{"operation":"document","citation":"CPF 22022007CAO","title":"SOUTHERN NATURAL GAS CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-18","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22022007cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22022007cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22022007cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22022007CAO","body":"Corrective Action Order involving SOUTHERN NATURAL GAS CO. The dataset does not identify a cited regulation for this case. The case was opened on 2022-02-18 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\n22022007CAO_Closure Letter_09082023_(22-235908).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22022007CAO/22022007CAO_Closure%20Letter_09082023_(22-235908).pdf\n\n22022007CAO_Closure Letter_09082023_(22-235908)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22022007CAO/22022007CAO_Closure%20Letter_09082023_(22-235908)_text.pdf\n\n22022007CAO_Corrective Action Order_02182022_(22-235908).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22022007CAO/22022007CAO_Corrective%20Action%20Order_02182022_(22-235908).pdf\n\n22022007CAO_Corrective Action Order_02182022_(22-235908)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22022007CAO/22022007CAO_Corrective%20Action%20Order_02182022_(22-235908)_text.pdf\n\n22022007CAO_Closure Letter_09082023_(22-235908)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom martin@kindermorgan.com;\nsteve kean@kindermorgan.com; kenneth grubb@kindermorgan.com;\nSeptember 8, 2023\nSouthern Natural Gas Company\nThomas Martin, President\n1001 Louisiana Street\nSuite 1000\nHouston, Texas 77002\nCPF 2-2022-007-CAO\nDear Mr. Martin:\nOn February 18, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Southern Natural Gas Company (SNG), a Corrective Action Order in the above-\nreferenced case. This Order included a requirement to take corrective actions on your pipeline.\nBased on PHMSA’s review of the documentation provided by SNG, it has been determined that\nSNG has complied 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\n22022007CAO_Corrective Action Order_02182022_(22-235908)_text.pdf\n\nFebruary 18, 2022\nVIA ELECTRONIC MAIL TO: kenneth grubb@kindermorgan.com\nMr. Kenneth Grubb\nChief Operating Officer\n1001 Louisiana St.\nSuite 1000\nHouston, Texas 77002\nRe: CPF No. 2-2022-007-CAO\nDear Mr. Grubb,\nEnclosed please find a Corrective Action Order (CAO or Order) issued by the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the\nabove-referenced case. It requires Southern Natural Gas Co., a subsidiary of Kinder Morgan,\nInc., to take certain corrective actions with respect to a pipeline failure that occurred on\nFebruary 13, 2022, on the 18-inch South Main Line in Perry County, Alabama.\nService of the CAO by electronic mail is effective upon the date of transmission and\nacknowledgment of receipt as provided under 49 C.F.R. § 190.5. The terms and conditions of\nthis Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA\nMr. Jaime Hernandez – Director – Engineering: Codes and Standards, Kinder Morgan,\njaime_hernandez@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 )\n)\n)\nSouthern Natural Gas Co., )\na subsidiary of Kinder Morgan, Inc. )\nRespondent. )\n____________________________________)\n) CPF No. 2-2022-007-CAO\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority\nof 49 U.S.C. § 60112, to require Southern Natural Gas Co. (SNG or Respondent), a subsidiary of\nKinder Morgan, Inc.,1 to take necessary corrective actions to protect the public, property, and the\nenvironment from potential hazards associated with the February 13, 2022, natural gas pipeline\nfailure that occurred on the 18-inch South Main Line at mile post 155.7, resulting in a rupture\nand fire, in Perry County, Alabama (Incident).\nThe South Main System consists of approximately 504 right-of-way (ROW) miles of the 18-inch\nand 16-inch South Main Line and multiple large diameter loop lines traversing from Gwinville,\nMississippi (MP 0) to Aiken, South Carolina (MP 504). The South Main System is in\nMississippi, Alabama, Georgia, and South Carolina. Approximately 379 miles of the 16- and 18-\ninch South Main Line were declared in-service in 1951, including the failed pipe. The 18-inch\nportion of the South Main Line terminates and transitions to the 16-inch diameter South Main\nLine at the Elmore Compressor Station in Elmore, Alabama. SNG’s above-referenced loop lines\nin the common ROW at the failure location are the South Main Loop, South Main 2nd Loop, and\nSouth Main 3rd Loop.\nAt approximately 04:42 PM Central Standard Time (CST) the pipeline ruptured, ejecting a\nfive-foot section of the pipe approximately 72 feet and initiating a fire that burned nearby\nvegetation. A Perry County, Alabama, resident called the Kinder Morgan Gas Control to report a\nfire had been observed on SNG’s pipeline ROW.\n1 Southern Company, Kinder Morgan Enter Southern Natural Gas Pipeline Strategic Venture, Kinder Morgan (July\n10, 2016), https://ir.kindermorgan.com/news/news-details/2016/Southern-Company-Kinder-Morgan-Enter-\nSouthern-Natural-Gas-Pipeline-Strategic-Venture/default.aspx.\n\n\n\nUpon being notified of the Incident, Respondent’s personnel isolated the line at mainline valve\n(MLV) #1 located at Gate #18 and MLV #1 located at Gate #19, upstream and downstream,\nrespectively, of the failure location to depressurize the line and extinguish the fire. Subsequently,\nSNG personnel isolated the adjacent 18-inch South Main Loop line and performed an inspection\nof the pipeline failure site. Respondent estimated a volume release of 171,159 MCF of natural\ngas.\nThe pressure was not reduced on the remaining adjacent lines (the South Main 2nd Loop and the\nSouth Main 3rd Loop). The pressure in the 18-inch South Main Loop has been restored to\nnormal operating pressure. The failed 18-inch South Main Line is currently shut-in.\nPursuant to 49 U.S.C. § 60117, PHMSA initiated an investigation of the Incident. The\npreliminary findings of the Agency’s ongoing investigation are as follows:\nPreliminary Findings\n At approximately 04:42 PM CST on February 13, 2022, a natural gas pipeline failure\noccurred on the 18-inch South Main Line at Mile Post (MP) 155.7, resulting in rupture\nand fire, in Perry County, Alabama. The town nearest to the location of the Incident is\nUniontown, Alabama.\n The rupture ejected a five-foot section of the pipe approximately 72 feet and initiated a\nfire that burned nearby vegetation. The Incident occurred in a Class 1 area and a non-high\nconsequence area (HCA). There were no reported fatalities, injuries, or evacuations.\n A Perry County, Alabama, resident called Kinder Morgan Gas Control to report a fire had\nbeen observed on SNG’s pipeline right-of-way.\n Respondent reported the Incident to the National Response Center (NRC) at 06:34 PM\nEastern Standard Time (EST) on February 13, 2022. SNG gave an updated report to the\nNRC at 02:25 PM EST on February 15, 2022.\n After being notified of the Incident, SNG personnel closed main line valves on the South\nMain Line at MLV #1 at Gate #18 and MLV #1 at Gate #19, upstream and downstream,\nrespectively, of the failure location to depressurize the line and extinguish the fire.\n After extinguishing the fire, SNG personnel isolated the adjacent 18-inch South Main\nLoop line and performed an inspection of the pipeline failure site. Respondent estimated\na volume release of 171,159 MCF.\n The pressure was not reduced on the remaining loop lines: the South Main 2nd Loop and\nthe South Main 3rd Loop.\n The pressure in the 18-inch South Main Loop line has been restored to normal operating\npressure. The failed South Main Line is currently shut-in.\n\n\n\n The South Main Line was manufactured in 1951. It is an A.O. Smith pipe with flash weld\nlongitudinal seam, 0.312 wall thickness, API 5L grade X52 (52,000 pounds per square\ninch specified minimum yield strength), with coal tar enamel coating.\n Approximately 379 miles of the 16- and 18-inch South Main Line were declared\nin-service in 1951, including the failure pipe.\n Prior to the failure, the 18-inch South Main Line operated at pressure of 1170 pounds per\nsquare inch gauge (psig).\n The maximum allowable operating pressure (MAOP) of the 18-inch South Main Line is\n1200 psig.\n In March 2008, in Sumter County, Alabama, the 18-inch, 1951 A.O. Smith flash weld\npipe (X52) on the South Main Line experienced a girth weld failure. The girth weld failed\ndue to high tensile stresses likely due to improper backfill from recent excavation.\nMetallurgical analysis revealed the girth weld was found to be deficient from the original\nconstruction.\n This line was assessed in 2014 with a magnetic flux leakage in-line inspection tool.\n The cause of the Incident is currently unknown. While probable cause has not yet been\nestablished, the failed pipe was 1951 vintage, manufactured by A.O. Smith with a flash\nweld longitudinal seam, which has a history of being susceptible to significant anomalies\ndue to inconsistent weld seam quality and hard spots. Additionally, pipe having low-\nfrequency, flash-welded longitudinal seams are a known threat to pipeline integrity under\ncertain conditions.\n Pre-1970 low-frequency electric resistance weld (ERW) pipe, including flash welded\npipe, has been the focus of many studies and reviews. A final report TTO Number 5,\nIntegrity Management Program Delivery Order DTRS56-02-D-70036, Integrity\nManagement Program regarding Low Frequency ERW and Lap Welded Longitudinal\nSeam Evaluation (Revision 3) was prepared by Michael Baker in association with\nKiefner and Associates, Inc., CorrMet Engineering Services, PC, in April 2004. The\nreport was written to support the importance of operators correctly selecting integrity\nassessment methods capable of assessing seam integrity and of detecting corrosion and\ndeformation anomalies.\n The Battelle Memorial Institute issued a report on the integrity characteristics of vintage\npipelines in 2005. The Battelle study stated that hard spots develop during hot rolling of a\nsteel plate when an uncontrolled jet of water locally cools a portion of the plate too\nquickly. The water quenched areas form untampered martensite, with hardness levels\nlocally much higher than the remainder of the pipe. If the coating does not have good\nadhesion or has been damaged, it can be exposed to hydrogen. If cathodic protection (CP)\nlevels are above or below certain voltage levels, hydrogen can be generated. Typically,\nthis occurs in pipelines that operate at higher stress levels.\n\n\n\n ERW pipe manufactured prior to 1970 has a history of increased risk of seam failures.\nPHMSA issued two advisory bulletins (ALN-88-01 on January 28, 1988, and ALN-89-01\non March 8, 1989) regarding factors contributing to operational failures of pipelines\nconstructed with ERW pipe manufactured prior to 1970. PHMSA identified selective\ncorrosion of the ERW seam as a contributing cause of failure in a significant number of\nthese accidents. Other failures have occurred due to the growth of manufacturing defects\nin ERW seams. The advisory bulletins recommended that operators reevaluate the\npotential for safety problems on their high-pressure pre-1970 ERW pipelines by\nhydrostatic testing on those pipelines, ensuring the effectiveness of cathodic protection\nsystems, and taking additional safety measures.\n Under 192.917(e), if a covered pipeline segment contains ERW pipe, lap welded pipe, or\nother conditions specified in ASME/ANSI B31.8S, Appendices A4.3 and A4.4, and any\ncovered or noncovered segment in the pipeline system with such pipe has experienced\nseam failure, or operating pressure on the covered segment has increased over the\nmaximum operating pressure experienced during the preceding five years, an operator\nmust select an assessment technology or technologies with a proven application capable\nof assessing seam integrity and seam corrosion anomalies. The failure location appears to\nbe a non-covered pipeline segment.\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 is 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\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider as\nappropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the pipeline, including the prior failure of the pipeline and the known issues\nwith 1951 A.O. Smith pipe with a flash weld longitudinal seam; the known threat to pipeline\nintegrity from pipe having low-frequency, flash-welded longitudinal seams; the hazardous nature\nof the material (natural gas) transported; the uncertainty as to the root cause of the Incident; the\n\n\n\nimpacts to property, the environment, and wildlife, and the risk of additional, related incidents;\nand the possibility that the same condition(s) that may have caused the failure remain present in\nthe pipeline; I find that continued operation of the Affected Pipeline, as defined below, without\ncorrective measures is or would be hazardous to life, property, or the environment, and that\nfailure to issue this Order expeditiously would result in the likelihood of serious harm.\nAccordingly, this Order mandating immediate corrective action is issued expeditiously without\nprior notice and opportunity for a hearing. The terms and conditions of this Order are effective\nupon 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, PHMSA, OPS Southern Region. 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 approximately 221 miles of SNG’s South\nMain pipeline that contains the 18-inch diameter, 1951 vintage A.O. Smith X52 pipe from\nGwinville Compressor Station in Gwinville, Mississippi (MP 0) to Elmore Compressor Station\nin Elmore, Alabama (MP 221.6). The “Affected Pipeline” traverses the following counties in\nMississippi: Jefferson Davis, Simpson, Smith, Jasper, Clarke, and Lauderdale; and the following\ncounties in Alabama: Sumter, Marengo, Hale, Perry, Dallas, Autauga, and Elmore.\nIsolated Segment – The \"Isolated Segment\" means the approximately 8.3-mile segment of\nSNG’s South Main Line that contains the 18-inch 1951 vintage A.O. Smith X52 pipe from Gate\n#18 (MP 150.783) to Gate #19 (MP 159.054). It is the portion of the “Affected Segment” that was\nshut-in after the failure on February 13, 2022, and must remain shut-in until a restart plan is\napproved by the “Director.”\nDirector – The \"Director\" means the Director, PHMSA, OPS Southern Region.\nPursuant to 49 U.S.C. 60112, I hereby order SNG to take the following corrective 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. SNG must reduce and maintain a twenty percent\n(20%) pressure reduction in the actual operating pressure along the entire length of the\n\n\n\n3. 4. 5. 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\nat the failure location, immediately prior to the failure on February 13, 2022.\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. Within 15 days of receipt of the CAO, SNG 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, software\nprogramming set-points or control points, and mechanical over-pressure devices to\nbe adjusted accordingly.\nWhen determining the pressure restriction set-points, SNG 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. SNG must review the pressure restriction monthly by analyzing the operating pressure\ndata, taking into account any ILI features or anomalies present in the Affected\nPipeline. SNG must immediately reduce the operating pressure further to maintain the\nsafe operations of the Affected Pipeline, if warranted by the monthly review. Further,\nSNG must submit the results of the monthly review to the Director including, at a\nminimum, the current discharge set-points (including any additional pressure\nreductions), and any pressure exceedance at discharge set-points. Submittals may be\nmade quarterly, in accordance with Item 15 below.\nInstrumented Leakage Survey. Within 30 days of receipt of the CAO, SNG must\nperform an aerial or ground instrumented leakage survey of the Affected Pipeline. SNG\nmust investigate all leak indications and remedy all leaks discovered. SNG must\nsubmit documentation of this survey to the Director within 45 days of receipt of the\nCAO.\nRecords Verification. SNG 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. SNG must submit\ndocumentation of this record verification to the Director within 45 days of receipt of\nthe CAO. See PHMSA Advisory Bulletin 2012-06 for additional information\nregarding records verification.\nReview of Prior In-line Inspection (ILI) Results.\na. Within 30 days of receipt of the CAO, SNG must conduct a review of any previous\nILI results of the Affected Pipeline. In its review, SNG must re-evaluate all ILI\nresults from the past 10 calendar years, including a review of the ILI vendors' raw\ndata and analysis. SNG must determine whether any features were present in the\nfailed pipe joints from the February 13, 2022, failure. Also, SNG must determine if\n\n\n\nany features with similar characteristics are present elsewhere on the Affected\nPipeline. SNG must submit documentation of this ILI review to the Director within\n45 days of receipt of the CAO, as follows:\ni. ii. 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\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.\n6. Mechanical and Metallurgical Testing. Within 45 days of receipt of the CAO, SNG\nmust complete mechanical and metallurgical testing and failure analysis of the failed\npipe, including an analysis of soil samples and any foreign materials. Mechanical and\nmetallurgical testing must be conducted by an independent third-party acceptable to\nthe Director, and must document the decision-making process and all factors\ncontributing to the failure. SNG must complete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nb. c. Within 10 days of receipt of the CAO, develop and submit the testing protocol\nand the proposed testing laboratory to the Director for prior approval.\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.\nd. 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 SNG.\n7. Root Cause Failure Analysis. Within 90 days following receipt of the CAO,\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\nprocess and all factors contributing to the failure. The final report must include\nfindings and any lessons learned and whether the findings and lessons learned are\napplicable to other locations within SNG’s pipeline system.\n8. Remedial Work Plan (RWP).\na. Within 90 days following receipt of the CAO, SNG 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\ninto this Order.\n\n\n\nd. e. The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures SNG will use to verify the integrity of the Affected Pipeline. It\nmust address all known or suspected factors and causes of the February 13, 2022,\nfailure. SNG 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 February 13, 2022, failure, including the\nage and 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. iv. 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.\nDetermine if conditions similar to those contributing to the failure on\nFebruary 13, 2022, 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 failure\non February 13, 2022, and other failures from the failure history (see (e)(ii)\nabove) 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 February 13, 2022, and that can reliably\ndetect and 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\npower 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\nfailure causes.\nNote: SNG may use the results of previous tests, inspections, assessments,\n\n\n\n9. vi. vii. viii. f. g. i. ii. iii. and 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 February 13, 2022, failure.\nDescribe the inspection and repair criteria SNG 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.\nBased on the known history and condition of the Affected Pipeline, describe the\nmethods SNG will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the pipeline failure on February 13,\n2022, and to address other known integrity threats along the Affected Pipeline.\nThe repair, replacement, or other corrective measures must meet the criteria\nspecified in (e)(vi) above.\nImplement 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.\nSNG must revise the RWP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of\nactions undertaken pursuant to this Order, and to incorporate modifications required\nby the Director.\nSubmit any plan revisions to the Director for prior approval.\nThe Director may approve plan revisions incrementally.\nAll 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.\nh. Implement the RWP as it is approved by the Director, including any revisions to\nthe plan.\nCAO Documentation Report (CDR). SNG must create and revise, as necessary, a\nCAO Documentation Report (CDR). When SNG has concluded all the items in this\nOrder it will submit the final CDR in its entirety to the Director. This will allow the\nDirector to complete a thorough review of all actions taken by SNG with regards to\nthis Order prior to approving the closure of this Order. The intent is for the CDR to\nsummarize all activities and documentation associated with this Order in one\ndocument.\na. The Director may approve the CDR incrementally without approving the entire CDR.\nb. Once 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;\n\n\n\nii. iii. iv. v. vi. vii. viii. ix. x. Summary of the pipeline failure of February 13, 2022, and the response activities;\nSummary of pipe data, material properties, and all prior assessments of the\nAffected Pipeline;\nSummary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the Order;\nSummary 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 SNG to implement the RWP, the results\nof those actions, and the inspection and repair criteria used;\nDocumentation 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;\nLessons learned while completing this Order;\nA path forward describing specific actions SNG will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\n10. Restart Plan. Prior to resuming operation of the Isolated Segment, develop and\nsubmit a written 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\nis approved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by\nreference into this Order.\nc. d. The 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.\ne. The Restart Plan must specify a daylight restart and include advance\ncommunications with local emergency response officials and adjacent\nlandowners.\nf. 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. SNG\nmust address any findings that require remedial measures to be implemented prior\n\n\n\nto restart.\ng. The 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 SNG’s O&M procedures manual.\n11. Return to Service. After the Director approves the Restart Plan, SNG may\nresume operation of the Isolated Segment according to the terms of the Restart\nPlan, but the operating pressure must not exceed the limit in accordance with\nItem 2 above.\n12. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction\nupon a written request from SNG 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 SNG 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.\nOther Requirements:\n13. Approvals. With respect to each submission under this Order that requires the\napproval of the Director, the Director may: (a) approve, in whole or part, the\nsubmission; (b) approve the submission on specified conditions; (c) modify the\nsubmission to cure any deficiencies; (d) disapprove in whole or in part, the\nsubmission, directing that Respondent modify the submission, or (e) any\ncombination of the above. In the event of approval, approval upon conditions, or\nmodification by the Director, Respondent shall proceed to take all action required\nby the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all\ndeficiencies within the time specified by the Director and resubmit it for approval.\n14. Extensions of Time. The Director may grant an extension of time for compliance\nwith any of the terms of this Order upon a written request timely submitted\ndemonstrating good 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\n\n\n\nprogress of the repairs or other remedial actions being undertaken. The first quarterly\nreport is due on March 31, 2022. The Director may change the interval for the\nsubmission of these reports.\n16. Documentation of the Costs. It is requested that Respondent maintain\ndocumentation of the costs associated with implementation of this CAO. Include in\neach monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements and other modifications; and\n(3) environmental remediation, if applicable.\nBe advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. § 552(b), along with the complete original\ndocument you must provide a second copy of the document with the portions you believe\nqualify for confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 2-2022-007-CAO” and for\neach document you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply\nto Respondent’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.\nRespondent may appeal any decision of the Director to the Associate Administrator for\nPipeline Safety. 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.\nFebruary 18, 2022\n_____________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":36671}