# PRODUCTS (SE) PIPE LINE CORPORATION — Safety Order

- **operation:** document
- **citation:** CPF 220155001S
- **title:** PRODUCTS (SE) PIPE LINE CORPORATION — Safety Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-03-09
- **effective on:** Not available
- **summary:** CLOSED safety order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220155001s.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220155001s.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220155001s
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220155001S
**body:**

Safety Order involving PRODUCTS (SE) PIPE LINE CORPORATION. The dataset does not identify a cited regulation for this case. The case was opened on 2015-03-09 and is reported as closed as of 2026-06-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220155001S_Closure Letter_06092026_(14-149971S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_Closure%20Letter_06092026_(14-149971S).pdf

220155001S_Closure Letter_06092026_(14-149971S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_Closure%20Letter_06092026_(14-149971S)_text.pdf

220155001S_Consent Agreement_05142015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_Consent%20Agreement_05142015.pdf

220155001S_Consent Agreement_05142015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_Consent%20Agreement_05142015_text.pdf

220155001S_Consent Order_08132015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_Consent%20Order_08132015.pdf

220155001S_Consent Order_08132015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_Consent%20Order_08132015_text.pdf

220155001S_NOPSO_03092015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_NOPSO_03092015.pdf

220155001S_NOPSO_03092015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220155001S/220155001S_NOPSO_03092015_text.pdf

220155001S_Consent Order_08132015_text.pdf

August 13, 2015
Mr. Steven J. Kean
President
Kinder Morgan, Inc.
1001 Louisiana St., Suite 1000
Houston, Texas 77002
Re: CPF No. 2-2015-5001S
Dear Mr. Kean:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement that was
signed on May 18, 2015, between PHMSA and Plantation Pipe Line Company, a subsidiary of
Kinder Morgan, Inc., in the above-referenced case. Service of the Consent Order and Consent
Agreement by certified mail is deemed effective upon the date of mailing, or as otherwise
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Wayne T. Lemoi, Director, Office of Pipeline Safety, Southern Region, PHMSA
Mr. Thomas A. Bannigan, President & CEO, Plantation Pipe Line Company, 1100
Alderman Drive #200, Alpharetta, Georgia 30005
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Plantation Pipe Line Company, ) CPF No. 2-2015-5001S
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated March 9, 2015, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) Office of Pipeline Safety issued a Notice of Proposed Safety Order (Notice) to
Plantation Pipe Line Company (Respondent) in this case.
In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist on
Respondent’s 665-mile CNG pipeline in Mississippi, Alabama, Georgia, South Carolina, and
North Carolina that pose a pipeline integrity risk to public safety, property, or the environment
and proposed that Respondent take certain actions to address the condition.
In response to the Notice, Respondent requested an informal consultation. Respondent and
PHMSA engaged in good faith settlement discussions resulting in the Consent Agreement
attached to this Order that settles all of the allegations in the Notice.
Accordingly, the foregoing Consent Agreement is hereby approved and incorporated by
reference into this Order. The Respondent is hereby ordered to comply with the terms of the
Consent Agreement, effective immediately.
Pursuant to 49 U.S.C. 60101 et seq., failure to comply with this Consent Order may result in the
assessment of civil penalties of up to $200,000 per violation per day, or in the referral of the case
for judicial enforcement. The terms and conditions of this Consent Order are effective upon
service in accordance with 49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

220155001S_Closure Letter_06092026_(14-149971S)_text.pdf

230 Peachtree Street N.W.
Suite 2100
Atlanta, GA 30303
404.832.1147
U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
VIA ELECTRONIC MAIL TO: Zach_Ragain@kindermorgan.com
June 9, 2026
Zach Ragain
Director- Engineering, of Codes and Standards
Products (SE) Pipe Line Corporation
1001 Louisiana Street
Suite 1000
Houston, TX 77002
Re: CPF 2-2015-5001S
Dear Mr. Ragain:
On August 13, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS), issued the above-referenced Consent Order to Products (SE) Pipe
Line, formerly Plantation Pipe Line Company. Products (SE) Pipe Line is a subsidiary of Kinder
Morgan, Inc.
This letter is to inform you that the above-mentioned Consent Order and resulting Consent
Agreement are now closed per the terms of the Order. Thank you for your cooperation throughout
this process.
Sincerely,
James Urisko
Director, Southern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration

220155001S_Consent Agreement_05142015_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 14, 2015
Mr. Ronald McClain
President
Products Pipelines
1001 Louisiana St., Suite 1000
Houston, TX 77002
CPF 2-2015-5001S
Dear Mr. McClain:
Enclosed for your signature is a Consent Agreement between the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety, Southern Region and
Plantation Pipe Line Company in accordance with §190.(b)(2). Once signed by both parties
the Associate Administrator for Pipeline Safety will issue a Consent Order, incorporating the
terms of the agreement, in lieu of the Safety Order proposed by the Southern Region via the
Notice of Proposed Safety Order referenced above.
Please sign the Consent Agreement and return the signed original to me. If you have any
questions on this matter or any other pipeline safety issue please call me at (404) 832-1160.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Consent Agreement



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
Southern Region
Atlanta, GA 30303
____________________________________
In the Matter of )
)
)
Plantation Pipe Line Company )
Respondent )
____________________________________)
) CPF 2-2015-5001S
CONSENT AGREEMENT
On March 9, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S.
Department of Transportation, issued to Plantation Pipe Line Company1 (PPL or Respondent) a
Notice of Proposed Safety Order (Notice). The Notice alleged that conditions exist on PPL's
665-mile CNG pipeline in Mississippi, Alabama, Georgia, South Carolina, and North Carolina
that pose a pipeline integrity risk to public safety, property, or the environment.
The Notice also proposed that Respondent take certain corrective measures to correct the alleged
conditions and ensure that the public, property, and the environment are protected from the
potential risk.
PPL responded to the Notice by letter dated April 8, 2015 (Response). Respondent
acknowledged receipt of the proposed safety order and requested an informal consultation,2
which was held on April 23, 2015, via a teleconference with the Office of Pipeline Safety,
Southern Region.
During the informal consultation, PHMSA and PPL agreed that settlement of this proceeding
will avoid further administrative proceedings or litigation and that entry into this Consent
Agreement is the most appropriate means of resolving the Notice; therefore, pursuant to 49
C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and
agreement of Respondent and PHMSA ("the Parties"), the Parties agree as follows:
I. General Provisions
1. Respondent acknowledges that as operator of the pipeline, Respondent and its pipeline
system are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101
et seq., and the regulations and administrative orders issued thereunder. For purposes of this
1 PPL is a subsidiary of Kinder Morgan, Inc.
2 PPL's Response is incorporated into this Consent Agreement in whole (see attached).



2
Consent Agreement, Respondent acknowledges that it received proper notice of PHMSA's action
in this proceeding and that the Notice states claims upon which relief may be granted pursuant to
49 U.S.C. 60101 et seq. and the regulations and orders issued thereunder.
2. Respondent does not admit or deny any allegation or conclusion in the Notice but agrees,
for purposes of this Consent Agreement, that the condition identified in the Notice exists and
agrees to address it by completing the actions specified in Section II of this agreement
(“Corrective Measures”). These actions, including any work plans and schedules, shall be
incorporated into this agreement. This Consent Agreement does not constitute a finding of
violation of any Federal law or regulation and therefore may not be used in any civil proceeding
of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of
any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this
agreement or in future PHMSA enforcement actions.
3. After Respondent returns this signed agreement, PHMSA's representative will present it to
the Associate Administrator for Pipeline Safety (“Associate Administrator”) recommending that
the Associate Administrator adopt the terms of this agreement by issuing an administrative order
(Consent Order) incorporating the terms of this Consent Agreement. The terms of this agreement
constitute an offer of settlement until accepted by the Associate Administrator.
4. Respondent consents to the issuance of the Consent Order, and hereby waives any further
procedural requirements with respect to its issuance. Respondent waives all rights to contest the
adequacy of notice, or the validity of the Consent Order or this Consent Agreement, including all
rights to administrative or judicial hearings or appeals.
5. This Consent Agreement shall apply to and be binding upon PHMSA, and upon
Respondent, its officers, directors, and employees, and its successors, assigns, or other entities or
persons otherwise bound by law. Respondent agrees to provide a copy of this agreement and any
incorporated work plans and schedules to all of Respondent's officers, employees, and agents
whose duties might reasonably include compliance with this agreement.
6. For all transfers of ownership or operating responsibility of Respondent’s pipeline,
Respondent must provide a copy of this Consent Agreement to the prospective transferee at least
30 days prior to such transfer and simultaneously provide written notice of the prospective
transfer to the PHMSA Regional Director who issued the Notice.
7. This Consent Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this agreement, and
the Parties acknowledge that there are no representations, agreements or understandings related
to the settlement other than those expressly contained in this agreement, except that the terms of
this agreement may be construed by reference to the Notice.
8. Nothing in this Consent Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101
et seq., and the regulations and orders issued thereunder. Nothing in this agreement alters
PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to
bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.
9. This Consent Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent's pipeline systems. This agreement is not a permit,



3
or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
10. This Consent Agreement does not create rights in, or grant any cause of action to, any third
party not party to this agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this agreement. The U.S.
Department of Transportation, its officers, employees, agents, and representatives are not liable
for any cause of action arising from any acts or omissions of Respondent or its contractors in
carrying out any work required by this agreement.
II. Corrective Measures
A. Within 30 days from the issuance of the Consent Order, submit to the Director, Office
of Pipeline Safety, PHMSA Southern Region an “Amended Comprehensive Steel
Sleeve Assessment Work Plan” (Amended Work Plan) for review and approval. This
Amended Work Plan will supersede the “Comprehensive Steel Sleeve Assessment Work
Plan” dated February 25, 2015, and, at a minimum, must include:
i. all the tasks described in PPL’s “Comprehensive Steel Sleeve Assessment Work
Plan” dated February 25, 2015;
ii. a milestone schedule to accomplish all the tasks in the Amended Work Plan
within one year after issuance of the Consent Order;
iii. a list of the 64 sleeves that PPL will excavate and inspect indicating the specific
segment (e.g. CNG-1 30-inch, Collins to Helena), type of sleeve, and identified
by mile post or stationing;
iv. a written process to integrate all the results from the 64 excavations, the
metallurgical assessments, and the Type “A” sleeve removals with the results
from the previously completed excavations/assessments and with the
metallurgical assessments of the two release locations and to apply the lessons
learned through this integration process to the remainder of the sleeves to
determine if further mitigation is required;
v. a commitment to complete the Kiefner and Associates study described in PPL’s
“Comprehensive Steel Sleeve Assessment Work Plan” dated February 25, 2015,
within six months after all tasks described within the “Amended Comprehensive
Steel Sleeve Assessment Work Plan” have been completed and that a copy of the
Final Report of that study will be submitted to the OPS Southern Region;
vi. a commitment to implement the recommendations contained in the Kiefner
report, if PPL disagrees with the recommendations in the Kiefner Report, PPL
reserves the right to discuss these recommendations with OPS Southern Region
and Kiefner and Associates; and,
vii. the name, phone number, and email address of PPL's point-of-contact for the
Amended Work Plan.
B. Provide to the OPS Southern Region all written metallurgical analysis reports resulting
from the work undertaken on the CNG pipeline as a result of the leaks of August and
December 2014 and all work completed under this Consent Order whether the reports
were written before or after issuance of this Consent Order.



4
C. Revise the Amended Work Plan as necessary to incorporate new information obtained
during the implementation of the plan and/or to incorporate any improvement
recommendations made by Kiefner and Associates as a result of the additional study
PPL plans to undertake (Item A.v. above)
D. Submit any such plan revisions to the Director, Office of Pipeline Safety, PHMSA
Southern Region for review and approval. The Director may approve plan revisions
incrementally. Once approved, the Amended Work Plan and all revisions will become
incorporated into the Consent Order.
E. Implement the Amended Work Plan, including any revisions to the plan.
F. Beginning 60 days after the Consent Order’s issuance, PPL is to prepare and submit
monthly progress reports to the Director, Office of Pipeline Safety, PHMSA Southern
Region. These reports should include documentation of the costs associated with
implementing the Corrective Measures and include sufficient detail to allow the
Director to track the progress of the project and to provide the Director (or his
designated representatives) an opportunity to observe and inspect future field activities
as they occur.
G. The Director may grant an extension of time for compliance with any of the terms of
the Consent Order upon a written request timely submitted demonstrating good cause
for an extension.
H. PPL may appeal any decision of the Director to the Associate Administrator for
Pipeline Safety. Decisions of the Associate Administrator shall be final.
I. PPL agrees to maintain documentation of the costs associated with implementing the
Corrective Measures set forth in the Notice and to submit such costs to the Regional
Director with the monthly progress reports described in the Notice.
III. Review and Approval Process
11. With respect to any submission under Section II of this Consent Agreement that requires
the approval of the Regional Director, the Director may: (a) approve, in whole or in part, the
submission, (b) approve the submission on specified conditions, (c) disapprove, in whole or in
part, the submission, or (d) any combination of the foregoing. If the Regional Director approves,
approves in part, or approves with conditions, Respondent will take all action as approved by the
Director, subject to Respondent's right to invoke the dispute resolution procedures in Section IV
with respect to any conditions the Director identifies. If the Director disapproves all or any
portion of the submission, the Director will provide Respondent with a written notice of the
deficiencies. Respondent will correct all deficiencies within the time specified by the Director
and resubmit it for approval.
IV. Dispute Resolution
12. The Regional Director and Respondent will informally attempt to resolve any disputes
arising under this Consent Agreement. If Respondent and the Regional Director are unable to
informally resolve the dispute within 15 days, Respondent may request in writing, within 10
days, a written determination resolving the dispute from the Associate Administrator for Pipeline



5
Safety providing all information that Respondent believes is relevant to the dispute. If the request
is submitted as provided herein, the Associate Administrator will issue a final determination in
writing. The existence of a dispute and PHMSA's consideration of matters placed in dispute will
not excuse, toll, or suspend any term or timeframe for completion of any work to be performed
under this agreement during the pendency of the dispute resolution process except as agreed by
the Regional Director or the Associate Administrator in writing.
V. Enforcement
13. This Consent Agreement, as adopted by the Consent Order, is subject to all enforcement
authorities available to PHMSA under 49 U.S.C. § 60101 et seq. and 49 C.F.R. Part 190,
including administrative civil penalties under § 60122 of up to $200,000 per violation for each
day the violation continues, if PHMSA determines that Respondent is not proceeding according
to the terms of the agreement, determinations made by the Regional Director, or if appealed,
decisions of the Associate Administrator. All work plans and associated schedules set forth or
referenced in Section II will be incorporated into this Consent Agreement and are enforceable in
the same manner.
VI. Record Keeping and Information Disclosure
14. Respondent agrees to maintain records demonstrating compliance with all requirements of
this Consent Agreement for a period of at least five years following completion of all work to be
performed. For any reports, plans, or other deliverables required to be submitted to PHMSA
pursuant to this Consent Agreement, Respondent may assert a claim of business confidentiality
or other protections applicable to the release of information by PHMSA, covering part or all of
the information required to be submitted to PHMSA pursuant to this agreement in accordance
with 49 C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each
page, and include a statement specifying the grounds for each claim of confidentially. PHMSA
determines release of any information submitted pursuant to this Consent Agreement in
accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and/or
PHMSA policies, and other applicable regulations and Executive Orders.
VII. Modification
15. The terms of this Consent Agreement may be modified by mutual agreement of the parties.
Such modifications must be in writing and signed by both parties.
VII. Termination
16. This Consent Agreement terminates upon completion of all terms set forth in Section II
(Corrective Measures) as determined by the Director, Southern Region. Respondent may request
written confirmation from PHMSA when this agreement is terminated. To the extent ongoing
monitoring is required; PHMSA may terminate this agreement with respect to all other
requirements with the exception of such monitoring. Nothing in this agreement prevents
Respondent from completing any of the obligations earlier than the deadlines provided for in this
Agreement.



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IX. Ratification
17. The Parties undersigned representatives certify that they are fully authorized to enter into
the terms and conditions of this Consent Agreement and to execute and legally bind such party to
this document.
18. The Parties hereby agree to all conditions and terms of this Consent Agreement:
For PHMSA: For Respondent:
_______________________________ _________________________________
Wayne T. Lemoi Date Ronald G. McClain Date
Director, Office of Pipeline Safety President,
PHMSA Southern Region Products Pipelines
U.S. Department of Transportation Plantation Pipe Line Company
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