{"operation":"document","citation":"CPF 22024009CAO","title":"TENNESSEE GAS PIPELINE COMPANY — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-02-07","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024009cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024009cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024009cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22024009CAO","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 2024-02-07 and is reported as closed as of 2025-03-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22024009CAO_Closure Letter_03062025_(24-298988).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024009CAO/22024009CAO_Closure%20Letter_03062025_(24-298988).pdf\n\n22024009CAO_Closure Letter_03062025_(24-298988)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024009CAO/22024009CAO_Closure%20Letter_03062025_(24-298988)_text.pdf\n\n22024009CAO_Corrective Action Order (Amended)_02092024_(24-298988).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024009CAO/22024009CAO_Corrective%20Action%20Order%20(Amended)_02092024_(24-298988).pdf\n\n22024009CAO_Corrective Action Order (Amended)_02092024_(24-298988)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024009CAO/22024009CAO_Corrective%20Action%20Order%20(Amended)_02092024_(24-298988)_text.pdf\n\n22024009CAO_Corrective Action Order_02072024_(24-298988).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024009CAO/22024009CAO_Corrective%20Action%20Order_02072024_(24-298988).pdf\n\n22024009CAO_Corrective Action Order_02072024_(24-298988)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024009CAO/22024009CAO_Corrective%20Action%20Order_02072024_(24-298988)_text.pdf\n\n22024009CAO_Closure Letter_03062025_(24-298988)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Tom martin@kindermorgan.com\nMarch 6, 2025\nThomas Martin\nPresident/CEO\nTennessee Gas Pipeline Company, LLC\n1001 Louisiana Street\nSuite 1000\nHouston, TX 77002\nRe: CPF No. 2-2024-009-CAO\nDear Mr. Martin:\nOn February 7, 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Tennessee Gas Pipeline Company, LLC, pursuant to 49 CFR § 190.233, a Corrective\nAction Order in the above-referenced case. This Order included a requirement to take corrective\nactions on your pipeline. PHMSA issued an amended Corrective Action Order on February 9,\n2024, amending certain of the corrective actions related to shutdown of the pipeline. Based on\nour review of the documentation you have provided, PHMSA has determined that you have\ncomplied with the terms of the Order and the amended Order.\nAccordingly, this case is now closed, and no further action is required. Thank you for your\ncooperation in this matter.\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n22024009CAO_Corrective Action Order (Amended)_02092024_(24-298988)_text.pdf\n\nFebruary 9, 2024\nVIA ELECTRONIC MAIL TO: tom martin@kindermorgan.com\nThomas Martin\nPresident/CEO – Gas Pipelines\nTennessee Gas Pipeline Company, LLC\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: CPF No. 2-2024-009-CAO\nDear Mr. Martin,\nEnclosed please find an Amended Corrective Action Order (Amended CAO or Amended Order)\nissued by the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of\nPipeline Safety (OPS), in the above-referenced case. It requires Tennessee Gas Pipeline\nCompany, LLC, to take certain corrective actions with respect to a pipeline failure that occurred\non February 3, 2024, on your Line 100 natural gas pipeline system in Panola County,\nMississippi.\nService of the Amended 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: Amended CAO\ncc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA\nMr. Zach Ragain, Director – Engineering, Compliance/Codes & Standards,\nTennessee Gas Pipeline Company, LLC, zach_ragain@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____________________________________\n)\nIn the Matter of )\n)\nTennessee Gas Pipeline Company, LLC ) CPF No. 2-2024-009-CAO\n)\nRespondent. )\n)\n____________________________________)\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background\nThis Amended Corrective Action Order (Amended CAO or Order) is being issued by the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), under the authority of 49 U.S.C. § 60112, to require Tennessee Gas Pipeline Company,\nLLC (Tennessee Gas or Respondent), to take necessary corrective actions to protect the public,\nproperty, and the environment from potential hazards associated with the February 3, 2024,\nnatural gas pipeline failure that occurred on Line 100 natural gas transmission pipeline system in\nPanola County, Mississippi (Failure).\nThe Line 100 system is an approximately 1,400-mile natural gas pipeline system that runs in a\nnortheasterly direction from Texas to West Virginia.\n1 It is composed of four parallel, looped\npipeline systems that are generally located in a common right-of-way (ROW): Line 100-1, Line\n100-2, Line 100-3, and Line 100-4. The February 3, 2024, Failure occurred on Line 100-1.\nAt approximately 01:03 AM Eastern Time a caller reported to Tennessee Gas a release of natural\ngas near Sardis, a town in Panola County, Mississippi. Respondent subsequently isolated a\nsection of Line 100-1 and blew it down to stop the leak. Line 100-1 has been removed from\nservice. Lines 100-2, 100-3, and 100-4 continue in operation. Line 100-1 was operating at 727\npounds per square inch gauge (psig) in a Class 1 area at the time of the release.\n1 The Tennessee Gas Pipeline, in its totality, is an approximately 11,760-mile pipeline system\nthat transports natural gas supplied from the Northeastern section of the United States to markets\nincluding the Northeast, Louisiana, the Texas Gulf Coast, and Mexico. See Interstate Operations,\nKINDER MORGAN, https://www.kindermorgan.com/Operations/Natural-Gas/Index#tabs-interstate\n(last accessed February 5, 2024).\n\n\n\nA failed wrinkle bend is suspected to be the cause of the release. The Failure occurred on the\nsame line and in the same general area as a November 21, 2011, failure that also stemmed from a\nwrinkle bend failure. The prior failure resulted in a Corrective Action Order issued on November\n28, 2011, which required, among other corrective actions, the operator to develop and implement\nan integrity testing plan that emphasized identifying and evaluating: 1) anomalies associated with\nwrinkle bends repaired by sleeves, and 2) dents, gouges, and grooves repaired by sleeves.2\nOn February 7, 2024, PHMSA issued a Corrective Action Order requiring Tennessee Gas to take\ncertain necessary corrective actions on Line 100-1. This Amended CAO amends certain of those\ncorrective actions related to shutdown of the pipeline.\nPursuant to 49 U.S.C. § 60117, PHMSA has initiated an investigation of the Failure. The\npreliminary findings of the Agency’s ongoing investigation are as follows:\nPreliminary Findings\n• On February 3, 2024, at approximately 01:03 AM Eastern Time, a caller reported to\nTennessee Gas a release of natural gas near Sardis, Mississippi. No fire or injuries were\nreported. At the time of this report, Respondent had not yet detected the release.\n• Kinder Morgan’s supervisory control and data acquisition (SCADA) personnel received\ncalls from the Panola County Sheriff Department and three calls from the public\nregarding the sound of a gas pipeline leak.\n• Tennessee Gas is a subsidiary of Kinder Morgan.\n• A Tennessee Gas employee notified the National Response Center (NRC) at 03:12 AM\nEastern Time on February 3, 2024. The caller reported a release of natural gas from a\ntransmission pipeline. At the time of the notification, the cause of the release was\nunknown. A second report to the NRC was made on February 4, 2024, at 08:57 PM\nEastern Time.\n• After receiving notification of the release, Tennessee Gas technicians located the leak.\nThe site of the Failure was on Line 100-1, approximately three-and-a-half miles east of\nSardis, Mississippi, between mainline valves (MLV) 64-1 and 65-1.\n• After locating the leak, Tennessee Gas technicians isolated the leak by closing valves\n64-1, 64A-101.1A, and 65-1. The isolated section of Line 100-1 was then blown down to\nstop the leak.\n• At the time of the Failure, Line 100-1 was operating at 727 psig. The maximum\nallowable operating pressure of Line 100-1 is 750 psig.\n2 CPF 2-2011-1010H (November 28, 2011).\n\n\n\n• Tennessee Gas reported that approximately 16,022 cubic feet (Mcf) of natural gas was\nlost as a result of the incident.\n• Three homes near the site of the Failure were evacuated, but residents were allowed to\nreturn to their homes after the pipe was blown down.\n• The Tennessee Gas Pipeline, in its totality, is an approximately 11,760-mile pipeline\nsystem that runs from the Gulf of Mexico in Texas and Louisiana up through Mississippi,\nArkansas, Tennessee, Alabama, Kentucky, Ohio, Pennsylvania, to the New England\nstates.\n• The Line 100 system is a 1,400-mile natural gas pipeline system that runs in a\nnortheasterly direction from Texas to West Virginia. It is composed of four parallel,\nlooped pipeline systems that are generally located in a common right-of-way (ROW):\nLine 100-1, Line 100-2, Line 100-3, and Line 100-4. The pipelines are one 24-inch, one\n26-inch, and two 30-inch diameter pipelines, respectively.\n• The segment of Line 100-1 that failed was originally constructed in 1944. The pipe at the\nfailure location is 0.281 inches thick, API 5L grade X45, seamless, and was\nmanufactured by National Tube. The pipeline has a coal tar coating.\n• Respondent cut out the section of the isolated segment that contained the wrinkle bends\nfor metallurgical analysis. Lines 100-2, 100-3, and 100-4 continue in operation. No\noutages occurred because delivery to one city gate was shifted to another line.\n• The cause of the failure is suspected to be a failed wrinkle bend. Visual inspection of the\npipe indicated a leak at a wrinkle bend. There were three wrinkles in a row, located on\ntop of the pipe. Of the three wrinkles, it appears the southwest most wrinkle leaked. In-\nline inspection (ILI) information described wrinkle bends with an approximate one-inch\nmaximum displacement. The three wrinkle bends comprise a sag bend.\n• In 1946, a wrinkle bend on Line 100-1 was repaired with a field-fabricated, pressure-\ncontaining sleeve after a leak was discovered. That sleeve is located at a low point in the\nline between two river weights.\n• A wrinkle bend failure occurred on April 24, 1992, on the Line 100-2, 26-inch diameter\npipeline. The leak occurred between MLV 64 and 65.\n• Another wrinkle bend failure occurred on January 22, 2018, on Line 100-1 between MLV\n63-1 and 64-1. This failure resulted in a leak causing an approximately 4-foot-deep\nhole/crater with a diameter of about 6 feet.\n• The February 3, 2024, Failure also occurred on the same line (Line 100-1) and in the\nsame general area as a November 21, 2011, failure that stemmed from a cracked wrinkle\nbend between MLV 63-1 and 64-1. The prior failure resulted in Corrective Action Order\n\n\n\n(CAO) CPF 2-2011-1010H, issued on November 28, 2011. The CAO called on\nRespondent to take certain corrective actions, to include identification of all pipe in the\naffected section of Line 100-1 with characteristics similar to the contributing factors\nidentified for the November 21, 2011, failure.\n• The investigation of the February 3, 2024, Failure is on-going, and information could\nchange. This order may be amended based on further findings during the investigation.\n• On February 7, 2024, PHMSA issued a Corrective Action Order requiring Tennessee Gas\nto take certain necessary corrective actions on Line 100-1 to protect the public, property,\nand the environment from potential hazards associated with the February 3, 2024,\nFailure.\nDetermination of Necessity for Amended 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 failures of the pipeline; the hazardous nature of\nthe material (natural gas) transported; the uncertainty as to the root cause(s) of the Failure; the\nleak was not detected; the existing and potential additional impacts to property, the environment,\nand wildlife; and the possibility that the same condition(s) that may have caused the Failure\nremain present in the pipeline and could lead to additional failures; I find that continued\noperation of the Affected Segment, as defined below, without corrective measures is or would be\nhazardous to life, property, or the environment, and that failure to issue this Amended Order\nexpeditiously would result in the likelihood of serious harm.\n\n\n\nAccordingly, this Amended Order mandating immediate corrective action is issued expeditiously\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Amended\nOrder are effective upon receipt.\nWithin 10 days of receipt of this Amended Order, Respondent may request a hearing, to be held\nas soon as practicable, by notifying the Associate Administrator for Pipeline Safety in writing,\nwith a copy to the Director, PHMSA, OPS Southern Region. If a hearing is requested, it will be\nheld in accordance 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 Amended\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 Segment – The “Affected Segment” means the approximately 175 miles of Tennessee\nGas’ Line 100-1, 24-inch pipeline at MLV 53-1B at Refuge Road in Washington County,\nMississippi through Greenville Compressor Station No. 54 in Washington County, Mississippi;\nBatesville Compressor Station No. 63 in Panola County, MS, and terminating at the Middleton\nCompressor Station No. 71 at MLV 70-1 in Hardeman County, Tennessee. The Affected Segment\ngenerally runs northerly and passes through portions of Washington, Bolivar, Sunflower,\nTallahatchie, Quitman, Panola, Lafayette, Tate, Marshall, and Benton counties in Mississippi and\nHardeman County in Tennessee. The Affected Segment corresponds to the segment of pipeline\nthat experienced wrinkle bend failures in 2011, 2018, and the February 3, 2024, Failure.\nIsolated Segment – The “Isolated Segment” means the approximately 10-mile segment of Line\n100-1 from MLV 64-1 to MLV 65.1. The Isolated Segment is the portion of the Affected\nSegment that was removed from service immediately after the February 3, 2024, leak by closing\nMLV 64-1 (upstream of the failure) and MLV-65-1 (downstream of the failure) which must\nremain out of service until a Restart Plan (as described in Item 12 below) is submitted and\napproved by the Director.\nDirector – The “Director” means the Director, PHMSA, Office of Pipeline Safety, Southern\nRegion.\nPursuant to 49 U.S.C. 60112, I hereby order Tennessee Gas to take the following corrective\nactions:\n1. Shutdown of the Isolated Segment. The Isolated Segment must be shut-in and may not\nbe operated until authorized to be restarted by the Director in accordance with the terms of\nthis Amended Order.\n\n\n\n2. 3. Operating Pressure Restriction. Respondent must reduce and maintain a twenty\npercent (20%) pressure reduction in the actual operating pressure along the entire\nlength of the Affected Segment such that operating pressure along the Affected Pipeline\nwill not exceed eighty percent (80%) of the actual operating pressure in effect at the\nFailure location, immediately prior to the Failure on February 3, 2024.\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\nobtained from the Director.\nb. Within 15 days of receipt of the Amended CAO, Tennessee Gas must provide the\nDirector the actual operating pressures of each compressor station on the Affected\nSegment at the time of Failure and the reduced pressure restriction set-points at\nthese same locations.\nc. d. This 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, Respondent must take into\naccount any ILI features or anomalies present in the Affected Segment to provide for\ncontinued safe operation while further corrective actions are completed.\ne. Tennessee Gas must review the pressure restriction monthly by analyzing the\noperating pressure data, taking into account any ILI features or anomalies present in\nthe Affected Segment. Respondent must immediately reduce the operating pressure\nfurther to maintain the safe operations of the Affected Segment, if warranted by the\nmonthly review. Further, Tennessee Gas must submit the results of the monthly\nreview to the Director including, at a minimum, the current discharge set-points\n(including any additional pressure reductions), and any pressure exceedance at\ndischarge set-points. Submittals may be made quarterly, in accordance with Item 17\nbelow.\nReview of Prior In-line Inspection (ILI) Results.\na. Within 30 days of receipt of the Amended CAO, Respondent must conduct a\nreview of any previous ILI results of the Affected Segment. In its review, Tennessee\nGas must re-evaluate all ILI results from the past 10 calendar years, including a\nreview of the ILI vendor’s raw data and analysis. Tennessee Gas must determine\nwhether any features were present in the failed wrinkle bend from the February 3,\n2024, Failure. Also, Respondent must determine if any features with similar\ncharacteristics are present elsewhere on the Affected Segment. Tennessee Gas must\nsubmit documentation of this ILI review to the Director within 45 days of receipt\nof the Amended CAO, 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 wrinkle bend and other pipe removed.\niii. List, describe (type, size, wall loss, etc.), and identify the specific location of all\n\n\n\nILI features with similar characteristics present elsewhere on the Affected\nSegment.\niv. Explain the process used to review the ILI results and the results of the\nreevaluation.\n4. Mechanical and Metallurgical Testing. Within 45 days of receipt of the Amended\nCAO, Tennessee Gas must complete mechanical and metallurgical testing and failure\nanalysis of the failed pipe, including an analysis of soil samples and any foreign\nmaterials. Mechanical and metallurgical testing must be conducted by an independent\nthird-party acceptable to the Director, and must document the decision-making process\nand all factors contributing to the Failure. Respondent must complete the testing and\nanalysis 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 Amended CAO, develop and submit the testing\nprotocol and 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 Respondent.\n5. Root Cause Failure Analysis. Within 90 days following receipt of the Amended\nCAO, complete a root cause failure analysis (RCFA) and submit a final report of\nthis RCFA to the Director. The RCFA must be supplemented or facilitated by an\nindependent third-party acceptable to the Director and must document the decision-\nmaking process and all factors contributing to the Failure. The final report must\ninclude findings and any lessons learned and whether the findings and lessons\nlearned are applicable to other locations within Tennessee Gas’ pipeline system.\n6. Analysis of Prior Integrity Testing Plan. Within 90 days following receipt of the\nAmended CAO, complete an analysis of why the integrity testing plan required by the\nNovember 28, 2011, Corrective Action Order, which emphasized identifying and\nevaluating anomalies associated with wrinkle bends, did not address the wrinkle bend\nfailure that resulted in the February 3, 2024, release.\n7. Records Verification. As recommended in PHMSA Advisory Bulletin 2012-06,\nRespondent must verify the records for the Affected Segment to confirm the maximum\nallowable operating pressure (MAOP). Tennessee Gas must submit documentation of\nthis record verification to the director within 45 days of receipt of this Amended\nOrder.\n8. Instrumented Leakage Survey. Within 90 days of receipt of this Amended Order,\nTennessee Gas must perform an instrumented leak survey over the Affected Segment\n\n\n\nand report those findings to the Director.\n9. Leak Detection Plan. Within 90 days of receipt of this Amended Order, Tennessee\nGas must perform a review and submit to the Director a written plan to improve the\nleak detection capability on the Affected Segment. This review must include a\ncomprehensive analysis of any SCADA, leak detection, surveillance, and other\nmonitoring systems on the Affected Segment. The written plan must include a\nschedule for improving the leak detection capability of the Affected Segment through\nadditional instrumentation, updated hardware or software, installation of a\ncomputational pipeline monitoring system and associated software programming,\nadditional surveillance, pipeline control staffing, ongoing leak surveys, and any other\nappropriate measures.\n10. Remedial Work Plan.\na. b. c. Within 90 days following receipt of the Amended CAO, Tennessee Gas must\nsubmit a remedial work plan (RWP) to the Director for approval.\nThe 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 Amended Order.\nd. e. The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures Respondent will use to verify the integrity of the Affected\nSegment. It must address all known or suspected factors and causes of the\nFebruary 3, 2024, Failure. Respondent must consider the risks and consequences\nof another failure to develop a prioritized schedule for RWP-related work along\nthe Affected Segment.\nThe RWP must include a procedure or process to:\ni. Identify pipe in the Affected Segment with characteristics similar to the\ncontributing factors identified for the February 3, 2024, Failure, including the\nage and manufacture of the entire length of the Affected Segment.\nii. Gather all data necessary to review the failure history (in service and pressure\ntest failures) of the Affected Segment 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 Amended Order with all relevant pre-\nexisting operational and assessment data for the Affected Segment. 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 direct current voltage gradient and alternating current\nvoltage gradient surveys.\nDetermine if conditions similar to those contributing to the Failure on\n\n\n\nvi. vii. viii. f. g. February 3, 2024, are likely to exist elsewhere on the Affected Segment.\nv. Conduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nFailure on February 3, 2024, and other failures from the failure history (see\n(e)(ii) above) or any other integrity threats are present elsewhere on the Affected\nSegment. 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 3, 2024,\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: Respondent may use the results of previous tests, inspections,\nassessments, and evaluations if approved by the Director, provided the\nresults of the tests, inspections, assessments, and evaluations are analyzed\nwith regard to the factors known or suspected to have caused the February 3,\n2024, Failure.\nDescribe the inspection and repair criteria Tennessee Gas will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded and a\nschedule for repairs or replacement.\nBased on the known history and condition of the Affected Segment, describe the\nmethods Respondent will use to repair, replace, or take other corrective\nmeasures to remediate the conditions associated with the pipeline failure on\nFebruary 3, 2024, and to address other known integrity threats along the\nAffected Segment. The repair, replacement, or other corrective measures must\nmeet the criteria specified in (e)(vi) above.\nImplement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Segment\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Amended Order.\nInclude a proposed schedule for completion of the RWP.\nTennessee Gas must revise the RWP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate the\n\n\n\ni. ii. iii. h. results of actions undertaken pursuant to this Amended Order, and to incorporate\nmodifications required by 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.\nImplement the RWP as it is approved by the Director, including any revisions to\nthe plan.\n11. CAO Documentation Report. Tennessee Gas must create and revise, as necessary, a\nCAO Documentation Report (CDR). When Respondent has concluded all the items in\nthis Order it will submit the final CDR in its entirety to the Director. This will allow\nthe Director to complete a thorough review of all actions taken by Tennessee Gas with\nregards to this Amended Order prior to approving the closure of this Amended Order.\nThe intent is for the CDR to summarize all activities and documentation associated\nwith this Amended Order in one document.\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;\nii. Summary of the pipeline failure of February 3, 2024, and the response activities;\niii. Summary 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 Amended Order;\nv. Summary of the mechanical and metallurgical testing as required by the Amended\nOrder;\nvi. Summary of the RCFA with all root causes as required by the Amended Order;\nvii. Documentation of all actions taken by Respondent to implement the RWP, the\nresults of those 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 Amended\nOrder and whenever necessary to incorporate new information obtained\nduring the failure investigation and remedial activities;\nix. Lessons learned while completing this Amended Order;\nx. A path forward describing specific actions Tennessee Gas will take on its\nentire pipeline system as a result of the lessons learned from work on this\n\n\n\nAmended Order; and\nxi. Appendices (if required).\n12. 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 Amended 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. 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.\nTennessee Gas must address any findings that require remedial measures to be\nimplemented prior to 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 Respondent’s O&M procedures manual.\n13. Return to Service. After the Director approves the Restart Plan, Tennessee Gas\nmay resume operation of the Isolated Segment according to the terms of the\nRestart Plan, but the operating pressure must not exceed the limit in accordance\nwith Item 2 above.\n14. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction\nupon a written request from Tennessee Gas demonstrating that restoring the\npipeline to its pre-failure operating pressure is justified based on a reliable\nengineering analysis showing that the pressure increase is safe considering all\nknown defects, anomalies, and operating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\n\n\n\nrestrictions upon a written request from Respondent 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 to provide for the safe operation of the Affected Segment 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:\n15. Approvals. With respect to each submission under this Amended Order that requires\nthe approval 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.\n16. Extensions of Time. The Director may grant an extension of time for compliance\nwith any of the terms of this Amended Order upon a written request timely\nsubmitted demonstrating good cause for an extension.\n17. Reporting. Submit quarterly reports to the Director that: (1) include all available data\nand results of the testing and evaluations required by this Amended Order; and (2)\ndescribe the progress of the repairs or other remedial actions being undertaken. The\nfirst quarterly report is due on July 15, 2024. The Director may change the interval\nfor the submission of these reports.\n18. Documentation of the Costs. It is requested that Respondent maintain\ndocumentation of the costs associated with implementation of this Amended CAO.\nInclude in each monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies, and analyses; (2) physical changes to\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).\n\n\n\nIn your correspondence on this matter, please refer to “CPF No. 2-2024-009-CAO” and for\neach document you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Amended Order are in addition to and do not waive any requirements\nthat apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any\nother order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other\nprovision of federal 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 Amended Order may result in the assessment of civil penalties and\nin referral to the Attorney General for appropriate relief in United States District Court pursuant\nto 49 U.S.C. § 60120.\nThe terms and conditions of this Amended Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nFebruary 9, 204\n_____________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n22024009CAO_Corrective Action Order_02072024_(24-298988)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom martin@kindermorgan.com\nThomas Martin\nPresident/CEO – Gas Pipelines\nTennessee Gas Pipeline Company, LLC\n1001 Louisiana Street\nSuite 1000\nHouston, Texas 77002\nRe: CPF No. 2-2024-009-CAO\nDear Mr. Martin,\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 Tennessee Gas Pipeline Company, LLC, to take certain\ncorrective actions with respect to a pipeline failure that occurred on February 3, 2024, on your\nLine 100 natural gas pipeline system in Panola County, Mississippi.\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,\nfor Alan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA\nMr. Zach Ragain, Director – Engineering, Compliance/Codes & Standards,\nTennessee Gas Pipeline Company, LLC, zach_ragain@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____________________________________\n)\nIn the Matter of )\n)\nTennessee Gas Pipeline Company, LLC ) CPF No. 2-2024-009-CAO\n)\nRespondent. )\n)\n____________________________________)\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 Tennessee Gas Pipeline Company, LLC (Tennessee Gas or\nRespondent), to take necessary corrective actions to protect the public, property, and the\nenvironment from potential hazards associated with the February 3, 2024, natural gas pipeline\nfailure that occurred on Line 100 natural ga","truncated":true,"body_characters":72093}