{"operation":"document","citation":"CPF 420075004M","title":"CYPRESS INTERSTATE PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-02-15","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(c), 195.452(h)(2), 195.452(j).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420075004M","body":"Notice of Amendment involving CYPRESS INTERSTATE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(c),  195.452(h)(2),  195.452(j). The case was opened on 2007-02-15 and is reported as closed as of 2007-02-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420075004M_Notice Letter_02152007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075004M/420075004M_Notice%20Letter_02152007.pdf\n\n420075004M_Notice Letter_02152007.pdf\n\n@\nU.S. Deportment\nof Tronsporlotion\nPipeline oncl\nHozordous trloleriqls Sofety\nAdministrotion\n8701 South Gessnet. Suite 1110\nHouston, fX 77W4\nNOTICE OF AMENDMENT\nCERTIFIED MAIL . RETURN RECEIPT REQUESTED\nFebruary 15,2007\nMr. Ron McClain\nVice President of Operations & Engineering\nKinder Morgan Energy Partners, L.P.\n500 Dallas Street, Suite 1000\nHouston, TX 77002\ncPF 4-2007-5004M\nDear Mr. McClain:\nOn September 25-29; October 10-13; and October 30-November 3, 2006, representatives\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Arizona\nCorporation Commission, and the California State Fire Marshall pursuant to Chapter 601 of\n49 United States Code inspected your procedures for your Integrity Management Program\n(lMP) in Houston, TX, Alpharetta, GA, and Orange, CA, respectively.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nKinder Morgan's plan or procedure and are described below:\n1. 5195.452 Pipeline integrity management in high consequence areas.\n(fl What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the\nfollowing elements in its written integrity management program:\n\n\n\n(4) Griteria for remedial actions to address integrity issues raised by the\nassessment methods and information analysis (see paragraph (h) of\nthis section)\n(h) What actions must an operator take to address integrity issues?\n(1) General requirements. An operator must take prompt action to\naddress all anomalous conditions that the operator discovers through\nthe integrity assessment or information analysis. ln addressing all\nconditions, an operator must evaluate all anomalous conditions and\nremediate those that could reduce a pipeline's integrity. An operator\nmust be able to demonstrate that the remediation of the condition will\nensure that the condition is unlikely to pose a threat to the long-term\nintegrity of the pipeline. A reduction in operating pressure cannot\nexceed 365 days without an operator taking further remedial action to\nensure the safety of the pipeline. An operator must comply with\n5195.422 when making a repair.\n(2) Discovery of condition. Discovery of a condition occurs when an\noperator has adequate information about the condition to determine that\nthe condition presents a potential threat to the integrity of the pipeline.\nAn operator must promptly, but no later than 180 days after an integrity\nassessment, obtain sufficient information about a condition to make\nthat determination, unless the operator can demonstrate that the 180-\nday period is impracticable.\nAppendix H7 .1, Section 4.4.2.3 requires that a minimum of one validation dig be conducted\nfor each lll tool run within 60 days of receiving the final report. A consumption of 60 days\nfor validating the results of the lLl report and conducting validation dig delays declaration of\ndiscovery of anomalous conditions and potentially delays the repair of anomalies meeting\n60-day criteria beyond the required timeframe. Appendix H7.3 details the process and\nprocedures used during the lll Metal Loss Tool Grading and Validation. The Inspection\nTeam reviewed proposed changes and detail to the discovery process for specific tools\n(and threats), and we continue to review how this process for discovery timeframes align\nwith rule requirements and PHMSA expectations. The process to declare discovery within\ntypical lLl tool applications must be sufficiently detailed to ensure consistent application.\n2. S 195.452 Pipeline integrity management in high consequence areas.\n(Q see above\n(5) A continual process of assessment and evaluation to maintain a\npipeline's integrity (see paragraph 0) of this section);\nlSl What is a continual process of evaluation and assess/nent to maintain a\npipeline's integrity?\n(1) General. After completing the baseline integrity assessment, an\noperator must continue to assess the line pipe at specified intervals and\nperiodically evaluate the integrity of each pipeline segment that could\naffect a high consequence area.\n(21 Evaluation. An operator must conduct a periodic evaluation as\nfrequently as needed to assure pipeline integrity. An operator must base\n\n\n\nthe frequency of evaluation on risk factors specific to its pipeline,\nincluding the factors specified in paragraph (e) of this section. The\nevaluation must consider the results of the baseline and periodic\nintegrity assessments, information analysis (paragraph (g) of this\nsection), and decisions about remediation, and preventive and\nmitigative actions (paragraphs (h) and (i) of this section).\n(3) Assessment intervals. An operator must establish intervals not to\nexceed five (5) years for continually assessing the line pipe's integrity.\nAn operator must base the assessment intervals on the risk the line\npipe poses to the high consequence area to determine the priority for\nassessing the pipeline segments. An operator must establish the\nassessment intervals based on the factors specified in paragraph (e) of\nthis section, the analysis of the results from the last integrity\nassessment, and the information analysis required by paragraph (g) of\nthis section.\nKMEP must detail the specific process inputs used in the hydrostatic pressure test\nreassessment interval determination process to ensure the 195.4520X3) requirements are\nmet.\n3. S 195.452 Pipeline integrity management in high consequence areas.\n(f) see above\n(2) A baseline assessment plan meeting the requirements of paragraph\n(c) of this section;\n(c) What must be in the baseline assessment plan?\n(1) An operator must include each of the following elements in its\nwritten baseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An\noperator must assess the integrity of the line pipe by any of the\nfollowing methods. The methods an operator selects to assess low\n. frequency electric resistance welded pipe or lap welded pipe\nsusceptible to longitudinal seam failure must be capable of\nand or detectins corrosion and\nffir=;:If.\" XH\",ll::n''\"\n(C) External corrosion direct assessment in accordance with\ns195.588;\nS 195.588 What standards apply to direct assessment?\n(a) lf you use direct assessment on an onshore pipeline to evaluate the effects\nof external corrosion, you must follow the requirements of this section for\nperforming external corrosion direct assessment. This section does not apply\nto methods associated with direct assessment, such as close interval surveys,\nvoltage gradient suryeys, or examination of exposed pipelines, when used\nseparately from the direct assessment process.\n(b) The requirements for performing external corrosion direct assessment are\nas follows:\n\n\n\n(1) General. You must follow the requirements of NACE Standard\nRP0502-2002 (incorporated by reference, see 5195.3). Also, you must\ndevelop and implement an EGDA plan that includes procedures\naddressing pre-assessment, indirect examination, direct examination,\nand post-assessment.\n(2) Pre-assessment. In addition to the requirements in Section 3 of\nNACE Standard RP0502-2002, the ECDA plan procedures for pre'\nassessment must include-\n(i) Provisions for applying more restrictive criteria when conducting\nEGDA for the first time on a pipeline segment;\n(ii) The basis on which you select at least two different, but\ncomplementary, indirect assessment tools to assess each EGDA\nregion; and\n(iii) lf you utilize an indirect inspection method not described in\nAppendix A of NAGE Standard RP0502-2002, you must demonstrate\nthe applicability, validation basis, equipment used, application\nprocedure, and utilization of data for the inspection method.\n(3) Indirect examination. In addition to the requirements in Section 4 of\nNACE Standard RP0502-2002, the procedures for indirect examination\nof the EGDA regions must include-\n(i) Provisions for applying more restrictive criteria when conducting\nECDA for the first time on a pipeline segment;\n(ii) Griteria for identifying and documenting those indications that\nmust be considered for excavation and direct examination,\nincluding at least the following:\n(A) The known sensitivities of assessment tools;\n(B) The procedures for using each tool; and\n(C) The approach to be used for decreasing the physical spacing of\nindirect assessment tool readings when the presence of a defect is\nsuspected;\n(iii) For each indication identified during the indirect examination,\ncriteria for-\n(A) Defining the urgency of excavation and direct examination of the\nindication; and\n(B) Defining the excavation urgency as immediate, scheduled, or\nmonitored; and\n(iv) Griteria for scheduling excavations of indications in each\nurgency level.\n(4) Direct examination. In addition to the requirements in Section 5 of\nNACE Standard RP0502-2002, the procedures for direct examination of\nindications from the indirect examination must include-\n(i) Provisions for applying more restrictive criteria when conducting\nECDA for the first time on a pipeline segment;\n(ii) Griteria for deciding what action should be taken if either:\n(A) Gorrosion defects are discovered that exceed allowable limits\n(Section 5.5.2.2 of NACE Standard RP0502-2002 provides guidance\nfor criteria); or\n\n\n\n(B) Root cause analysis reveals conditions for which ECDA is not\nsuitable (Section 5.6.2 of NAGE Standard RP0502-2002 provides\nguidance for criteria) ;\n(iii) Griteria and notification procedures for any changes in the\nECDA plan, including changes that affect the severity classification,\nthe priority of direct examination, and the time frame for direct\nexamination of indications; and\n(iv) Criteria that describe how and on what basis you will reclassify\nand re-prioritize, any of the provisions specified in Section 5.9 of\nNAGE Standard RP0502-2002.\n(5) Post assessment and continuing evaluation. In addition to the\nrequirements in Section 6 of NACE Standard UP 0502-2002, the\nprocedures for post assessment of the effectiveness of the ECDA\nprocess must include-\n(i) Measures for evaluating the long-term effectiveness of ECDA in\naddressing external corrosion in pipeline segments; and\n(ii) Griteria for evaluating whether conditions discovered by direct\nexamination of indications in each ECDA region indicate a need for\nreassessment of the pipeline segment at an interval less than that\nspecified in Sections 6.2 and 6.3 of NAGE Standard RP0502-2002\n(see Appendix D of NAGE Standard RP0502-2002).\nIMP Appendix H8.2 provides the basis for implementing an ECDA plan, and the procedure\nmust modified to provide the detail necessary to consistently develop a \"business unit asset\nspecific\" ECDA ptan by specifying the requirements of $195.588 and NACE RP 0502\nstandard, as appropriate.\nln regard to ltems 1, 2, and 3 listed above, KMEP provided finalized documentation via\nemail to PHMSA on December 1, 2006, of various changes made to the lMP. After\nconsidering the material provided, PHMSA deemed the modifications adequate, and no\nfurther action is required in response to this Notice.\nSincerely,\n44@\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Ad ministration\nEnclosure: Respons e Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":12013}