# NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320051011
- **title:** NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2005-03-14
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.465(d), 192.479(b), 192.613(b), 192.745, 192.751.
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320051011
**body:**

Notice of Probable Violation involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). PHMSA's enforcement data identifies the cited regulations as 192,  192.465(d),  192.479(b),  192.613(b),  192.745,  192.751. The case was opened on 2005-03-14 and is reported as closed as of 2008-01-28. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320051011_FinalOrderClosure_01282008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320051011/320051011_FinalOrderClosure_01282008.pdf

320051011_finalorderclosure_01282008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320051011/320051011_finalorderclosure_01282008_text.pdf

320051011_finalorderclosure_01282008_text.pdf

U S Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Ave S E
Washington DC 20590
dA0 2 8 ZITI
Mr. M. Dwayne Burton
Vice President of Gas Operations
Natural Gas Pipeline Company of America
One Allen Center
500 Dallas Street, Suite 1000
Houston, TX 77002
Re: CPF No. 3-2005-1011
Dear Mr. Burton;
Enclosed is the Final Order in the above-referenced case. It makes findings of violation and
finds that you have completed the actions specified in the Notice required to comply with the
pipeline safety regulations. This case is now closed. Your receipt of the Final Order constitutes
service of that document under 49 C, F. R. $ 190. 5,
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
CC: Ivan Huntoon, Director, Central Region, PHMSA
CERTIFIED MAIL — RETURN RECEIPT RE UESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D. C. 20590
In the Matter of )
)
)
Natural Gas Pipeline Company )
of America, )
(formerly Kinder Morgan, Inc, ) )
)
Respondent )
CPF No. 3-2005-1011
FINAL ORDER
On June 16-28 and July 7-11, 2003, pursuant to 49 U. S. C. ) 60117, representatives of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
conducted an on-site pipeline safety inspection of Respondent's' facilities and records in
Minneola, Great Bend, and Glasco, Kansas; Beatrice, Nebraska; and Geneseo, Illinois. As a
result of the inspection, the Director, Central Region, PHMSA, issued to Respondent, by letter
dated March 14, 2005, a Notice of Probable Violation and Proposed Compliance Order (Notice).
In accordance with 49 C. F. R. $ 190. 207, the Notice proposed finding that Respondent had
committed violations of 49 C. F. R. Part 192 and proposed ordering Respondent to take certain
measures to correct the alleged violations. In addition, the Notice contained a warning that
Respondent had committed certain other violations of 49 C. F. R. $ 192. 465(d), 192. 745, and
192. 751 and advised Respondent to take appropriate corrective action.
Respondent responded to the Notice by letter dated November 8, 2005, as supplemented by letter
dated February 2, 2006 (Response). Respondent did not contest the allegations of violation and
provided information concerning the corrective actions it had taken. Respondent did not request
a hearing, and therefore has waived its right to one.
FINDINGS OF VIOLATION
In its Response, Respondent did not contest the allegations in the Notice that it violated 49
C. F. R. Part 192, as follows:
In December 2007, Knight Inc, formerly known as Kmder Morgan Inc, mformed PHMSA that it had retained a
20% equity ownersh&p in the NGPL system and w&11 contmue as the operator of the system



Notice Item 2:
49 C. F. R. g 192. 479 Atmospheric corrosion control: GeneraL
(a) Each operator must clean and coat each pipeline or portion of pipeline that is
exposed to the atmosphere, except pipelines under paragraph (c) of this section.
(b) Coating material must be suitable for the prevention of atmospheric corrosion.
Specifically, Item 2 in the Notice alleged that Respondent failed to clean and coat portions of its
pipeline exposed to the atmosphere at the Glasco Station. PHMSA's representative observed
atmospheric corrosion at the basement entrance point on the 3" fuel gas lines to station engines
No. 12 and 13. Respondent did not contest the allegation. Accordingly, I find that Respondent
violated 49 C. F, R. ) 192. 479 by failing to clean and coat portions of its pipeline exposed to the
atmosphere at the Glasco Station.
Notice Item 3:
49 C. F. R. g 192. 613 Continuing surveillance.
(b) If a segment of pipeline is determined to be in unsatisfactory condition but no
immediate hazard exists, the operator shall initiate a program to recondition or phase out
the segment involved, or, if the segment cannot be reconditioned or phased out, reduce
the maximum allowable operating pressure in accordance with )192. 619(a) and (b),
Specifically, Item 3 in the Notice alleged that Respondent failed to recondition or phase out a
segment of pipeline No. 3 where an unsatisfactory condition existed. At the Nemaha River
crossing (Mile Post 533), PHMSA's representative observed that the line was exposed and that
large gaps existed between the pipe and the river weights. Respondent did not contest the
allegation. Accordingly, I find that Respondent violated 49 C. F. R. ) 192. 613 by failing to
recondition or phase out a segment of pipeline No. 3 where an unsatisfactory condition existed.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
With respect to Items 2 and 3, the Notice proposed a compliance order. Under 49 U. S. C $
60118(a), each person who engages in the transportation of gas or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601. The Director, Central Region, PHMSA has indicated that with respect to Item 2,
Respondent has corrected the atmospheric corrosion; with respect to Item 3, Respondent has
completed a series of scheduled projects to correct conditions at river crossings.



Accordingly, since compliance has been achieved with respect to these violations, it is
unnecessary to include compliance terms in this Order.
WARNING ITEMS
With respect to Items 1, 4 and 5, the Notice alleged probable violations of Part 192 but did not
propose a civil penalty or compliance order for these items. Therefore, these are considered to
be warning items. The warnings were for:
49 C. F. R. ) 192. 465(d) (Notice Item 1) — failure to take prompt remedial action to
correct cathodic protection deficiencies indicated by monitoring. Respondent allegedly
failed to take prompt remedial action to correct low cathodic protection readings
identified at Mile Post 146/147 in 2001;
49 C. F. R. $ 192. 745 (Notice Item 4) — failure to inspect and partially operate each
transmission line valve that might be required during any emergency at mtervals not
exceeding 15 months, but at least once each calendar year. Respondent allegedly failed
to inspect and partially operate valves 152 and 163 in 2001; and
49 C. F. R. $ 192. 751 (Notice Item 5) — failure to take steps to minimize the danger of
accidental ignition of gas in any structure or area where the presence of gas constitutes a
hazard of fire or explosion. Respondent allegedly failed to vent a regulator with an
internal relief valve to the outside at the Agenda Town Border Station.
Respondent presented information in its Response showing that it had taken certain actions to
address these items. Having considered such information, pursuant to 49 C. F. R. $ 190. 205, I
find that probable violations of 49 C. F. R. Part 192 have occiured as described in Notice Items 1,
4 and 5 and Respondent is hereby advised to correct such conditions. In the event that PHMSA
finds a violation for any of these items in a subsequent inspection, Respondent may be subject to
future enforcement action.
The terms and conditions of this Final Order are effective on receipt.
JAN 2 8 2008
Je ey . Wiese
Associate Administrator
for Pipeline Safety
Date Issued
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