{"operation":"document","citation":"CPF 320101001","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":"2010-02-25","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.201(a), 192.455(a), 192.459, 192.481(a), 192.603(b), 192.605(c)(4), 192.615(b)(3), 192.735(a), 192.743(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320101001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320101001","body":"Notice of Probable Violation involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). PHMSA's enforcement data identifies the cited regulations as 192.201(a),  192.455(a),  192.459,  192.481(a),  192.603(b),  192.605(c)(4),  192.615(b)(3),  192.735(a),  192.743(a). The case was opened on 2010-02-25 and is reported as closed as of 2011-06-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320101001_FinalOrder_06242011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101001/320101001_FinalOrder_06242011.pdf\n\n320101001_FinalOrder_06242011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101001/320101001_FinalOrder_06242011_text.pdf\n\n320101001_NOPV PCO_02252010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101001/320101001_NOPV%20PCO_02252010.pdf\n\n320101001_NOPV PCO_02252010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101001/320101001_NOPV%20PCO_02252010_text.pdf\n\n320101001_Opr Response_03242010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320101001/320101001_Opr%20Response_03242010.pdf\n\n320101001_FinalOrder_06242011_text.pdf\n\nJUN 24 2011\nMr. Dwayne Burton\nVice President – Gas Pipeline Operations\nNatural Gas Pipeline Company of America LLC\n500 Dallas Street, Suite 1000\nHouston, TX 77002\nRe: CPF No. 3-2010-1001\nDear Mr. Burton:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and finds that Natural Gas Pipeline Company of America LLC has completed the\nactions specified in the Notice to comply with the pipeline safety regulations. Therefore, this\ncase is now closed. Service of the Final Order by certified mail is deemed effective upon the\ndate of mailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Alan Mayberry, Deputy Associate Administrator for Field Operations, Pipeline Safety\nDavid Barrett, Director, PHMSA Central Region\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 1160 0001 0075 9589]\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)\nNatural Gas Pipeline Company ) CPF No. 3-2010-1001\nof America LLC )\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn various dates between August 10 and October 29, 2009, pursuant to 49 U.S.C. § 60117, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office\nof Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and\nrecords of Natural Gas Pipeline Company of America LLC (NGPA or Respondent) in Minneola,\nKansas, Great Bend, Kansas, Glasco, Kansas, Beatrice, Nebraska, and Geneseo, Illinois.\nRespondent operates a large natural gas pipeline system extending approximately 9,122 miles\nacross several states.\nAs a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,\nby letter dated February 25, 2010, a Notice of Probable Violation and Proposed Compliance\nOrder (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that\nNGPA had committed various violations of 49 C.F.R. Part 192 and proposed ordering\nRespondent to take certain measures to correct two of the alleged violations.\nFINDING OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.455(a), which states in\nrelevant part:\n§ 192.455 – External corrosion control: Buried or submerged pipelines installed\nafter July 31, 1971.\n(a) Except as provided in paragraphs (b), (c), and (f) of this section,\neach buried or submerged pipeline installed after July 31, 1971, must be\n\n\n\n2\nprotected against external corrosion, including the following:\n(2) It must have a cathodic protection system designed to protect the pipeline in\naccordance with this subpart, installed and placed in operation within 1 year after\ncompletion of construction.\nSpecifically, the Notice alleged that Respondent failed to have cathodic protection on a section\nof pipe at the Atkinson Meter Station in the Geneseo area. In its Response, NGPA\nacknowledged that the specified section of pipe had been insulated from cathodic protection and\nexplained that it connected it to cathodic protection immediately after the OPS inspection.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.\n§ 192.455(a) by failing to have cathodic protection on a section of pipe at the Atkinson Meter\nStation in the Geneseo area.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nWITHDRAWAL OF ALLEGATION\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.201(a), which states in\nrelevant part:\n§ 192.201 -- Required capacity of pressure relieving and limiting stations.\n(a) Each pressure relief station or pressure limiting station or group of\nthose stations installed to protect a pipeline must have enough capacity,\nand must be set to operate, to insure the following:\n(2) In pipelines other than a low pressure distribution system:\n(i) If the maximum allowable operating pressure is 60 p.s.i. (414 kPa)\ngage or more, the pressure may not exceed the maximum allowable\noperating pressure plus 10 percent, or the pressure that produces a\nhoop stress of 75 percent of SMYS, whichever is lower;\n(ii) If the maximum allowable operating pressure is 12 p.s.i. (83 kPa)\ngage or more, but less than 60 p.s.i. (414 kPa) gage, the pressure may\nnot exceed the maximum allowable operating pressure plus 6 p.s.i. (41\nkPa) gage; or\n(iii) If the maximum allowable operating pressure is less than 12 p.s.i.\n(83 kPa) gage, the pressure may not exceed the maximum allowable\noperating pressure plus 50 percent.\n\n\n\n3\nSpecifically, the Notice alleged that Respondent failed to set pressure relief devices to ensure\npressure would not exceed maximum allowable operating pressure (MAOP) plus allowable\nbuild-up at several stations in the Minneola and Great Bend areas. In its Response, NGPA\nestablished that the MAOP was the same upstream and downstream of the regulation facilities to\nthe point of custody transfer to customer facilities and that to the extent the downstream MAOP\nwas lower it was relevant to customer facilities only. Therefore, the cited facilities are not\nsubject to the regulations.\nBased upon the foregoing, I hereby order that Item 1 of the Notice be withdrawn.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 2 in the Notice for violations of 49\nC.F.R. § 192.455(a). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of gas or who owns or operates a pipeline facility is required to comply with the\napplicable safety standards established under chapter 601. The Director indicates that with\nrespect to Item 2, Respondent has reviewed the relevant documentation with OPS and confirmed\nthat no other sections of pipe in the specified stations are isolated from cathodic protection as\nspecified in the proposed compliance order.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nWARNING ITEMS\nWith respect to Items 3−9, the Notice alleged probable violations of Part 192 and specifically\nconsidered these to be warning items. The warnings were for:\n49 C.F.R. § 192.459 (Item 3) ─ Respondent’s alleged failure to maintain records\nof certain exposed pipe inspections;\n49 C.F.R. § 192.603(b) (Item 4) ─ Respondent’s alleged failure to maintain\nrecords of emergency response training for personnel in the Great Bend area for\nyears 2007 or 2008;\n49 C.F.R. § 192.605(c) (Item 5) ─ Respondent’s alleged failure to conduct\nperiodic reviews of the effectiveness of procedures for responding to two\nspecified abnormal operating condition events;\n49 C.F.R. § 192.615(b) (Item 6) ─ Respondent’s alleged failure to review\nemployee activities following a failure emergency to determine whether the\nrelevant emergency procedures were effectively followed;\n\n\n\n4\n49 C.F.R. § 192.743(a) (Item 7) ─ Respondent’s alleged failure perform annual\ncapacity calculations for pressure relief devices in the Minneola area within the\nrequired interval;\n49 C.F.R. § 192.481(a) (Item 8) ─ Respondent’s alleged failure to conduct\natmospheric corrosion monitoring inspections on certain above-ground facilities\nin the Minneola, Glasco, and Geneseo areas within the required interval; and\n49 C.F.R. § 192.735(a) (Item 9) ─ Respondent’s alleged failure to store two\nbarrels of combustible materials a safe distance from a compressor building at a\nstation in the Great Bend area.\nNGPA presented information in its Response showing that it had taken certain actions to address\nthe cited items. If OPS finds a violation of any of these provisions in a subsequent inspection,\nRespondent may be subject to future enforcement action.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":9460}