{"operation":"document","citation":"CPF 420075008W","title":"CYPRESS INTERSTATE PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-02-20","effective_on":null,"summary":"CLOSED warning letter citing 195.452(h), 195.452(j).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420075008W","body":"Warning Letter involving CYPRESS INTERSTATE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(h),  195.452(j). The case was opened on 2007-02-20 and is reported as closed as of 2007-02-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420075008W_Warning Letter_02202007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075008W/420075008W_Warning%20Letter_02202007.pdf\n\n420075008W_Warning Letter_02202007.pdf\n\nr\\--il\n| i ; i L - . v |\n@\nU.S. Depqrfment\nof Tronsportolion\nPipellne ond\nHqzqrdous Mqterlqlc Sotety\nAdminislrotion\n8701 South Gessner, Suite 1110\nHouston, TX 77074\nWARNING LETTER\nCERTIFIED MAIL - RETURN REGEIPT REQUESTED\nFebruary 20,2007\nMr. Ron McClain\nVice President of Operations & Engineering\nKinder Morgan Energy Partners, L.P.\n500 Dallas Street, Suite 1000\nHouston, TX 77002\ncPF 4-2007-5008W\nDear Mr. McClain:\nOn September 25 - 29; October 10 - 13; and October 30 - November 3, 2006,\nrepresentatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Arizona Corporation Commission, and the California State Fire Marshall\npursuant to Chapter 601 of 49 United States Code inspected your procedures for your\nIntegrity Management Program (lMP) in Houston, TX, Alpharetta, GA, and Orange, CA,\nrespectively.\nAs a result of this inspection, it appears that Kinder Morgan Energy Partners, L.P.\n(KMEP) has committed probable violations of the pipeline safety regulations, Title 49,\nCode of Federal Regulations, Part 195. The probable violations are as follows:\n1. S 195.452 Pipeline integrity management in high consequence areas.\n(fl What are the elements of an integrity program? Each operator of a\npipeline covered by this section must include, at minimum, in its written\nIMP:\n(5) A continual process of assessment and evaluation to maintain a\npipeline's integrity (see paragraph 0) of this section);\nU) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(1) General. After completing the baseline integrity assessment' an\n\n\n\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(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.\nSeven pipeline segments were not re-assessed within the maximum S-year re-\nassessment interval required by $195.a52fi)(3). Segments that exceeded the S-year\ntimeframe are noted below.\nPipeline Segment\nBaseline\nCompletion Date\nFive Year\nActual Date\nReassessment\nGompleted or\nDate\nScheduled\n1S.64 Rocklin - Chico 41212000 4t2t2005 11t9t2005\nLS-14 Portland -\n5t24t2000 5t2412005 10t2812005\nEuqene\nHwy 52 -\nLS-122\nMission Valley\n5l4l20oo 5t4t2005 6t28t2005\n10\"\nGX64A\n14\" GX64A 14\" 6t28t2000 6t28t2005 11t1012005\nGX64B\n14', GX64B 14\" 612812000 6l28l2oj5 1111012005\nGX32\n10\"t12\" GX3210\"112\" 6t27t2000 6t27t2005 1111812005\nPL-1 19 8\" Pacific Jct -\n8t15t2001 811512006 Scheduled for 4'n\nCouncil Bluff\nquarter 2006\nKMEP did not provide notification to PHMSA that KMEP required a longer assessment\ninterval to perform any of the seven integrity assessments. When KMEP anticipates a\ndelay in conducting an integrity assessment, a notification of the variance from the five\nyear maximum interval should be submitted to PHMSA under 195.452(JX4). A\nnotification based on engineering basis or unavailable technology should be submitted\n270 days and 180 days respectively before the end of the five year (or less) assessment\ninterval.\nPHMSA understands that operational difficulties arise during the performance of\nintegrity assessments, and the organizational changes and process improvements\nKMEP has implemented to address this issue was discussed during the inspection.\nWhen operational difficulties arise during the performance of integrity assessments that\n\n\n\ninitiated wiihin required timeframes and/or KMEP anticipates the possibility of exceeding\nrequired timeframes, the notification process may be used to communicate the reasons\nfor the delay, identify preventive and mitigative measures to be performed during the\ndelay, and provide PHMSA the opportunity to comment.\n2. S 195.452 Pipeline integrity management in high consequence areas.\n(f) see above\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(in its entirety)\nAn anomaly classified as a 60-day repair on PL-107, Morris to Lemont, was not\ndiscovered or remediated within required timeframes. The preliminary lLl report was\nreceived 121212005, and the final lll report was received 11312006. Discovery of\ncondition was established as 612312006, which exceeded the required 180 day\ntimeframe for discovery. The repair was completed on 9/6/2006, which exceeded the\n60-day repair timeframe criteria.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violations persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct\nadditional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Be advised that failure to do so\nwill result in KMEP being subject to additional enforcement action.\nNo reply to this letter is required. lf you choose to reply, in your correspondence please\nrefer to CPF 4-2007-5008W.\nSincerely,\n4*-e6\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration","truncated":false,"body_characters":6288}