{"operation":"document","citation":"CPF 22021012CAO","title":"EL PASO NATURAL GAS CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-08-19","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021012cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021012cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021012cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22021012CAO","body":"Corrective Action Order involving EL PASO NATURAL GAS CO. The dataset does not identify a cited regulation for this case. The case was opened on 2021-08-19 and is reported as closed as of 2024-09-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22021012CAO_Closure Letter_09052024_(21-220734).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021012CAO/22021012CAO_Closure%20Letter_09052024_(21-220734).pdf\n\n22021012CAO_Closure Letter_09052024_(21-220734)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021012CAO/22021012CAO_Closure%20Letter_09052024_(21-220734)_text.pdf\n\n22021012CAO_Corrective Action Order_08192021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021012CAO/22021012CAO_Corrective%20Action%20Order_08192021.pdf\n\n22021012CAO_Corrective Action Order_08192021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021012CAO/22021012CAO_Corrective%20Action%20Order_08192021_text.pdf\n\n22021012CAO_Corrective Action Order_08192021_text.pdf\n\nAugust 19, 2021\nVIA ELECTRONIC MAIL TO: kenneth grubb@kindermorgan.com\nKenneth W. Grubb\nChief Operating Officer of Gas Pipelines\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF No. 2-2021-012-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 El Paso Natural Gas Company, LLC, (EPNG or Respondent), operated\nby Kinder Morgan, Inc., to take certain corrective actions with respect to a rupture that occurred\non the 30-inch El Paso Natural Gas pipeline system in Coolidge, Arizona.\nService of the CAO by electronic transmission 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\nMr. Jaime Hernandez, Director—Engineering, Compliance/Codes & Standards, Kinder\nMorgan, jaime_hernandez@kindermorgan.com\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 )\nEl Paso Natural Gas Company, LLC, )\n)\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 2-2021-012-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 El Paso Natural Gas Company, LLC, (EPNG or Respondent), operated by\nKinder Morgan, Inc.,1 to take the necessary corrective actions to protect the public, property, and\nthe environment from potential hazards associated with the August 15, 2021 rupture of its 30-inch\nnatural gas pipeline located in Coolidge, Arizona (Incident). Coolidge is located in Pinal County,\napproximately 50 miles southeast of Phoenix, Arizona.\nAt approximately 5:40 am Mountain Standard Time (MST) on August 15, 2021, EPNG’s 30-inch\n2000 Line ruptured, resulting in an explosion and fire. The fire destroyed a farmhouse located\napproximately 412 feet north-northwest of the failure location, resulting in two fatalities and one\ninjury requiring hospitalization. A crater measuring approximately 50 feet in diameter and ten feet\nin depth resulted from the rupture. The fire also destroyed a three-foot-wide irrigation ditch and\ndamaged numerous power poles and cotton crops at distances up to 500 feet from the crater. A 46-\nfoot long section of pipe was ejected and landed approximately 50 feet south-southwest of the\ncrater. The failed pipeline reportedly released approximately 868 MMCF of natural gas during the\nIncident. Prior to the rupture, the line was reported to be operating at approximately 700 psig.\nKinder Morgan reported the downstream valve, mainline valve (MLV) 39, was closed at\napproximately 6:29 am MST and the upstream valve, MLV 37, was closed at approximately 7:00\nam MST. The State Fire Marshal and Coolidge Police Department responded to the scene. The\nfire was extinguished at 8:20 am MST. The failed section of the pipeline remains isolated.\n1 El Paso Natural Gas (EPNG) is a 10,140-mile pipeline system which transports natural gas from the San Juan,\nPermian, and Anadarko basins, to California, Arizona, Nevada, New Mexico, Oklahoma, Texas, and Northern\nMexico. EPNG also owns approximately 44 billion cubic feet of underground working natural gas storage capacity\nin Southeast New Mexico. EPNG is owned and operated by Kinder Morgan, Inc. See\nhttps://www kindermorgan.com/Operations/Natural-Gas/Index (last accessed August 17, 2021).\n\n\n\nCPF No. 2-2021-012-CAO\nPage 2\nPursuant to 49 U.S.C. §§ 60117 and 60106, PHMSA, Office of Pipeline Safety (OPS) and the\nArizona Corporation Commission (AZ CC), initiated an investigation of the Incident. The\npreliminary findings of the agencies’ ongoing investigation are outlined below. The National\nTransportation Safety Board (NTSB) is also conducting an investigation of the Incident.\nPreliminary Findings\n At approximately 5:42 am MST on August 15, 2021, EPNG’s 30-inch, 2000 Line\nruptured, resulting in an explosion and fire. The fire destroyed a farmhouse located\napproximately 412 feet north-northwest of the failure location and resulted in two\nfatalities and one injury requiring hospitalization. The fire also destroyed a\nthree-foot-wide irrigation ditch and damaged numerous power poles, and cotton crops\nat distances up to 500 feet from the failure location.\n Kinder Morgan initially reported the Incident to the National Response Center (NRC)\nat 9:24 am EDT on August 15, 2021 (NRC Report No. 1313733), indicating there was\na release and ignition of natural gas from a transmission line. Kinder Morgan submitted\na second NRC report at 11:58 am EDT on August 15, 2021 (NRC Report No. 1313743),\nreporting the fatalities and injury, providing the coordinates of the failure location and\nreporting the fire was extinguished at 8:20 am MST. Kinder Morgan submitted a third\nNRC report at 1:59 pm EDT on August 16, 2021 (NRC Report No. 1313836), reporting\na potential exceedance of the reportable quantity for nitrogen oxide may have occurred.\n The Arizona State Fire Marshal and Coolidge Police Department responded to the\nscene of the Incident. The fire was extinguished at 8:20 am MST.\n A crater measuring approximately 50 feet in diameter and ten feet in depth resulted\nfrom the rupture. A 46-foot long section of pipe was ejected and landed approximately\n50 feet south-southwest of the crater.\n The 2000 Line of the El Paso Natural Gas system is approximately 745 miles in length,\nbeginning in McCamey, Texas, and ending in Ehrenberg, Arizona. The 2000 Line\npasses through Class 1, 2, and 3 locations, including high consequence areas (HCAs).\nThe isolated section of the 2000 Line that includes the Incident location is\napproximately 39 miles in length, beginning at MLV 37 (upstream) and ending at MLV\n39 (downstream).\n The Incident occurred in a Class 1 location, non-HCA.\n The Incident occurred where the 2000 Line crosses N. Vail Road in Pinal County.\nNatural gas flowed north through a 45-degree bend in the pipeline crossing under the\nroad, then through a second 45-degree bend in the pipeline and flowed westward to\nPicacho Compressor station.\n\n\n\nCPF No. 2-2021-012-CAO\nPage 3\n The north flowing portion of the failed segment of pipeline was manufactured and\ninstalled in 1985 with a 30-inch nominal diameter, 0.281-inch wall thickness, and\nconsists of X-70 grade pipe. The pipeline has a double-submerged arc-welded\nlongitudinal seam. The pipe manufacturer and coating type are unknown.\n The portion of the pipeline crossing under N. Vail Road and continuing west was\nmanufactured and installed in 2002, with a 30-inch nominal diameter, 0.375-inch wall\nthickness, and consists of X-70 grade pipe. The pipe was manufactured by NAPA,\nhas a double-submerged arc-welded longitudinal seam, and a fusion-bonded epoxy\ncoating.\n Kinder Morgan reported the downstream valve, MLV 39, was closed at approximately\n6:29 am MST and the upstream valve, MLV 37, was closed at approximately 7:00 am\nMST on August 15, 2021. The failed section of the pipeline remains shut-in.\n Prior to the rupture, the 2000 Line was reported to be operating at approximately 700\npsig. The maximum allowable operating pressure (MAOP) of the 2000 Line is 944\npsig.\n The 2000 Line was originally owned and operated by Plains All-American Pipeline\nand transported crude oil before it was purchased by EPNG in 2000. EPNG converted\nthe system to natural gas service in 2002.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\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\n\n\n\nCPF No. 2-2021-012-CAO\nPage 4\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 that some of\nthe characteristics of the pipeline are unknown at this time, the nature of the material transported,\nthe uncertainty as to the root causes of the Incident, and potential for additional, related incidents,\nI 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:\nAffected Pipeline – The “Affected Pipeline” means EPNG’s entire 2000 Line. The 2000 Line\nstarts in McCamey, Texas, and ends in Ehrenberg, Arizona. The 2000 Line is approximately\n745 miles long.\nIsolated Segment – The \"Isolated Segment\" means the approximately 39-mile segment of the\n2000 Line from MLV 37 to MLV 39. It is the portion of the \"Affected Pipeline\" that was\nshut-in with the above-referenced upstream and downstream valves.\nPursuant to 49 U.S.C. § 60112, I hereby order EPNG to immediately take the following corrective\nactions:\n1. Shutdown of the Isolated Segment. The Isolated Segment must remain shut in and may\nnot be operated until authorized to be restarted by the Director in accordance with the terms\nof this Order.\n\n\n\n2. 3. CPF No. 2-2021-012-CAO\nPage 5\nOperating Pressure Restriction. EPNG 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 not\nexceed eighty percent (80%) of the actual operating pressure in effect at the failure location\nimmediately prior to the Incident.\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. Within 15 days of receipt of this Order, EPNG 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.\nc. This 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.\nd. When determining the pressure restriction set-points, EPNG 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.\ne. EPNG 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. EPNG must immediately reduce the operating pressure further to\nmaintain the safe operations of the Affected Pipeline, if warranted by the monthly\nreview. Further, EPNG 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. Submittals\nmay be made quarterly, in accordance with Item 15 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 2 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. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials and adjacent landowners, if\n\n\n\nCPF No. 2-2021-012-CAO\nPage 6\nf. any.\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. EPNG\nmust address any findings that require remedial measures to be implemented prior to\nrestart.\ng. 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 EPNG’s O&M procedures manual.\n4. Return to Service. After the Director approves the Restart Plan, EPNG may return the\nIsolated Segment to service according to the terms of the Restart Plan, but the operating\npressure 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 upon a\nwritten request from EPNG demonstrating that restoring the pipeline to its pre-failure\noperating pressure is justified based on a reliable engineering analysis showing that\nthe pressure 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\nrestrictions upon a written request from EPNG 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 and\nprovision of evidence that preventative and mitigative actions taken by the operator\nprovide for the safe operation of the Affected Pipeline during the temporary removal\nor modification of the pressure restriction. Appeals to determinations of the Director\nin this regard will be decided by the Associate Administrator for Pipeline Safety.\n6. Instrumented Leakage Survey. Within 30 days of receipt of this Order, EPNG must perform\nan aerial or ground instrumented leakage survey of the Affected Pipeline. EPNG must\ninvestigate all leak indications and remedy all leaks discovered. EPNG must submit\ndocumentation of this survey to the Director within 45 days of receipt of this Order.\n7. Records Verification. EPNG must verify the records for the Affected Pipeline that were used\nto establish the MAOP in accordance with § 192.619, including any adjustments needed for\nthe current class locations per §§ 192.609 and 192.611. EPNG must submit documentation of\nthis this record verification to the Director within 45 days of receipt of this Order.\n8. Review of Prior Inline Inspection (ILI) Results. Within 180 days of receipt of this Order,\nEPNG must conduct a review of any previous ILI results of the Affected Pipeline, including a\nreview of the ILI vendors' raw data and analysis. EPNG must determine whether any features\nwere present in the failed pipe joints from the Incident. Also, EPNG must determine if any\nfeatures with similar characteristics are present elsewhere on the Affected Pipeline. EPNG\n\n\n\nCPF No. 2-2021-012-CAO\nPage 7\n9. 10. must submit documentation of this ILI review to the Director within 180 days of receipt of\nthis Order as follows:\na. b. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nList, 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. Mechanical and metallurgical testing may be\nconducted by the NTSB. If the NTSB elects not to conduct the testing, EPNG must conduct\ncomplete the mechanical and metallurgical testing in accordance with the requirements of\nthis Item.\na. EPNG must complete mechanical and metallurgical testing and failure analysis of the\nfailed pipe, including an analysis of soil samples and any foreign materials, within 45\ndays of receipt of this Order.\nb. Mechanical and metallurgical testing must be conducted by an independent third-\nparty acceptable to the Director and must document the decision-making process and\nall factors contributing to the failure.\nc. EPNG must complete the testing and analysis as follows:\ni. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nii. Within 10 days of receipt of this Order, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval.\niii. Prior to beginning the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\niv. Ensure 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 EPNG.\nRoot Cause Failure Analysis (RCFA). The NTSB may conduct the root cause failure\nanalysis (RCFA). If the NTSB elects not to conduct the analysis, EPNG must conduct the\nanalysis in accordance with the requirements of this Item.\na. EPNG must complete a RCFA and submit a final report to the Director within 90\ndays following receipt of this Order.\nb. The RCFA must be supplemented or facilitated by an independent third-party\nacceptable to the Director and must document the decision-making process and all\nfactors contributing to the failure.\nc. The final report must include findings and any lessons learned and whether the\nfindings and lessons learned are applicable to other locations within EPNG’s pipeline\nsystem.\n\n\n\nCPF No. 2-2021-012-CAO\nPage 8\n11. Remedial Work Plan (RWP).\na. Within 90 days following receipt of this Order, EPNG must submit a remedial work plan\n(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 EPNG will use to verify the integrity of the Affected Pipeline. It must address\nall known or suspected factors and causes of the Incident. EPNG must consider the risks\nand consequences of another failure to develop a prioritized schedule for RWP-related\nwork 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 contributing\nfactors identified for the Incident, including the age and manufacture of the entire\nlength of the Affected Pipeline.\nii. Gather 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.\niii. Integrate 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.\niv. Determine if conditions similar to those contributing to the Incident are likely to exist\nelsewhere on the Affected Pipeline.\nv. Conduct additional field tests, inspections, assessments, and evaluations to determine\nwhether, and to what extent, the conditions associated with the Incident, and other\nfailures from the failure history (see (e)(ii) above) or any other integrity threats are\npresent elsewhere on the Affected Pipeline. At a minimum, this process must\nconsider all failure causes and specify 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 the Incident, and that can reliably detect and identify\nanomalies,\n2) Hydrostatic pressure testing,\n3) Close-interval surveys,\n4) Cathodic protection surveys, to include interference surveys in coordination\nwith other utilities (e.g. underground utilities, overhead power lines, etc.) in\nthe area,\n5) Coating surveys,\n\n\n\nCPF No. 2-2021-012-CAO\nPage 9\n12. 6) Stress corrosion cracking surveys,\n7) 8) Selective seam corrosion surveys; and\nOther tests, inspections, assessments, and evaluations appropriate for the\nfailure causes.\nNote: EPNG may use the results of previous tests, inspections, assessments, and\nevaluations if approved by the Director, provided the results of the tests, inspections,\nassessments, and evaluations are analyzed with regard to the factors known or\nsuspected to have caused the Incident.\nvi. Describe the inspection and repair criteria EPNG 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.\nvii. Based on the known history and condition of the Affected Pipeline, describe the\nmethods EPNG will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the Incident and to address other known\nintegrity threats along the Affected Pipeline. The repair, replacement, or other\ncorrective measures must meet the criteria specified in (e)(vi) above.\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.\nEPNG 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). EPNG must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When EPNG 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 EPNG 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:\n\n\n\nCPF No. 2-2021-012-CAO\nPage 10\ni. Table of Contents;\nii. iii. Summary of the Incident 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 EPNG 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\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 EPNG 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:\n13. 14. 15. 16. 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, 2021. The Director may change the interval for the submission of these reports.\nDocumentation of the Costs. It is requested that Respondent maintain documentation of the\ncosts associated with implementation of this Corrective Action Order. Include in each monthly\nreport submitted, the to-date total costs associated with: (1) preparation and revision of\n\n\n\nCPF No. 2-2021-012-CAO\nPage 11\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure, including\nrepairs, replacements and other modifications; and (3) environmental remediation, if\napplicable.\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. 2-2021-012-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 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.\nAugust 19, 2021\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n22021012CAO_Closure Letter_09052024_(21-220734)_text.pdf\n\nVIA ELECTRONIC MAIL TO: kenneth grubb@kindermorgan.com;\nJaime Hernandez@kindermorgan.com;Tom Otjen@kindermorgan.com\nSeptember 5, 2024\nKenneth W. Grubb\nChief Operating Officer of Gas Pipelines\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF No. 2-2021-012-CAO\nDear Mr. Grubb:\nOn September 13, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to El Paso Natural Gas Company, L.L.C. (EPNG), an Amended Corrective Action Order\n(CAO) in the above-referenced case. This Amended CAO included several required corrective\nactions. Based on our review of the documentation provided, it has been determined that EPNG\nhas complied with the terms of the Amended CAO.\nAccordingly, this case is now closed, and no further action is necessary. Please be advised that\nthis letter refers only to the referenced Amended CAO (CPF #2-2021-012-CAO) and not to other\nPHMSA cases, if any. Thank you for your cooperation in this matter.\nSincerely,\nJames A. Urisko\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":33603}