{"operation":"document","citation":"CPF 22020001CAO","title":"NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2020-10-01","effective_on":null,"summary":"OPEN corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22020001cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22020001cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22020001cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22020001CAO","body":"Corrective Action Order involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). The dataset does not identify a cited regulation for this case. The case was opened on 2020-10-01 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22020001CAO_Corrective Action Order_10012020_(20-192189).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22020001CAO/22020001CAO_Corrective%20Action%20Order_10012020_(20-192189).pdf\n\n22020001CAO_Corrective Action Order_10012020_(20-192189)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22020001CAO/22020001CAO_Corrective%20Action%20Order_10012020_(20-192189)_text.pdf\n\n22020001CAO_Corrective Action Order_10012020_(20-192189)_text.pdf\n\nOctober 1, 2020\nVIA ELECTRONIC MAIL TO: kenneth grubb@kindermorgan.com\nMr. Kenneth W. Grubb\nChief Operating Officer of Gas Pipelines\nKinder Morgan\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF No. 2-2020-001-CAO\nDear Mr. Grubb:\nEnclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-\nreferenced case. It requires Natural Gas Pipeline Company of America (NGPL or Respondent),\noperated by Kinder Morgan, to take certain corrective actions with respect to a rupture that\noccurred on the 20-inch Indian Basin pipeline located in Eddy County, New Mexico.\nService of the CAO by electronic mail is deemed complete upon transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. James Urisko, Director, Southern Region, OPS\nMs. Kristin Van Der Laan, Manager - Engineering, Compliance/Codes & Standards,\nKinder Morgan, kristin_vanderlaan@kindermorgan.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nNatural Gas Pipeline Company\n)\n)\n)\nof America, LLC,\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 2-2020-001-CAO\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.\n§ 60112 to require Natural Gas Pipeline Company of America, LLC (NGPL or Respondent),\noperated by Kinder Morgan,1 to take the necessary corrective actions to protect the public,\nproperty, and the environment from potential hazards associated with the September 24, 2020\nrupture from its 20-inch Indian Basin natural gas pipeline located in Eddy County, New Mexico\n(Incident).\nAt approximately 12:30am MDT on September 24, 2020, NGPL’s 20-inch Indian Basin Pipeline2\nruptured and released approximately 31,757 MCF of natural gas. The incident was discovered\nwhen Kinder Morgan’s SCADA Gas Control Center in Houston, Texas detected a rapid pressure\ndrop at an active receipt point on the Indian Basin Pipeline. It was initially determined the pressure\ndrop was 500 pounds per square inch (psig) in 90 minutes. Prior to the rupture, the line was\noperating at 946 psig. NGPL dispatched personnel to the site, who, at approximately 6:00am\nMDT, identified the rupture location near engineering station 1895+00, approximately one mile\nwest of a main line valve IB-2. The pipeline failure created a crater, but no pipe ejected from the\nditch. There were no reports of fires, injuries, fatalities or evacuations.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS), initiated an investigation\nof the Incident. The preliminary findings of the agency’s ongoing investigation are as follows:\n1 NGPL has approximately 9,100 miles of pipeline and 288 billion cubic feet of natural gas storage through New\nMexico, Texas, Louisiana, Arkansas, Oklahoma, Kansas, Missouri, Nebraska, Illinois, and Iowa. NGPL is jointly\nowned by Kinder Morgan, Inc. and Brookfield Infrastructure Partners, LP. The entity is operated by Kinder Morgan.\nSee https://www kindermorgan.com/Operations/Natural-Gas/Index (last accessed September 25, 2020).\n2 NGPL also refers to this line as the Indian Basin Pipeline and Segment 7.\n\n\n\nCPF No. 2-2020-001-CAO\nPage 2\nPreliminary Findings\n At approximately 12:30am MDT on September 24, 2020, NGPL’s Indian Basin\nPipeline ruptured. Kinder Morgan’s SCADA Gas Control Center in Houston, Texas\ndetected a rapid pressure drop (500 psig in 90 minutes) at an active receipt point on the\nIndian Basin Pipeline. NGPL dispatched personnel to the site to find the cause of the\nrapid pressure drop. An NGPL Artesia District technician, investigating from west to\neast, discovered an ice-covered regulator at a receipt point indicating a rapid natural\ngas expansion event downstream of the regulator due to a possible leak or rupture. An\nNGPL Lovington District Technician, investigating from east to west, discovered the\nrupture location near engineering station 1895+00, approximately one mile west of\nmain line valve IB-2.\n NGPL initially reported the Incident to the National Response Center (NRC) at 7:53am\nEDT on September 24, 2020 (NRC Report No. 1288123), indicating there was a\npotential release of an unknown amount of natural gas from a transmission line.\n NGPL provided a follow-up report to the NRC at 12:14pm EDT on September 25, 2020\n(NRC Report No. 1288243) indicating the GPS coordinates of the release location,\ndisclosing the amount of natural gas believed to be released, advising a line rupture\ncaused the release of natural gas, and identified the nearest city to the release as Loco\nHills, New Mexico.\n There were no fires, injuries, fatalities, or evacuations associated with this incident;\nhowever, the rupture exposed approximately 81 feet of the pipeline. No pipe was\nejected from the ditch.\n The volume of natural gas released was approximately 31,757 MCF. The gas was\nreleased into the air without ignition.\n Prior to the rupture, the line was operating at 946 psig. The maximum allowable\noperating pressure (MAOP) of the line is 1000 psig.\n The Indian Basin Pipeline was shut in at 3:19am MDT, when the NGPL technician\nclosed the upstream mainline valve IB-3. Mainline valve IB-2, the downstream\nisolation valve, is a “line break” valve and automatically closed upon sensing a set\npressure decrease over time. The reported pressure drop of 500 psig in 90 minutes met\nthe criteria for IB-2 to close. At 4:40am MDT, NGPL personnel confirmed IB-2 had\nclosed automatically as the result of the rupture.\n The Indian Basin Pipeline runs northeast from the Occidental (Oxy) Indian Basin Gas\nPlant to the NGPL Compressor Station 167 and is approximately 67 miles in length.\nApproximately 44 miles of the Indian Basin Pipeline was constructed in 1965 with a\n20-inch nominal diameter, 0.235-inch wall thickness, API 5L, X-60 grade pipe that was\n\n\n\nCPF No. 2-2020-001-CAO\nPage 3\nmanufactured by Youngstown Sheet and Tube. The pipe has a direct-current electric\nresistance welded (DC-ERW) longitudinal seam and has an asphalt enamel coating.\n The Indian Basin Pipeline flows northeasterly and transports natural gas from various\nreceipt points including the Oxy Indian Basin Gas Plant to the NGPL compressor\nstation 167, where it is compressed into NGPL’s two Permian pipelines.\n The failure occurred in a Class 1 location, non-high consequence area, approximately\n16 miles east of Artesia, New Mexico in Eddy County.\n Preliminary indications suggest the Incident occurred due to the failure of the pipe\nlongitudinal seam.\n On August 21, 2019, NGPL experienced a pipeline rupture on the Indian Basin Pipeline\napproximately five miles west of the September 24, 2020 rupture location. The portion\nof pipe that ruptured on August 21, 2019, was 20-inch diameter, 1965 vintage,\nYoungstown Sheet and Tube, API 5L, X60 grade, with a DC-ERW longitudinal seam.\nThis is the same type of pipe that failed on September 24, 2020.\n The August 21, 2019, failure occurred at an operating pressure of 879 psig. The MAOP\nof the line at the time of failure was 1000 psig.\n The metallurgical evaluation of the 2019 incident determined the rupture was caused\nby wall thinning in the pipe’s longitudinal seam due to external corrosion, in the form\nof selective seam weld corrosion.\n The operator performed a fitness for service hydrostatic pressure test of the Indian\nBasin Pipeline on January 7, 2020, following the 2019 incident. The test medium was\nwater. The duration of the test was eight hours. The actual minimum test pressure was\n1268 psig, and the actual maximum test pressure was 1347 psig.\n PHMSA has issued Advisory Bulletins on the safety risks of ERW and Flash-welded\nPipe manufactured prior to 1970. It also issued Alert Notice, ALN-88-01, in January\n1988, advising owners and operators of natural gas and hazardous liquids pipelines to\nconsider the threat from ERW pipe manufactured prior to 1970. The operators were\nadvised to determine whether their pipelines were susceptible to ERW seam failures\nand address the potential impact on pipeline integrity.\n PHMSA addresses Selective Seam Corrosion on its Pipeline Safety Stakeholders\nCommunications webpage, titled, Fact Sheet: Selective Seam Corrosion (SSC).3\nDetermination of Necessity for Corrective Action Order and Right to Hearing\n3 Available at https://primis.phmsa.dot.gov/comm/FactSheets/FSSelectiveSeamCorrosion htm?nocache=717.\n\n\n\nCPF No. 2-2020-001-CAO\nPage 4\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material are transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in which\nthe pipeline facility is located; (6) any recommendation of the National Transportation Safety\nBoard made under another law; and (7) other factors PHMSA may considers appropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the proximity\nof the pipeline to public roadways and populated areas, the failure history of the pipeline, the\nsimilarity in the root cause of previous failures to the potential root cause of this failure, the age of\nthe pipeline, material properties of pipeline, including the presence of a DC-ERW longitudinal\nseam, hazardous nature of the product transported, and a history of known problems with this type\nof pipe, I find that continued operation of the pipeline without corrective measures is or would be\nhazardous to life, property, or the environment, and that failure to issue this Order expeditiously\nwould result in the likelihood of serious harm.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective 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, with a copy\nto the Director, Southern Region, PHMSA (Director). If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe 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 Actions\nDefinitions:\n\n\n\nCPF No. 2-2020-001-CAO\nPage 5\nAffected Pipeline – The “Affected Pipeline” means the NGPL 20-inch Indian Basin Pipeline,\nspecifically the approximately 67 miles of pipeline that generally runs northeasterly between\nthe Oxy Indian Basin Natural Gas Plant in Eddy County, New Mexico and the Kinder\nMorgan/NGPL Compressor Station Number 167, located in Lea County, New Mexico.\nIsolated Segment – The \"Isolated Segment\" means the 17-mile segment of NGPL 20-inch\nIndian Basin Pipeline from main line valve IB-3 (Sta. No. 1048+09.2) to line break valve\nIB-2 (Sta. No. 1945+98.9). It is the portion of the \"Affected Pipeline\" that was partially shut-\nin with the automatic closing of line-break valve IB-2 (downstream of the rupture), and the\nmanual closing of main line valve IB-3 (upstream of the rupture).\nPursuant to 49 U.S.C. 60112, I hereby order NGPL to immediately take the following corrective\nactions:\n1. Shutdown of the Isolated Segment. The Isolated Segment is currently out of service.\nBased on the pipeline configuration, the shut-in of the Isolated Segment has resulted in the\nisolation and shutdown of the Affected Pipeline. The Isolated Segment must remain shut\nin and may not be operated until authorized to be restarted by the Director in accordance\nwith the terms of this Order.\n2. Operating Pressure Restriction. NGPL must reduce and maintain a maximum twenty\npercent (20%) pressure reduction in the actual operating pressure along the entire length of\nthe Affected Pipeline such that upon restart the operating pressure along the Affected\nPipeline will not exceed eighty percent (80%) of the actual operating pressure in effect\nimmediately prior to the failure on September 24, 2020.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is obtained from\nthe Director.\nb. c. d. e. Within 15 days of receipt of this Order, NGPL must provide the Director the actual\noperating pressures of each compressor station and each main line pressure regulating\nstation on the Affected Pipeline at the time of failure and the reduced pressure\nrestriction set-points at these same locations.\nThis pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\nadjusted accordingly.\nWhen determining the pressure restriction set-points, NGPL must take into account\nany in-line inspection (ILI) features or anomalies present in the Affected Pipeline to\nprovide for continued safe operation while further corrective actions are completed.\nNGPL must review the pressure restriction monthly by analyzing the operating\npressure data, taking into account any ILI features or anomalies present in the\nAffected Pipeline. NGPL must immediately reduce the operating pressure further to\nmaintain the safe operations of the Affected Pipeline, if warranted by the monthly\nreview. Further, NGPL must submit the results of the monthly review to the Director\n\n\n\nCPF No. 2-2020-001-CAO\nPage 6\n3. including, at a minimum, the current discharge set-points (including any additional\npressure reductions), and any pressure exceedance at discharge set-points. Submittals\nmay be made quarterly, in accordance with Item 17 below.\nRestart Plan. Prior to resuming operation of the Isolated Segment, develop and submit a\nwritten Restart Plan to the Director for prior approval.\na. b. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Isolated Segment cannot resume operation until the Restart Plan is\napproved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment during\nthe restart process and must include incremental pressure increases during start up,\nwith each increment to be held for at least two hours.\nd. The Restart Plan must include sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\ne. f. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\nThe Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those of the failure including a review of construction, operating and\nmaintenance (O&M) and integrity management records such as ILI results,\nhydrostatic tests, root cause failure analysis of prior failures, aerial and ground\npatrols, corrosion, cathodic protection, excavations and pipe replacements. NGPL\nmust address any findings that require remedial measures to be implemented prior to\nrestart.\n4. g. The Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications\nare incorporated into NGPL’s O&M procedures manual.\nh. The Restart Plan must provide for hydrostatic pressure testing of the Isolated\nSegment.\nReturn to Service. After the Director approves the Restart Plan, NGPL may return the\nIsolated Segment to service but the operating pressure must not exceed the limit in\naccordance with Item 2 above.\n5. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from NGPL demonstrating that restoring the pipeline to its pre-failure\noperating pressure is justified based on a reliable engineering analysis showing that the\npressure increase is safe considering all known defects, anomalies, and operating\nparameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\n\n\n\n6. 7. 8. 9. CPF No. 2-2020-001-CAO\nPage 7\nrestrictions upon a written request from NGPL demonstrating that temporary mitigative\nand preventive measures are implemented prior to and during the temporary removal or\nmodification of the pressure restriction. The Director's determination will be based on\nthe failure cause and provision of evidence that preventative and mitigative actions taken\nby the operator provide for the safe operation of the Affected Pipeline during the\ntemporary removal or modification of the pressure restriction. Appeals to determinations\nof the Director in this regard will be decided by the Associate Administrator for Pipeline\nSafety.\nInstrumented Leakage Survey. Within 30 days of receipt of this Order, NGPL must perform\nan aerial or ground instrumented leakage survey of the Affected Pipeline. NGPL must\ninvestigate all leak indications and remedy all leaks discovered. NGPL must submit\ndocumentation of this survey to the Director within 45 days of receipt of this Order.\nRecords Verification. As recommended in PHMSA Advisory Bulletin 2012-06, NGPL must\nverify the records for the Affected Pipeline to confirm the MAOP. NGPL must submit\ndocumentation of this this record verification to the Director within 45 days of receipt of this\nOrder.\nReview of Prior Inline Inspection (ILI) Results. Within 30 days of receipt of this Order,\nNGPL must conduct a review of any previous ILI results of the Affected Pipeline. In its\nreview, NGPL must re-evaluate all ILI results from the past 10 calendar years, including a\nreview of the ILI vendors' raw data and analysis. NGPL must determine whether any\nfeatures were present in the failed pipe joints from the September 24, 2020 failure, the\nAugust 21, 2019 failure, and any other pipe removed. Also, NGPL must determine if any\nfeatures with similar characteristics are present elsewhere on the Affected Pipeline. NGPL\nmust submit documentation of this ILI review to the Director within 60 days of receipt of this\nOrder as follows:\na. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nb. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present in the failed joint and other pipe removed.\nc. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Pipeline.\nd. Explain the process used to review the ILI results and the results of the reevaluation.\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order, NGPL must\ncomplete mechanical and metallurgical testing and failure analysis of the failed pipe,\nincluding an analysis of soil samples and any foreign materials. Mechanical and\nmetallurgical testing must be conducted by an independent third-party acceptable to the\nDirector, and must document the decision-making process and all factors contributing to the\nfailure. NGPL must complete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the failure site.\nb. Within 10 days of receipt of this Order, develop and submit the testing protocol and the\nproposed testing laboratory to the Director for prior approval.\n\n\n\nCPF No. 2-2020-001-CAO\nPage 8\n10. c. Prior to beginning the mechanical and metallurgical testing, provide the Director with the\nscheduled date, time, and location of the testing to allow for an OPS representative to\nwitness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their entirety\nto the Director at the same time they are made available to NGPL.\nRoot Cause Failure Analysis. Within 120 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\nThe RCFA must be supplemented or facilitated by an independent third-party acceptable to\nthe Director and must document the decision-making process and all factors contributing to\nthe failure. The final report must include findings and any lessons learned and whether the\nfindings and lessons learned are applicable to other locations within NGPL’s pipeline system.\nFurther, the lessons learned must include consideration of causal factors for the August 21,\n2019 failure.\n11. Emergency Response Plan and Training Review. NGPL must review and assess the\neffectiveness of its emergency response plan with regards to the failure. Include in the\nreview and assessment the on-scene response and support, coordination, and communication\nwith emergency responders and public officials. Also, include a review and assessment of\nthe effectiveness of its emergency training program. NGPL must amend its emergency\nresponse plan and emergency training, if necessary, to reflect the results of this review.\nFurther, NGPL must review controller response to all alarms prior to, and following,\nconfirmation of the rupture. NGPL must also review the controllers’ coordination and\ncommunications with internal and external stakeholders prior to and throughout this incident\nresponse. The documentation of this Emergency Response Plan and Training Review must\nbe available for inspection by OPS or provided to the Director, if requested.\n12. Public Awareness Program Review. NGPL must review and assess the effectiveness of its\nPublic Awareness Program with regards to the failure. NGPL must amend its Public\nAwareness Program, if necessary, to reflect the results of this review. The documentation of\nthis Public Awareness Program Review must be available for inspection by OPS or provided\nto the Director, if requested.\n13. Remedial Work Plan (RWP).\na. Within 120 days following receipt of this Order, NGPL must submit a remedial work\nplan (RWP) to the Director for approval.\nb. c. The Director may approve the RWP incrementally without approving the entire RWP.\nOnce approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nd. e. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures NGPL will use to verify the integrity of the Affected Pipeline. It must address\nall known or suspected factors and causes of the September 24, 2020 failure, as well as\nall known or suspected factors of the August 21, 2019 failure. NGPL must consider the\nrisks and consequences of another failure to develop a prioritized schedule for RWP-\nrelated work along the Affected Pipeline.\nThe RWP must include a procedure or process to:\n\n\n\ni. ii. iii. iv. v. vi. vii. CPF No. 2-2020-001-CAO\nPage 9\nIdentify pipe in the Affected Pipeline with characteristics similar to the contributing\nfactors identified for the September 24, 2020 failure.\nGather all data necessary to review the failure history (in service and pressure test\nfailures) of the Affected Pipeline and to prepare a written report containing all the\navailable information such as the locations, dates, and causes of leaks and failures.\nIntegrate the results of the metallurgical testing, root cause failure analysis, and other\ncorrective actions required by this Order with all relevant pre-existing operational and\nassessment data for the Affected Pipeline. Pre-existing operational data includes, but\nis not limited to, design, construction, operations, maintenance, testing, repairs, prior\nmetallurgical analyses, and any third-party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic pressure\ntesting, direct assessments, close interval surveys, and DCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the failure on\nSeptember 24, 2020 are likely to exist elsewhere on the Affected Pipeline.\nConduct additional field tests, inspections, assessments, and evaluations to determine\nwhether, and to what extent, the conditions associated with the failure on September\n24, 2020, and other failures from the failure history (see (e)(ii) above) or any other\nintegrity threats are present elsewhere on the Affected Pipeline. At a minimum, this\nprocess must consider all failure causes and specify the use of one or more of the\nfollowing:\n1) ILI tools that are technically appropriate for assessing the pipeline system based\non the cause of failure on September 24, 2020, and that can reliably detect and\nidentify anomalies;\n2) Hydrostatic pressure testing;\n3) Close-interval surveys;\n4) Cathodic protection surveys, to include interference surveys in coordination with\nother utilities (e.g. underground utilities, overhead power lines, etc.) in the area;\n5) Coating surveys;\n6) Stress corrosion cracking surveys;\n7) Selective seam corrosion surveys; and\n8) Other tests, inspections, assessments, and evaluations appropriate for the failure\ncauses.\nNote: NGPL may not use the results of previous tests, inspections, assessments, and\nevaluations.\nDescribe the inspection and repair criteria NGPL will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity threats.\nInclude a description of how any defects will be graded and a schedule for repairs or\nreplacement.\nBased on the known history and condition of the Affected Pipeline, describe the\nmethods NGPL will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the pipeline failure on September 24, 2020,\n\n\n\n14. CPF No. 2-2020-001-CAO\nPage 10\nand to address other known integrity threats along the Affected Pipeline. The repair,\nreplacement, or other corrective measures must meet the criteria specified in (e)(vi)\nabove.\nviii. Implement continuing long-term periodic testing and integrity verification measures\nto ensure the ongoing safe operation of the Affected Pipeline considering the results\nof the analyses, inspections, evaluations, and corrective measures undertaken\npursuant to the Order.\nf. g. Include a proposed schedule for completion of the RWP.\nNGPL must revise the RWP as necessary to incorporate new information obtained during\nthe failure investigation and remedial activities, to incorporate the results of actions\nundertaken pursuant to this Order, and to incorporate modifications required by the\nDirector.\ni. Submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\niii. All revisions to the RWP after it has been approved and incorporated by reference into\nthis Order will be fully described and documented in the CAO Documentation Report.\nh. Implement the RWP as it is approved by the Director, including any revisions to the plan.\nCAO Documentation Report (CDR). NGPL must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When NGPL has concluded all the items in this Order it will\nsubmit the final CDR in its entirety to the Director. This will allow the Director to complete a\nthorough review of all actions taken by NGPL with regards to this Order prior to approving the\nclosure of this Order. The intent is for the CDR to summarize all activities and documentation\nassociated with this Order in one document.\na. b. c. The Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into this Order.\nThe CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the pipeline failure of September 24, 2020 and the response activities;\nSummary of pipe data, material properties and all prior assessments of the Affected\nPipeline;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis required by\nthe Order;\nv. vi. vii. Summary of the Mechanical and Metallurgical Testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by NGPL to implement the RWP, the results of\nthose actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to incorporate\nthe results of actions undertaken pursuant to this Order and whenever necessary to\n\n\n\nCPF No. 2-2020-001-CAO\nPage 11\nincorporate new information obtained during the failure investigation and remedial\nactivities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions NGPL will take on its entire pipeline system\nas a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\nOther Requirements:\n15. 16. 17. 18. Approvals. With respect to each submission that under this Order requires the approval of the\nDirector, the Director may: (a) approve, in whole or part, the submission; (b) approve the\nsubmission on specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director, and resubmit it for approval.\nExtensions of Time. The Director may grant an extension of time for compliance with any of\nthe terms of this Order upon a written request timely submitted demonstrating good cause for\nan extension.\nReporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress of\nthe repairs or other remedial actions being undertaken. The first quarterly report is due on\nDecember 31, 2020. The Director may change the interval for the submission of these reports.\nDocumentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action Order.\nInclude in each monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies and analyses; (2) physical changes to pipeline\ninfrastructure, including repairs, replacements and other modifications; and (3) environmental\nremediation, if applicable.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 2-2020-001-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The actions\nrequired by this Order are in addition to and do not waive any requirements that apply to\n\n\n\nCPF No. 2-2020-001-CAO\nPage 12\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued\nto Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of Federal\nor State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nOctober 1, 2020\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":34962}