{"operation":"document","citation":"CPF 22021010CAO","title":"TENNESSEE GAS PIPELINE COMPANY — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-07-09","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021010cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021010cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021010cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22021010CAO","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 2021-07-09 and is reported as closed as of 2023-09-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22021010CAO_Amended Corrective Action Order_07232021_(21-216102).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021010CAO/22021010CAO_Amended%20Corrective%20Action%20Order_07232021_(21-216102).pdf\n\n22021010CAO_Amended Corrective Action Order_07232021_(21-216102)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021010CAO/22021010CAO_Amended%20Corrective%20Action%20Order_07232021_(21-216102)_text.pdf\n\n22021010CAO_Closure Letter_09082023_(21-216102).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021010CAO/22021010CAO_Closure%20Letter_09082023_(21-216102).pdf\n\n22021010CAO_Closure Letter_09082023_(21-216102)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021010CAO/22021010CAO_Closure%20Letter_09082023_(21-216102)_text.pdf\n\n22021010CAO_Closure Letter_09082023_(21-216102)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom martin@kindermorgan.com;\nsteve kean@kindermorgan.com; kenneth grubb@kindermorgan.com;\nSeptember 8, 2023\nTennessee Gas Pipeline Company\nThomas Martin, President\n1001 Louisiana Street\nSuite 1000\nHouston, Texas 77002\nCPF 2-2021-010-CAO\nDear Mr. Martin:\nOn July 9, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to\nTennessee Gas Pipeline Company (TGPC), a Corrective Action Order in the above-referenced\ncase. This Order included a requirement to take corrective actions on your pipeline. Based on\nPHMSA’s review of the documentation provided by TGPC, it has been determined that TGPC has\ncomplied with the terms of this Order.\nAccordingly, this case is now closed, and no further action is required with respect to the matters\ninvolved in this case. Thank you for your cooperation in this matter.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA, Southern Region\n\n22021010CAO_Amended Corrective Action Order_07232021_(21-216102)_text.pdf\n\nJuly 23, 2021\nVIA ELECTRONIC MAIL TO: kenneth grubb@kindermorgan.com\nKenneth W. Grubb\nChief Operating Officer of Gas\nPipelines Kinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF No. 2-2021-010-CAO\nDear Mr. Grubb:\nEnclosed please find the Amended Corrective Action Order (ACAO or Order) issued by the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), in the above-referenced case. It requires Tennessee Gas Pipeline Company, LLC, (TGP\nor Respondent), operated by Kinder Morgan, Inc., to take certain corrective actions with respect\nto a rupture that occurred on the 24-inch Tennessee Gas Pipeline located in West Bloomfield,\nNew York.\nService of the A CAO by electronic transmission is deemed complete upon transmission\nand acknowledgment of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms\nand conditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: ACAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. James Urisko, Director, Southern Region, OPS\nMr. Jaime Hernandez, Director—Engineering, Compliance/Codes & Standards,\nKinder Morgan, jaime_hernandez@kindermorgan.com\nCONFIRMATION OF RECEIPT REQUESTED\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY\nADMINISTRATION OFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n\n\n\n____________________________________\nIn the Matter of )\nTennessee Gas Pipeline Company, LLC, ) CPF No. 2-2021-010-CAO\n)\n)\n)\nPetitioner. )\n____________________________________)\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background\nThis Amended Corrective Action Order (ACAO or Order) is being issued under the authority of\n49 U.S.C. § 60112 to require Tennessee Gas Pipeline Company, LLC, (TGP or Respondent),\noperated by Kinder Morgan, Inc.,1 to take the necessary corrective actions to protect the public,\nproperty, and the environment from potential hazards associated with the June 26, 2021 rupture\nof its 24-inch natural gas pipeline located in West Bloomfield, New York.\nAt approximately 7:25 pm EDT on June 26, 2021, TGP’s 24-inch Tennessee Gas Pipeline 2\nruptured and reportedly released approximately 11,000 MCF of natural gas (Incident). The Ontario\nCounty Sheriff’s Department notified Kinder Morgan’s control room in Houston, Texas of the\nevent. Prior to the rupture, the line was operating at 659 psig. Kinder Morgan dispatched\npersonnel to the site, who, at approximately 9:45 pm EDT, identified the rupture location near\nWest Bloomfield, New York, southeast of Lima, New York. Kinder Morgan discovered a 12-\nfoot long section of pipeline ejected and laying in a crater. Kinder Morgan personnel also\nreported that the termini of the remaining buried pipeline were exposed, one of which was\ndeflected 45-degrees upward from the force of the rupture. Kinder Morgan confirmed the\nupstream and downstream valves had closed automatically. There were no reports of fires,\ninjuries, fatalities, or evacuations.\nPursuant to 49 U.S.C. §§ 60117 and 60106, PHMSA, Office of Pipeline Safety (OPS) and the New\nYork State Department of Public Service (NY DPS), initiated an investigation of the Incident and,\non July 9, 2021, issued a Corrective Action Order (CAO). The ACAO amends the preliminary\nfindings, one corrective action and the scope of the corrective actions prescribed in the CAO.\nThe preliminary findings of the agencies’ ongoing investigation are as follows:\n1 The Tennessee Gas Pipeline is an approximately 11,750-mile pipeline system that transports natural gas from\nLouisiana, the Gulf of Mexico and South Texas to the Northeast section of the United States, including New York\nCity and Boston. TGP is owned and operated by Kinder Morgan, Inc. See\nhttps://www kindermorgan.com/Operations/Natural-Gas/Index (last accessed July 1, 2021).\n2 The rupture occurred on the Line 200-1 segment of the Tennessee Gas Pipeline.\n\n\n\nAmended Preliminary Findings\n At approximately 7:25 pm EDT on June 26, 2021, TGP’s Tennessee Gas Pipeline\nruptured.3 The Ontario County Sheriff’s Department notified Kinder Morgan’s control\nroom in Houston, Texas of the event. Kinder Morgan dispatched personnel to the site who\ndiscovered the rupture location near West Bloomfield, New York, southeast of Lima, New\nYork. Per Kinder Morgan, the rupture location was 9.6322 miles downstream from\nMainline Valve (MLV) 234-1 on TGP’s Line 200-1. Kinder Morgan confirmed that the\nbounding upstream and downstream MLVs (234-1 and 235-1, respectively) closed\nautomatically.\n Kinder Morgan initially reported the Incident to the National Response Center (NRC) at\n10:23 pm EDT on June 26, 2021 (NRC Report No. 1308933), indicating there was a release\nof approximately 11,000 MCF of natural gas from a transmission line. Kinder Morgan\nsubmitted a second NRC report on June 28, 2021 (NRC Report No. 1309098), updating the\ncoordinates for the location of the incident.\n The natural gas was released to the atmosphere with no fires, injuries, fatalities or\nevacuations associated with this incident. Kinder Morgan discovered a 12-foot long section\nof pipeline ejected and laying in a crater. Kinder Morgan personnel also reported that the\ntermini of the remaining buried pipeline were exposed, one of which was deflected 45-\ndegrees upward from the force of the rupture.\n Prior to the rupture, Line 200-1 was operating at 659 psig. The maximum allowable\noperating pressure (MAOP) of the Line is 760 psig.\n Line 200-1 was shut in soon after 7:25 pm EDT, when MLV 234-1 and MLV 235-1 closed\nautomatically. Kinder Morgan reported approximately 12 miles of pipeline remains\nshutdown and isolated.\n TGP delineates its Line 200-1 in to two sections – the South Section and the North Section.\nThe South Section of Line 200-1 is 382.63 miles long. It starts in Greenup County,\nKentucky and ends in Erie County, New York. The North Section of Line 200- 1, the failed\nsegment, is 419.75 miles long. It starts in Erie County, New York and ends in Middlesex\nCounty, Massachusetts. The entire Line 200-1 is 802.38 miles long.\n The failed portion of the pipeline was constructed in 1951 with a 24-inch nominal diameter,\n0.281-inch wall thickness, X-52 grade pipe that was manufactured by A.O. Smith. The pipe\nhas an electric flash welded (EFW) longitudinal seam and has a coal tar coating. Kinder\nMorgan reported that approximately 401.36 miles of Line 200-1 is of similar vintage and\nmanufacture.4\n3 The exact time of failure is unknown by TGP.\n4 Kinder Morgan reported that the entire Line 200-1 pipeline is 802.38 miles long.\n\n\n\n Kinder Morgan operates TGP Line 200-2, a 30-inch natural gas pipeline that is located\napproximately 20 feet parallel to Line 200-1. Kinder Morgan crews did not identify any\nleaks on the parallel line during a leak survey conducted on June 30, 2021.\n The Incident occurred in a Class 1 location, non-high consequence area. Kinder Morgan\nreported that Line 200-1 pipeline has 564.49 miles in Class 1 locations, 173.34 miles in Class\n2 locations, 64.04 miles in Class 3 locations, 0.51 miles in Class 4 locations, and 13.51\nmiles in tribal lands.\n Kinder Morgan performed an in-line inspection tool run of this pipeline in 2020 to\ndetect hard spots. Kinder Morgan reported there were no indications of hard spots along\nthis section of pipeline.\n Kinder Morgan initially reported to PHMSA that it believes the failure occurred due to a\nwrinkle bend in the line, but later reported the failure may have been due to a buckle. A\nKinder Morgan metallurgist at the scene reported discovering three wrinkles or buckles in\nthe failed pipeline. PHMSA’s interstate agent (NY DPS) reported a wrinkle or buckle in the\nejected pipe. PHMSA has not yet confirmed whether wrinkles or buckles were present at\nthe location of the Incident. Kinder Morgan also reported at least one wrinkle bend\npotentially exists in the same line approximately 50 feet away from the site of the Incident.\n Kinder Morgan records indicate that TGP Line 200-1 crosses a steel water line immediately\nwest of the failure location, near Rochester Water Authority Road. Preliminary information\nis that this water line was recently replaced, although the exact date of replacement is\nunknown at this time.\n Kinder Morgan reported the Incident occurred in the vicinity of an overbend in the pipeline\nat a 50-foot downhill slope.\n Kinder Morgan has attributed other failures on its TGP System to wrinkle bends, including\na failure on its Line 100-2 in 2010.5\n PHMSA has issued Advisory Bulletins on the safety risks of electric resistance welded\n(ERW) and EFW pipe manufactured prior to 1970. It also issued Alert Notice, ALN-88-\n01, in January 1988, advising owners and operators of natural gas and hazardous liquids\npipelines to consider the threat from ERW pipe manufactured prior to 1970.\n Concerns exist among the pipeline industry about the effects of wrinkle bends on the\nlong-term integrity of pipelines as well as the known threat of unintended buckling.\nOn July 14, 2021, Kinder Morgan submitted technical data on Line 200-1, which included\n5 See In the Matter of Tennessee Gas Pipeline Company, CPF No. 4-2010-1007H, 2010 WL 5761102 (Dec. 2,\n2010).\n\n\n\nprior inspection reports and updated ILI analyses. Kinder Morgan reported to PHMSA that\nit believes the failure was caused by a buckle in the line. Kinder Morgan informed PHMSA\nthat geotechnical and soil analyses are ongoing to determine whether there has been any land\nmovement or soil subsidence in the area of the failure location. Kinder Morgan also\npresented data regarding the potential impact a 20 percent pressure reduction on the Affected\nPipeline, as defined in the CAO, would have on its system and consumer supply. Based\nupon a review of this data, the preliminary indications of the failure cause, and the operating\nconditions, PHMSA is limiting the scope of ACAO by amending the definition of the\nAffected Pipeline to include approximately 75 miles of the TGP’s Line 200-1 pipeline rather\nthan the entire 800 miles of Line 200-1. The ACAO also amends the corrective actions\nKinder Morgan will be required to perform. Determination of Necessity for Corrective\nAction Order and Right to Hearing.\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a\npipeline facility is or would be hazardous to life, property, or the environment and if there is\na likelihood of serious harm, to issue an order without prior notice to the operator of the\nfacility to take necessary corrective action, including suspended or restricted use of the\nfacility, physical inspection, testing, repair, replacement, or other appropriate action. An\norder issued without notice must provide an opportunity for a hearing as soon as practicable\nafter the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1)\nthe characteristics of the pipe and other equipment used in the pipeline facility, including the\nage, manufacture, physical properties, and method of manufacturing, constructing, or\nassembling the equipment; (2) the nature of the material the pipeline facility transports, the\ncorrosive and deteriorative qualities of the material, the sequence in which the material are\ntransported, and the pressure required for transporting the material; (3) the aspects of the area\nin which the pipeline facility is located, including climatic and geologic conditions and soil\ncharacteristics; (4) the proximity of the area in which the hazardous liquid pipeline facility is\nlocated to environmentally sensitive areas; (5) the population density and population and\ngrowth patterns of the area in whichthe pipeline facility is located; (6) any recommendation\nof the National Transportation Safety Board made under another law; and (7) other factors\nPHMSA may considers appropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the age of\nthe pipeline, the known issues with the manufacturer of the pipeline, the material properties\nof pipeline, the significant length of the pipeline of this same vintage and manufacture, the\nhazardous nature of the product transported, the proximity of the pipeline to populated areas,\nthe pressure required for transporting the material, the uncertainty as to the cause of the\nfailure, and the possibility that the same condition(s) that may have caused the failure remain\npresent in the pipeline, I find that continued operation of the pipeline without corrective\n\n\n\nmeasures is or would be hazardous to life, property, or the environment, and that failure to\nissue this Order without notice would result in the likelihood of serious harm.\nAccordingly, this Amended Corrective Action Order mandating immediate corrective action\nis issued without prior notice and opportunity for a hearing. The terms and conditions of this\nOrder are effective upon receipt.\nWithin 10 days of receipt of this Amended Order, Respondent may request a hearing, to be\nheld as soon as practicable, by notifying the Associate Administrator for Pipeline Safety in\nwriting, with a copy to the Director, Southern Region, PHMSA (Director). If a hearing is\nrequested, it will be held in accordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA\nmay identify other corrective measures that need to be taken. Respondent will be notified of\nany additional measures required and, if appropriate, PHMSA will consider amending this\nOrder. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nDefinitions:\nAffected Pipeline – The “Affected Pipeline” means the segment of TGP’s Line 200-1\nbetween Compressor Stations 230 and 237. This segment of Line 200-1 starts in Erie\nCounty, NY (MLV 230; Map Station 0+00) and ends in Ontario County, NY (MLV 236,\nMap Station 474+49). This segment of TGP’s Line 200-1 is 74.47 miles long.\nIsolated Segment – The \"Isolated Segment\" means the approximately 12-mile segment of\nKinder Morgan’s 24-inch TGP Line 200-1 from MLV 234-1 to MLV 235-1. It is the\nportion of the \"Affected Pipeline\" that was shut-in with the above-referenced upstream\nand downstream valves.\nPursuant to 49 U.S.C. § 60112, I hereby order TGP to immediately take the following\ncorrective actions:\n1. Shutdown of the Isolated Segment. The Isolated Segment must remain shut in and\nmay not be operated until authorized to be restarted by the Director in accordance with\nthe terms of this order.\n2. Operating Pressure Restriction. TGP must reduce and maintain a twenty percent (20%)\npressure reduction in the actual operating pressure along the entire length of the Affected\nPipeline such that upon restart the operating pressure along the Affected Pipeline will\n\n\n\n3. not exceed eighty percent (80%) of the actual operating pressure in effect at the failure\nlocation immediately prior to the failure on June 26, 2021.\na. This pressure restriction is to remain in effect until written approval to increase\nthe pressure or return the pipeline to its pre-failure operating pressure is obtained\nfrom the Director.\nb. c. d. e. Within 15 days of receipt of the ACAO, TGP must provide the Director the actual\noperating pressures of each compressor station and each main line pressure\nregulating station on the Affected Pipeline at the time of failure and the reduced\npressure restriction set-points at these same locations.\nThis pressure restriction requires any relevant remote or local alarm limits,\nsoftware programming set-points or control points, and mechanical over-pressure\ndevices to be adjusted accordingly.\nWhen determining the pressure restriction set-points, TGP must take into account\nany in-line inspection (ILI) features or anomalies present in the Affected Pipeline\nto provide for continued safe operation while further corrective actions are\ncompleted.\nTGP 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. TGP must immediately reduce the operating pressure further to\nmaintain the safe operations of the Affected Pipeline, if warranted by the monthly\nreview. Further, TGP must submit the results of the monthly review to the Director\nincluding, at a minimum, the current discharge set-points (including any additional\npressure reductions), and any pressure exceedance at discharge set-points.\nSubmittals may be made quarterly, in accordance with Item 15 below.\nRestart Plan. Prior to resuming operation of the Isolated Segment, develop and submit\na written Restart Plan to the Director for prior approval.\na. b. c. d. e. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Isolated Segment cannot resume operation until the Restart Plan\nis approved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by\nreference into this Order.\nThe Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases during\nstart up, with each increment to be held for at least 2 hours.\nThe 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.\nThe Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials and adjacent\nlandowners.\n\n\n\nf. g. The 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. TGP\nmust address any findings that require remedial measures to be implemented prior\nto restart.\nThe Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into TGP’s O&M procedures manual.\n4. Return to Service. After the Director approves the Restart Plan, TGP may return\nthe Isolated Segment to service according to the terms of the Restart Plan, but the\noperating pressure must not exceed the limit in accordance with Item 2 above.\n5. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction\nupon a written request from TGP demonstrating that restoring the pipeline to its\npre-failure operating pressure is justified based on a reliable engineering analysis\nshowing that the pressure increase is safe considering all known defects,\nanomalies, and operating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from TGP demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on available information, including the failure cause\nand provision of evidence that preventative and mitigative actions taken by the\noperator provide for the safe operation of the Affected Pipeline during the\ntemporary removal or modification of the pressure restriction. Appeals to\ndeterminations of the Director in this regard will be decided by the Associate\nAdministrator for Pipeline Safety.\n6. Instrumented Leakage Survey. Within 30 days of receipt of the ACAO, TGP must\nperform an aerial or ground instrumented leakage survey of the Affected Pipeline. TGP\nmust investigate all leak indications and remedy all leaks discovered. TGP must submit\ndocumentation of this survey to the Director within 45 days of receipt of the ACAO.\n7. Records Verification. TGP must verify the records for the Affected Pipeline that were\nused to establish the MAOP in accordance with § 192.619, including any adjustments\nneeded for the current class locations per §§ 192.609 and 192.611. TGP must submit\ndocumentation of this this record verification to the Director within 45 days of receipt\nof the ACAO.\n\n\n\n8. 9. Review of Prior Inline Inspection (ILI) Results.\na. Within 30 days of receipt of the ACAO, TGP must conduct a review of any\nprevious ILI results of the Affected Pipeline. In its review, TGP must re-evaluate\nall ILI results from the past five calendar years, including a review of the ILI\nvendors' raw data and analysis. TGP must determine whether any features were\npresent in the failed pipe joints from the June 26, 2021 failure. Also, TGP must\ndetermine if any features with similar characteristics are present elsewhere on the\nAffected Pipeline. TGP must submit documentation of this ILI review to the\nDirector within 45 days of receipt of the ACAO, as follows:\ni. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nii. List, describe (type, size, wall loss, etc.), and identify the specific location of all\nILI features present in the failed joint and other pipe removed.\niii. List, describe (type, size, wall loss, etc.), and identify the specific location of all\nILI features with similar characteristics present elsewhere on the Affected\nPipeline.\niv. Explain the process used to review the ILI results and the results of the\nreevaluation.\nb. Within 180 days of receipt of the ACAO, TGP must conduct a review of any previous\nILI results for the entirety of TGP Line 200-1. TGP must determine if any features\nwith similar characteristics to the June 26, 2021 failure are present elsewhere on Line\n200-1. Line 200-1 starts in Greenup County, Kentucky (Station 200-1, Mile Post\n(MP) 0+00) and ends in Middlesex County, Massachusetts (Station 270-1, MP\n46+05). TGP must make the results of this review available for PHMSA’s review\nupon request.\nMechanical and Metallurgical Testing. Within 45 days of receipt of the July 9, 2021\nCAO, TGP must complete mechanical and metallurgical testing and failure analysis of\nthe failed pipe, including an analysis of soil samples and any foreign materials.\nMechanical and metallurgical testing must be conducted by an independent third-party\nacceptable to the Director, and must document the decision-making process and all\nfactors contributing to the failure. TGP must complete the testing and analysis as\nfollows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nb. c. d. Within 10 days of receipt of the July 9, 2021 CAO, develop and submit the\ntesting protocol and the proposed testing laboratory to the Director for prior\napproval.\nPrior to beginning the mechanical and metallurgical testing, provide the Director with\nthe scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nEnsure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to TGP.\n\n\n\n10. Root Cause Failure Analysis. Within 90 days following receipt of the ACAO,\ncomplete a root cause failure analysis (RCFA) and submit a final report of this RCFA\nto the Director. The RCFA must be supplemented or facilitated by an independent\nthird-party acceptable to the Director and must document the decision-making process\nand all factors contributing to the failure. The final report must include findings and\nany lessons learned and whether the findings and lessons learned are applicable to\nother locations within TGP’s pipeline system.\n11. Remedial Work Plan (RWP).\na. Within 90 days following receipt of the ACAO, TGP must submit a remedial\nwork plan (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\ninto this Order.\nd. e. The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures TGP will use to verify the integrity of the Affected Pipeline. It\nmust address all known or suspected factors and causes of the June 26, 2021\nfailure. TGP must consider the risks and consequences of another failure to\ndevelop a prioritized schedule for RWP- related work along the Affected Pipeline.\nThe RWP must include a procedure or process to:\ni. Identify pipe in the Affected Pipeline with characteristics similar to the\ncontributing factors identified for the June 26, 2021 failure, including the age\nand manufacture of the entire length of the Affected Pipeline.\nii. Gather all data necessary to review the failure history (in service and pressure\ntest failures) of the Affected Pipeline and to prepare a written report containing\nall the available information such as the locations, dates, and causes of leaks\nand failures.\niii. Integrate the results of the metallurgical testing, root cause failure analysis, and\nother corrective actions required by this Order with all relevant pre-existing\noperational and assessment data for the Affected Pipeline. Pre-existing\noperational data includes, but is not limited to, design, construction, operations,\nmaintenance, testing, repairs, prior metallurgical analyses, and any third-party\nconsultation information. Pre-existing assessment data includes, but is not\nlimited to, ILI tool runs, hydrostatic pressure testing, direct assessments, close\ninterval surveys, and DCVG/ACVG surveys.\niv. Determine if conditions similar to those contributing to the failure on June 26,\n2021 are likely to exist elsewhere on the Affected Pipeline.\nv. Conduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nfailure on June 26, 2021 and other failures from the failure history (see (e)(ii)\n\n\n\nf. g. above) or any other integrity threats are present elsewhere on the Affected\nPipeline. At a minimum, this process must consider all failure causes and\nspecify the use of one or more of the following:\n1) ILI tools that are technically appropriate for assessing the pipeline system\nbased on the cause of failure on June 26, 2021, and that can reliably detect\nand identify anomalies,\n2) Hydrostatic pressure testing,\n3) Close-interval surveys,\n4) Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities, overhead power\nlines, 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\nfailure causes.\nNote: TGP may use the results of previous tests, inspections, assessments,\nand evaluations if approved by the Director, provided the results of the tests,\ninspections, assessments, and evaluations are analyzed with regard to the\nfactors known or suspected to have caused the June 26, 2021 failure.\nvi. Describe the inspection and repair criteria TGP will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity\nthreats. Include a description of how any defects will be graded and a schedule\nfor repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipeline, describe the\nmethods TGP will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the pipeline failure on June 26, 2021\nand to address other known integrity threats along the Affected Pipeline. The\nrepair, replacement, or other corrective measures must meet the criteria\nspecified in (e)(vi) above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipeline\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Order.\nInclude a proposed schedule for completion of the RWP.\nTGP 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. ii. Submit any plan revisions to the Director for prior approval.\nThe Director may approve plan revisions incrementally.\n\n\n\nh. iii. All revisions to the RWP after it has been approved and incorporated by\nreference into this Order will be fully described and documented in the CAO\nDocumentation Report.\nImplement the RWP as it is approved by the Director, including any revisions to the\nplan.\n12. CAO Documentation Report (CDR). TGP must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When TGP has concluded all the items in this Order it\nwill submit the final CDR in its entirety to the Director. This will allow the Director to\ncomplete a thorough review of all actions taken by TGP with regards to this Order prior\nto approving the closure of this Order. The intent is for the CDR to summarize all\nactivities and documentation associated with this Order in one document.\na. b. 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\nOrder.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the pipeline failure of June 26, 2021 and the response activities;\nSummary of pipe data, material properties and all prior assessments of the\nAffected Pipeline;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the 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 TGP 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\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the failure\ninvestigation and remedial activities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions TGP will take on its entire pipeline\nsystemas a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\n13. Other Requirements:\nApprovals. With respect to each submission that under this Order requires the approval\nof the Director, the Director may: (a) approve, in whole or part, the submission; (b)\n\n\n\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that\nRespondent modify the submission, or (e) any combination of the above. In the event of\napproval, approval upon conditions, or modification by the Director, Respondent shall\nproceed to take all action required by the submission as approved or modified by the\nDirector. If the Director disapproves all or any portion of the submission, Respondent\nmust correct all deficiencies within the time specified by the Director and resubmit it\nfor approval.\n14. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted demonstrating\ngood cause for an extension.\n15. Reporting. Submit quarterly reports to the Director that: (1) include all available data\nand results of the testing and evaluations required by this Order; and (2) describe the\nprogress of the repairs or other remedial actions being undertaken. The first quarterly\nreport is due on September 30, 2021. The Director may change the interval for the\nsubmission of these reports.\n16. Documentation of the Costs. It is requested that Respondent maintain documentation of\nthe costs associated with implementation of this Corrective Action Order. Include in\neach monthly report submitted, the to-date total costs associated with: (1) preparation\nand revision of procedures, studies and analyses; (2) physical changes to pipeline\ninfrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, 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. 2-2021-010-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\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nfederal or state law.\n\n\n\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\nto the 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.\nJuly 23, 2021\n_____________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":36483}