nfield evaluation of the anomalies that are excavated. This is to include a\ndescription of how any defects are to be graded and the schedule for repairs or\nreplacement.\nC. An evaluation of the line for areas of damaged or disbonded coating, including\nbut not limited to, a current interrupted close-interval survey.\nD. Integration of all available data from internal inspections, metallurgical analyses,\nand historical data, including repair and cathodic protection records.\nE. Hydrostatic pressure testing of the line segment and/or other mitigative\nmeasures required to address the cause and contributing factors to the July\n22,2006 pipeline failure.\nReview applicable historical, operational, maintenance and incident information on the 100\nand 800 System pipeline segments that traverse through shale terrain in Kentucky, along with\nthe results of the failure analysis required in Item 2. Determine if additional actions and/or\npreventive measures are necessary to reduce the risk of a failure similar the one that occurred\non July 22,2006. Information such as pipeline vintage, type of coating, prevalence of\ndisbonded coating, most recent ILI surveys, pressure test, close-interval survey should be\n\n\n\n5. 6. 7. 8. 6\nconsidered. Within 45 days, submit documentation to show completion to Director, Southern\nRegion, OPS.\nSubmit the plan required of Item 4 and the results of the requirements in Item 5 to: Director,\nSouthern Region, OPS, 233 Peachtree Street, Suite 600, Atlanta, GA 30303. The plan must\nbe revised, as necessary, to incorporate new information obtained during the failure\ninvestigation and remedial activities undertaken pursuant to this Order. Submit any such\nplan revisions to the Director for prior approval. The Director, Southern Region, OPS, may\napprove plan elements incrementally.\nImplement the plan as it is approved, including any revisions to the plan.\nThe Director, Southern Region, OPS, may allow the removal or modification of the pressure\nrestriction set forth in Item 1 upon a written request from Respondent demonstrating that the\nhazard has been abated and that restoring the pipeline to its pre-failure operating pressure is\njustified based on a reliable engineering analysis showing that the pressure increase is safe\nconsidering all known defects, anomalies and operating parameters of the pipeline. Appeals\nto determinations of the Director, Southern Region, OPS, will be subject to the decision of\nthe Acting Associate Administrator for Pipeline Safety.\nThe Director, Southern Region, OPS, may grant an extension of time for compliance with\nany of the terms of this order for good cause. A request for an extension must be in writing.\nThe corrective actions required by this Corrective Action Order are in addition to and do not\nwaive any requirements that apply to the pipeline under any other order issued to Respondent\nunder authority of 49 U.S.C. chapter 601, under 49 C.F.R. Part 191, or under any other provision\nof Federal or state law.\nFailure to comply with this Order may result in the assessment of civil penalties of up to\n$1 00,000 per violation per day pursuant to 49 U.S.C. 601 22, and in referral to the Attorney\nGeneral for imposition of civil judicial penalties or other appropriate relief in United States\nDistrict Court pursuant to 49 U.S.C. 60120.\nTheodore L. Wilke\nActing Associate Administrator\nfor Pipeline Safety\nDate Issued","truncated":false,"body_characters":16404}