# CYPRESS INTERSTATE PIPELINE LLC — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 195.452(c), 195.452(h)(2), 195.452(j).
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**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.

Official case documents:

420075004M_Notice Letter_02152007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075004M/420075004M_Notice%20Letter_02152007.pdf

420075004M_Notice Letter_02152007.pdf

@
U.S. Deportment
of Tronsporlotion
Pipeline oncl
Hozordous trloleriqls Sofety
Administrotion
8701 South Gessnet. Suite 1110
Houston, fX 77W4
NOTICE OF AMENDMENT
CERTIFIED MAIL . RETURN RECEIPT REQUESTED
February 15,2007
Mr. Ron McClain
Vice President of Operations & Engineering
Kinder Morgan Energy Partners, L.P.
500 Dallas Street, Suite 1000
Houston, TX 77002
cPF 4-2007-5004M
Dear Mr. McClain:
On September 25-29; October 10-13; and October 30-November 3, 2006, representatives
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Arizona
Corporation Commission, and the California State Fire Marshall pursuant to Chapter 601 of
49 United States Code inspected your procedures for your Integrity Management Program
(lMP) in Houston, TX, Alpharetta, GA, and Orange, CA, respectively.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within
Kinder Morgan's plan or procedure and are described below:
1. 5195.452 Pipeline integrity management in high consequence areas.
(fl What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the
following elements in its written integrity management program:



(4) Griteria for remedial actions to address integrity issues raised by the
assessment methods and information analysis (see paragraph (h) of
this section)
(h) What actions must an operator take to address integrity issues?
(1) General requirements. An operator must take prompt action to
address all anomalous conditions that the operator discovers through
the integrity assessment or information analysis. ln addressing all
conditions, an operator must evaluate all anomalous conditions and
remediate those that could reduce a pipeline's integrity. An operator
must be able to demonstrate that the remediation of the condition will
ensure that the condition is unlikely to pose a threat to the long-term
integrity of the pipeline. A reduction in operating pressure cannot
exceed 365 days without an operator taking further remedial action to
ensure the safety of the pipeline. An operator must comply with
5195.422 when making a repair.
(2) Discovery of condition. Discovery of a condition occurs when an
operator has adequate information about the condition to determine that
the condition presents a potential threat to the integrity of the pipeline.
An operator must promptly, but no later than 180 days after an integrity
assessment, obtain sufficient information about a condition to make
that determination, unless the operator can demonstrate that the 180-
day period is impracticable.
Appendix H7 .1, Section 4.4.2.3 requires that a minimum of one validation dig be conducted
for each lll tool run within 60 days of receiving the final report. A consumption of 60 days
for validating the results of the lLl report and conducting validation dig delays declaration of
discovery of anomalous conditions and potentially delays the repair of anomalies meeting
60-day criteria beyond the required timeframe. Appendix H7.3 details the process and
procedures used during the lll Metal Loss Tool Grading and Validation. The Inspection
Team reviewed proposed changes and detail to the discovery process for specific tools
(and threats), and we continue to review how this process for discovery timeframes align
with rule requirements and PHMSA expectations. The process to declare discovery within
typical lLl tool applications must be sufficiently detailed to ensure consistent application.
2. S 195.452 Pipeline integrity management in high consequence areas.
(Q see above
(5) A continual process of assessment and evaluation to maintain a
pipeline's integrity (see paragraph 0) of this section);
lSl What is a continual process of evaluation and assess/nent to maintain a
pipeline's integrity?
(1) General. After completing the baseline integrity assessment, an
operator must continue to assess the line pipe at specified intervals and
periodically evaluate the integrity of each pipeline segment that could
affect a high consequence area.
(21 Evaluation. An operator must conduct a periodic evaluation as
frequently as needed to assure pipeline integrity. An operator must base



the frequency of evaluation on risk factors specific to its pipeline,
including the factors specified in paragraph (e) of this section. The
evaluation must consider the results of the baseline and periodic
integrity assessments, information analysis (paragraph (g) of this
section), and decisions about remediation, and preventive and
mitigative actions (paragraphs (h) and (i) of this section).
(3) Assessment intervals. An operator must establish intervals not to
exceed five (5) years for continually assessing the line pipe's integrity.
An operator must base the assessment intervals on the risk the line
pipe poses to the high consequence area to determine the priority for
assessing the pipeline segments. An operator must establish the
assessment intervals based on the factors specified in paragraph (e) of
this section, the analysis of the results from the last integrity
assessment, and the information analysis required by paragraph (g) of
this section.
KMEP must detail the specific process inputs used in the hydrostatic pressure test
reassessment interval determination process to ensure the 195.4520X3) requirements are
met.
3. S 195.452 Pipeline integrity management in high consequence areas.
(f) see above
(2) A baseline assessment plan meeting the requirements of paragraph
(c) of this section;
(c) What must be in the baseline assessment plan?
(1) An operator must include each of the following elements in its
written baseline assessment plan:
(i) The methods selected to assess the integrity of the line pipe. An
operator must assess the integrity of the line pipe by any of the
following methods. The methods an operator selects to assess low
. frequency electric resistance welded pipe or lap welded pipe
susceptible to longitudinal seam failure must be capable of
and or detectins corrosion and
ffir=;:If." XH",ll::n''"
(C) External corrosion direct assessment in accordance with
s195.588;
S 195.588 What standards apply to direct assessment?
(a) lf you use direct assessment on an onshore pipeline to evaluate the effects
of external corrosion, you must follow the requirements of this section for
performing external corrosion direct assessment. This section does not apply
to methods associated with direct assessment, such as close interval surveys,
voltage gradient suryeys, or examination of exposed pipelines, when used
separately from the direct assessment process.
(b) The requirements for performing external corrosion direct assessment are
as follows:



(1) General. You must follow the requirements of NACE Standard
RP0502-2002 (incorporated by reference, see 5195.3). Also, you must
develop and implement an EGDA plan that includes procedures
addressing pre-assessment, indirect examination, direct examination,
and post-assessment.
(2) Pre-assessment. In addition to the requirements in Section 3 of
NACE Standard RP0502-2002, the ECDA plan procedures for pre'
assessment must include-
(i) Provisions for applying more restrictive criteria when conducting
EGDA for the first time on a pipeline segment;
(ii) The basis on which you select at least two different, but
complementary, indirect assessment tools to assess each EGDA
region; and
(iii) lf you utilize an indirect inspection method not described in
Appendix A of NAGE Standard RP0502-2002, you must demonstrate
the applicability, validation basis, equipment used, application
procedure, and utilization of data for the inspection method.
(3) Indirect examination. In addition to the requirements in Section 4 of
NACE Standard RP0502-2002, the procedures for indirect examination
of the EGDA regions must include-
(i) Provisions for applying more restrictive criteria when conducting
ECDA for the first time on a pipeline segment;
(ii) Griteria for identifying and documenting those indications that
must be considered for excavation and direct examination,
including at least the following:
(A) The known sensitivities of assessment tools;
(B) The procedures for using each tool; and
(C) The approach to be used for decreasing the physical spacing of
indirect assessment tool readings when the presence of a defect is
suspected;
(iii) For each indication identified during the indirect examination,
criteria for-
(A) Defining the urgency of excavation and direct examination of the
indication; and
(B) Defining the excavation urgency as immediate, scheduled, or
monitored; and
(iv) Griteria for scheduling excavations of indications in each
urgency level.
(4) Direct examination. In addition to the requirements in Section 5 of
NACE Standard RP0502-2002, the procedures for direct examination of
indications from the indirect examination must include-
(i) Provisions for applying more restrictive criteria when conducting
ECDA for the first time on a pipeline segment;
(ii) Griteria for deciding what action should be taken if either:
(A) Gorrosion defects are discovered that exceed allowable limits
(Section 5.5.2.2 of NACE Standard RP0502-2002 provides guidance
for criteria); or



(B) Root cause analysis reveals conditions for which ECDA is not
suitable (Section 5.6.2 of NAGE Standard RP0502-2002 provides
guidance for criteria) ;
(iii) Griteria and notification procedures for any changes in the
ECDA plan, including changes that affect the severity classification,
the priority of direct examination, and the time frame for direct
examination of indications; and
(iv) Criteria that describe how and on what basis you will reclassify
and re-prioritize, any of the provisions specified in Section 5.9 of
NAGE Standard RP0502-2002.
(5) Post assessment and continuing evaluation. In addition to the
requirements in Section 6 of NACE Standard UP 0502-2002, the
procedures for post assessment of the effectiveness of the ECDA
process must include-
(i) Measures for evaluating the long-term effectiveness of ECDA in
addressing external corrosion in pipeline segments; and
(ii) Griteria for evaluating whether conditions discovered by direct
examination of indications in each ECDA region indicate a need for
reassessment of the pipeline segment at an interval less than that
specified in Sections 6.2 and 6.3 of NAGE Standard RP0502-2002
(see Appendix D of NAGE Standard RP0502-2002).
IMP Appendix H8.2 provides the basis for implementing an ECDA plan, and the procedure
must modified to provide the detail necessary to consistently develop a "business unit asset
specific" ECDA ptan by specifying the requirements of $195.588 and NACE RP 0502
standard, as appropriate.
ln regard to ltems 1, 2, and 3 listed above, KMEP provided finalized documentation via
email to PHMSA on December 1, 2006, of various changes made to the lMP. After
considering the material provided, PHMSA deemed the modifications adequate, and no
further action is required in response to this Notice.
Sincerely,
44@
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Ad ministration
Enclosure: Respons e Options for Pipeline Operators in Compliance Proceedings
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