{"operation":"document","citation":"CPF 22025005CAO","title":"COLORADO INTERSTATE GAS CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-09-24","effective_on":null,"summary":"OPEN corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025005cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025005cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025005cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22025005CAO","body":"Corrective Action Order involving COLORADO INTERSTATE GAS CO. The dataset does not identify a cited regulation for this case. The case was opened on 2025-09-24 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22025005CAO_Corrective Action Order_09242025_(25-353258).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22025005CAO/22025005CAO_Corrective%20Action%20Order_09242025_(25-353258).pdf\n\n22025005CAO_Corrective Action Order_09242025_(25-353258)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22025005CAO/22025005CAO_Corrective%20Action%20Order_09242025_(25-353258)_text.pdf\n\n22025005CAO_Corrective Action Order_09242025_(25-353258)_text.pdf\n\n1\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSeptember 24, 2025\nVIA ELECTRONIC MAIL TO: steven_romano@kindermorgan.com\nSteven Romano\nChief Operating Officer\nColorado Interstate Gas Company, L.L.C.\n1001 Louisiana St.\nSuite 1000\nHouston, TX 77002\nCPF No. 2-2025-005-CAO\nDear Mr. Romano:\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). It\nrequires Colorado Interstate Gas Company, L.L.C., a subsidiary of Kinder Morgan, Inc., to take\ncertain corrective actions with respect to a pipeline failure that occurred on September 21, 2025,\non the 22-inch interstate natural gas transmission line near Cheyenne, Wyoming.\nService of the CAO by electronic mail is effective upon the date of transmission and\nacknowledgement of receipt as provided under 49 CFR § 190.5. The terms and conditions of this\nOrder are effective upon completion of service.\nSincerely,\nLinda G. Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Mr. Zachary Ragain – Director – Codes and Standards,\nZach_Ragain@kindermorgan.com\nMr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA,\njames.urisko@dot.gov\n\n\n\n2\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\n3\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColorado Interstate Gas Co., L.L.C., )\na subsidiary of Kinder Morgan, Inc. ) CPF No. 2-2025-005-CAO\n)\n)\n)\nRespondent. )\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 Colorado Interstate Gas Company, L.L.C. (CIG or Respondent),\na subsidiary of Kinder Morgan, Inc.,1 to take certain necessary corrective actions to protect the\npublic, property, and the environment from potential hazards associated with the September 21,\n2025 natural gas pipeline failure that occurred on the 22-inch Colorado Interstate Line 05A\npipeline at mile post 103+2918 (approximately 1,930 feet west of main line valve 10) near\nCheyenne, Wyoming (hereinafter the Incident).\nColorado Interstate is a 4,350-mile pipeline system that transports natural gas from production\nareas in the Rocky Mountains directly to customers in Colorado and the Pacific Northwest. On\nSeptember 21, 2025, at approximately 01:40 AM Eastern Daylight Time (EDT) Colorado\nInterstate’s Line 05A pipeline failed.\n2 The failure resulted in a rupture and fire.\nRailroad tracks are in proximity to the pipeline right-of-way and failure location. Prior to the\nfailure, the crew of a Union Pacific Railroad MNPWC-20 freight train visually observed a dust\nand vapor cloud. Following this observation, they brought the train to a safe stop. After the train\nstopped, the Incident occurred. The rupture caused a 50-foot crater to form next to the railroad\nsiding. The main track and siding are significantly comprised. Two train storage cars carrying\nethanol initially derailed where the track was compromised. The storage cars melted in the\n1 Colorado Interstate Gas Company, L.L.C., KINDER MORGAN,\nhttps://pipeportal.kindermorgan.com/portalui/DefaultKM.aspx?TSP=CIGD (last visited September 23, 2025).\n2 September 21, 2025, at 01:40 AM was the approximate time of the failure in Eastern Daylight Time. It occurred\nSeptember 20, 2025, at 11:40 PM local time (Mountain Daylight Time).\n\n\n\n4\nrailway siding and collapsed in on themselves. A third railcar with unknown contents eventually\nderailed as well. Union Pacific Railroad reported NRC #1443295 for fire on a freight train.\nIn response, CIG shutdown a segment of Line 05A between main line valve 8.7 and main line\nvalve 11. It remains shutdown. CIG reported the Incident to the NRC on September 21, 2025, at\n04:29 AM Eastern Daylight Time.3 An estimated 500,000 MCF of natural gas was released. The\ndamage amount is currently unknown. No injuries or fatalities have been reported.\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• Colorado Interstate is a 4,350-mile pipeline system that transports natural gas from\nproduction areas in the Rocky Mountains directly to customers in Colorado and the\nPacific Northwest.\n• At approximately 01:40 AM Eastern Daylight Time on September 21, 2025, a Colorado\nInterstate’s 22-inch Line 05A natural gas pipeline failed at mile post 103+2918\n(approximately 1,930 feet west of main line valve 10), near Cheyenne Wyoming. The\ntown closest to the location of the Incident is Granite, Wyoming.\n• Line 05A was installed January 4, 1956. The pipeline wall thickness is 0.375 inches with\ncoal tar coating. The pipeline steel grade is reported as API 5L - X46,000. AO Smith\nmanufactured the pipeline with an electric resistance weld. The system is cathodically\nprotected.\n• The pipeline maximum allowable operating pressure (MAOP) is 850 psig.\n• Line 05A shares a common right-of-way with five parallel natural gas transmission\npipelines and one highly volatile liquid transmission pipeline: All five pipelines run\nparallel to the adjacent railroad tracks. Three other operators share the right-of-way with\nColorado Interstate.\n• Railroad tracks are in proximity to the pipeline right-of-way and failure location. Prior to\nthe failure, the crew of a Union Pacific Railroad MNPWC-20 freight train visually\nobserved a dust and vapor cloud. Following this observation, they brought the train to a\nsafe stop. After the train stopped, the Incident occurred.\n• The rupture caused a 50-foot crater to form next to the railroad siding. The main track\nand siding are significantly comprised. Two train storage cars carrying ethanol initially\nderailed where the track was compromised. The storage cars melted in the railway siding\nand collapsed in on themselves. A third railcar with unknown contents eventually\n3 NRC Report # 1443296 (original) and 1443457 (48-hour update).\n\n\n\n5\nderailed as well. Union Pacific Railroad reported NRC #1443295 for fire on a freight\ntrain.\n• An estimated 500,000 MCF of natural gas was released. The damage amount is currently\nunknown. No injuries or fatalities have been reported.\n• CIG shutdown the segment of Line 05A between main line valve 8.7 at Cheyenne\nCompressor Station and main line valve 11 located east of Buford Road and south of I-\n80. It remains shutdown.\n• The cause of the Incident is currently unknown. PHMSA is continuing its investigation.\nThe National Transportation Safety Board has also initiated an investigation.\n• Pre-1970 low-frequency electric resistance weld (ERW) pipe has been the focus of many\nstudies and reviews. A final report TTO Number 5, Integrity Management Program\nDelivery Order DTRS56-02-D-70036, Integrity Management Program regarding Low\nFrequency ERW and Lap Welded Longitudinal Seam Evaluation (Revision 3) was\nprepared by Michael Baker in association with Kiefner and Associates, Inc., CorrMet\nEngineering Services, PC, in April 2004. The report was written to support the\nimportance of operators correctly selecting integrity assessment methods capable of\nassessing seam integrity and of detecting corrosion and deformation 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• 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• PHMSA’s safety regulations require an operator to identify potential threats to pipeline\nintegrity and use the identified threats in its pipeline safety integrity program.4 ERW pipe\n4 49 CFR § 192.917.\n\n\n\n6\nand defects from manufacturing and construction are specific threats identified by\nPHMSA’s regulations and PHMSA’s regulations require an operator to take specific\nactions to address them.5\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 hazardous nature of the material (natural gas)\ntransported and the known threat to pipeline integrity from ERW pipe and manufacturing and\nconstruction defects; the uncertainty as to the root cause of the Incident; the impacts and\npotentially unknown impacts to nearby property, multiple pipelines and modes of transportation,\nand the environment; the risk of additional, related incidents; and the possibility that the same\ncondition(s) that may have caused the failure remain present in the pipeline; I find that continued\noperation of the Affected Pipeline, as defined below, 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 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 Acting Associate Administrator for Pipeline Safety in writing, with\na copy to the Director, Southern Region, PHMSA. If a hearing is requested, it will be held in\naccordance with 49 CFR § 190.211.\n5 49 CFR § 192.917(e)(3) & (e)(4).\n\n\n\n7\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 the approximately 68-mile segment of CIG’s\nLine 05A pipeline between CIG’s Cheyenne and Laramie Compressor Stations.\nIsolated Segment – The \"Isolated Segment\" means the segment of CIG’s Line 05A pipeline\nbetween main line valve 8.7 at Cheyenne Compressor Station and main line valve 11 located east\nof Buford Road and south of I-80.\nDirector – The \"Director\" means the Director, PHMSA, OPS Southern Region.\nPursuant to 49 U.S.C. 60112, I hereby order CIG to take the following corrective actions:\n1. Shutdown of the Isolated Segment. CIG must not operate the Isolated Segment until\nauthorized to do so in writing by the Director.\n2. Operating Pressure Restriction. CIG must reduce and maintain a twenty percent\n(20%) pressure reduction in the actual operating pressure along the entire length of the\nAffected 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 September 21, 2025.\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. Within 15 days of receipt of the CAO, CIG 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. This includes the Cheyenne\nand Laramie Compressor Stations bounding the Affected Pipeline.\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\nbe adjusted accordingly.\nd. When determining the pressure restriction set-points, CIG 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.\n\n\n\n8\ne. CIG 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. CIG must immediately reduce the operating pressure further to maintain the\nsafe operations of the Affected Pipeline, if warranted by the monthly review. Further,\nCIG 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 14 below.\n3. Instrumented Leakage Survey. Within 30 days of receipt of the CAO, CIG must\nperform an aerial or ground instrumented leakage survey of the Affected Pipeline. CIG\nmust investigate all leak indications and remedy all leaks discovered. CIG must submit\ndocumentation of this survey to the Director within 45 days of receipt of the CAO.\n4. Review of Prior Inline Inspection (ILI) Results.\na. Within 30 days of receipt of the CAO, CIG must conduct a review of any previous\nILI results of the Affected Pipeline. In its review, CIG must re-evaluate all ILI\nresults from the past 10 calendar years, including a review of the ILI vendors' raw\ndata and analysis. CIG must determine whether any features were present in the\nfailed pipe joints from the September 21, 2025 failure. Also, CIG must determine if\nany features with similar characteristics are present elsewhere on the Affected\nPipeline. CIG must submit documentation of this ILI review to the Director within\n45 days of receipt of the 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 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.\n5. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing,\nincluding failure analysis, will be performed by the NTSB in accordance with NTSB\nprocedures and protocols. In the event the NTSB does not perform these functions,\nwithin 45 days of receipt of the CAO, CIG must complete mechanical and\nmetallurgical testing and failure analysis of the failed pipe, including an analysis of soil\nsamples and any foreign materials. Mechanical and metallurgical testing must be\nconducted by an independent third-party acceptable to the Director, and must\ndocument the decision-making process and all factors contributing to the failure. CIG\nmust 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.\n\n\n\n9\nb. 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.\nc. Prior 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 CIG.\n6. 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 approved in writing by 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 learned\nare applicable to other locations within CIG’s pipeline system. Should the NTSB\nperform the RCFA as part of its investigation, CIG must incorporate the results of that\nanalysis into its integrity management plan and operations and maintenance manual.\n7. Remedial Work Plan (RWP).\na. Within 90 days following receipt of the CAO, CIG must submit a remedial work\nplan (RWP) to the Director for approval.\nb. The Director may approve the RWP incrementally without approving the entire RWP.\nc. Once approved by the Director, the RWP will be incorporated by reference\ninto this Order.\nd. The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures CIG will use to verify the integrity of the Affected Pipeline. It\nmust address all known or suspected factors and causes of the September 21, 2025\nfailure. CIG must consider the risks and consequences of another failure to\ndevelop a prioritized schedule for RWP- related work along the Affected Pipeline.\ne. The 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 September 21, 2025 failure, including\nthe age 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. 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\n\n\n\n10\nconsultation information. Pre-existing assessment data includes, but is not\nlimited to, ILI tool runs, hydrostatic pressure testing, direct assessments, close\ninterval surveys, and DCVG/ACVG surveys.\niv. Determine if conditions similar to those contributing to the failure on\nSeptember 21, 2025, are likely to exist elsewhere on the Affected Pipeline.\nv. Conduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nfailure on September 21, 2025, and other failures from the failure history (see\n(e)(ii) above) or any other integrity threats are present elsewhere on the\nAffected Pipeline. At a minimum, this process must consider all failure causes\nand 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 failure on September 21, 2025, 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 power\nlines, etc.) in the area,\n5) Coating surveys,\n6) Stress corrosion cracking surveys,\n7) Selective seam corrosion surveys; and\n8) Other tests, inspections, assessments, and evaluations appropriate for the\nfailure causes.\nNote: CIG may use the results of previous tests, inspections, assessments,\nand evaluations if approved by the Director, provided the results of the tests,\ninspections, assessments, and evaluations are analyzed with regard to the\nfactors known or suspected to have caused the September 21, 2025 failure.\nvi. Describe the inspection and repair criteria CIG will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity\nthreats. Include a description of how any defects will be graded and a schedule\nfor repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipeline, describe the\nmethods CIG will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the pipeline failure on September 21,\n2025, 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.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipeline\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Order.\n\n\n\n11\nf. Include a proposed schedule for completion of the RWP.\ng. CIG 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.\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\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.\n8. CAO Documentation Report (CDR). CIG must create and revise, as necessary, a\nCAO Documentation Report (CDR). When CIG 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 CIG 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;\nii. Summary of the pipeline failure of September 21, 2025, 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 Order;\nv. Summary of the mechanical and metallurgical testing as required by the Order;\nvi. Summary of the RCFA with all root causes as required by the Order;\nvii. Documentation of all actions taken by CIG to implement the RWP, the results of\nthose actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the failure\ninvestigation and remedial activities;\nix. Lessons learned while completing this Order;\n\n\n\n12\nx. A path forward describing specific actions CIG will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\n9. Restart Plan. Prior to resuming operation of the Isolated Segment, develop and\nsubmit a written Restart Plan to the Director for prior approval.\na. 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.\nb. Once approved by the Director, the Restart Plan will be incorporated by\nreference into this Order.\nc. 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.\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\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. CIG\nmust address any findings that require remedial measures to be implemented prior\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 CIG’s O&M procedures manual.\n10. Return to Service. After the Director approves the Restart Plan, CIG 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.\n11. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction\nupon a written request from CIG 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.\n\n\n\n13\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from CIG 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 Acting\nAssociate Administrator for Pipeline Safety.\nOther Requirements:\n12. 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.\n13. 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.\n14. Reporting. Submit quarterly reports to the Director that: (1) include all available data\nand results of the testing and evaluations required by this Order; and (2) describe the\nprogress of the repairs or other remedial actions being undertaken. The first quarterly\nreport is due on January 15, 2026. The Director may change the interval for the\nsubmission of these reports.\n15. 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\n\n\n\n14\ninformation qualifies for confidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 2-2025-005-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 CFR 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 Acting Associate Administrator for\nPipeline Safety. Decisions of the Acting 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 CFR\n§ 190.5.\n_____________________________ __________________________\nLinda G. Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":33838}