# NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Corrective Action Order

- **operation:** document
- **citation:** CPF 420121011H
- **title:** NATURAL GAS PIPELINE CO OF AMERICA (KMI) — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-06-12
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420121011h.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420121011h.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420121011h
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420121011H
**body:**

Corrective Action Order involving NATURAL GAS PIPELINE CO OF AMERICA (KMI). The dataset does not identify a cited regulation for this case. The case was opened on 2012-06-12 and is reported as closed as of 2013-03-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420121011H_Closure Letter_03262013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121011H/420121011H_Closure%20Letter_03262013.pdf

420121011H_Corrective Action Order 06122012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121011H/420121011H_Corrective%20Action%20Order%2006122012_text.pdf

420121011H_Corrective Action Order_06122012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420121011H/420121011H_Corrective%20Action%20Order_06122012.pdf

420121011H_Closure Letter_03262013.pdf

U.S. Department
of Transportation
Houston, TX 77074
8701 South Gessner, Suite 1110
Pipeline and
Administration
Hazardous Materials Safety
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 26, 2013
Mr. Dwayne Burton
Vice President, Gas Pipeline Operations
Natural Gas Pipeline Company of America (KMI)
500 Dallas Street, Suite 1000
Room 318011
Houston, TX 77002
CPF No. 4-2012-1011H
Dear Mr. Burton:
On June 6, 2012, Natural Gas Pipeline of America (KMI) experienced a failure of its Oklahoma
Extension (OE #1) 26-inch diameter pipeline near Laketon, Texas. As a result of the incident,
the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Corrective
Action Order (CAO), 4-2012-1011H, dated June 12, 2012, requiring KMI to take corrective
actions with respect to its pipeline system.
The cause of the failure was determined to be hydrogen induced stress cracking within a hard
spot on the pipeline and KMI presented a plan of identification and corrective measures designed
to prevent additional in-service failures. PHMSA monitored the actions taken within the
integrity verification process, and has determined that KMI has substantially completed the
requirements of the CAO.
Consequently, PHMSA has closed the CAO, CPF 4-2012-1011H.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

420121011H_Corrective Action Order_06122012.pdf

of Transportation
U.S. Department
Washington, D.C. 20590
1200 New Jersey Avenue, SE
Materials Safety
Pipeline and Hazardous
JUN 1 2 2012
Administration
VIA CERTIFIED MAIL (Mr. Dwayne Burton| AND FAX TO: (713)-495-7432
Mr. Dwayne Burton
Vice President, Gas Pipeline Operations
Natural Gas Pipeline Company of America (KMI)
500 Dallas Street, Suite 1000
Room 3180H
Houston, TX 77002
Re: CPF No. 4-2012-1011H
Dear Mr. Burton:
Enclosed please find the Corrective Action Order issued in the above-referenced case. It finds
that operation of Natural Gas Pipeline Company of America's 26-inch Oklahoma Extension
natural gas pipeline is hazardous to life, property, and the environment without corrective action.
The Corrective Action Order requires you to take immediate action to protect the public,
property, and the environment in connection with the failure of the pipeline that occurred on or
about June 6, 2012, near Laketon, Texas.
Service of the Corrective Action Order is being made by certified mail and facsimile. Your
receipt of this Corrective Action Order constitutes service of that document under
49 C.F.R. § 190.5. The terms and conditions of the Order are effective upon receipt.
We look forward to a successful resolution of the concerns arising out of this failure to ensure
the safe operation of the pipeline. Please direct any questions on this matter to Rod Seeley,
Director, Southwest Region, OPS, at (713) 272-2852.
Sincerely,
Associate Administrator
for Pipeline Safety
Enclosures: Corrective Action Order and Copy of 49 C.F.R. § 190.233
CC:
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Rod Seeley, Director, Southwest Region, OPS



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of
Natural Gas Pipeline
CPF No. 4-2012-1011H
Company of America (KMI),
Respondent.
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (Order) is being issued under 49 U.S.C. § 60112 to Natural Gas
Pipeline Company of America (KMI) (NGPA or Respondent), the operator of the 26-inch
diameter Oklahoma Extension natural gas pipeline. This Order finds that operation of the
pipeline without corrective action is hazardous to life, property, or the environment and requires
Respondent to take immediate action to ensure the safe operation of the pipeline.
On or about June 6, 2012, Respondent experienced a failure on the Oklahoma Extension (OE #1)
pipeline near the town of Laketon, Texas, resulting in a release of gas that ignited and burned.
Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the accident. The cause
of the failure has not yet been determined. The preliminary findings of the investigation are as
follows:
Preliminary Findings
At approximately 2:00 a.m. CDT on June 6, 2012, Respondent experienced a sudden
pressure drop on the OE #1 pipeline, requiring shut down of the line. Pampa local law
enforcement contacted Respondent's Gas Control 800 number and reported a fire in the
vicinity of a compressor station in a rural farming area.
.
The failure occurred at Compressor Station 154 located at Mile Post (MP) 52 in Gray
County, Texas, approximately four miles east of the town of Laketon.



2
• The escaping gas ignited, leaving a crater approximately 30 feet in diameter and burning
approximately two acres of an agricultural area including two 500-gallon plastic tanks
used to store liquid fertilizer. The fire also burned two telephone poles and associated
transformers and required State Highway 152 to be shut down for several hours.
Following the failure, automated valves closed upstream and downstream of the failure
site and the main fire self-extinguished after about two hours, although a smaller fire
resulting from valve leakage continued to burn for about seven hours. The pipeline
remains out of service.
• NGPA reported the incident to the National Response Center at 4:07 EST a.m. (NRC
Report 1013669)
• On June 9, 2012, Respondent excavated the failure site and removed the section of pipe
containing the failed pipe. The preliminary visual inspection by NGPA at the scene
indicated the presence of a 50-foot-long longitudinal rupture in the body of the pipe at the
1 o'clock position that propagated through one girth weld and arrested at the next
upstream girth weld. The failed pipe section has been transported to a metallurgist in
Houston, Texas, for failure analysis.
• The cause of the failure is unknown and the investigation is ongoing.
• The OE #1 pipeline transports gas from its origin station near the town of Fritch in
Hutchinson County, Texas, across portions of Southern Oklahoma to its end station near
the town of Bridgeport in Wise County, Texas. Its total length is approximately 256
miles and portions of the pipeline are routed near populated areas and cross numerous
state and local highways.
• The 26-inch diameter OE #1 pipeline was constructed in 1957 of 0.250-inch wall
thickness, grade X52 pipe with an electric flash welded (EFW) seam. It was
manufactured by A. O. Smith and has an asphalt enamel coating and an impressed-
current cathodic protection system.
• The maximum allowable operating pressure (MAOP) of the pipeline is 720 psig. At the
time of the failure, the actual operating pressure of the pipeline was reported to be 688
psig.
• NGPA operates an interstate pipeline system consisting of approximately 9,800 miles of
pipeline and is the largest transporter of natural gas into the Chicago market.'
1 Kinder Morgan, to, owns and perses 20% inse i CAL is isi one 1, 20c, owns 80%.



Determination of Necessity for Corrective Action Order and Right to Hearing
Under 49 U.S.C. § 60112 and 49 C.F.R. § 190.233, the Associate Administrator for Pipeline
Safety (Associate Administrator) may issue a corrective action order after providing reasonable
notice and the opportunity for a hearing if he finds that a particular pipeline facility is or would
be hazardous to life, property, or the environment. The terms of such an order may include the
suspended or restricted use of a pipeline facility, physical inspection, testing, repair, replacement,
or any other action as appropriate. The Associate Administrator may also issue a corrective
action order without providing any notice or the opportunity for a hearing if he finds that a
failure to do so expeditiously will result in likely serious harm to life, property or the
environment. The opportunity for a hearing is provided as soon as practicable after the issuance
of the CAO in such cases.
After evaluating the preliminary findings, I find that the continued operation of the OE #1
pipeline without corrective measures would be hazardous to life, property, and the environment.
Additionally, having considered the age of the pipe, the manufacture of the pipe, the
circumstances surrounding the failure, the proximity of the pipeline to populated areas and public
roadways, the hazardous nature of the product being transported, the pressure required for
transporting the material, and the ongoing investigation to determine the cause of the failure, I
find that a failure to issue this Order expeditiously to require immediate corrective action would
result in likely serious harm to life, property, and the environment. Accordingly, this Corrective
Action Order is being issued without prior notice and opportunity for a hearing and the terms and
conditions are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, Southwest Region, PHMSA (Director). If a hearing is requested, it will be held
telephonically or in-person in Houston, Texas.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
additional measures required and amendment of this Order will be considered. To the extent
identify other corrective measures that need to be taken. Respondent will be notified of any
consistent with safety, NGPA will receive notice and an opportunity for a hearing prior to the
imposition of any additional corrective measures.
Required Corrective Action
Pursuant to 49 U.S.C. § 60112, NGPA is ordered to immediately take the following corrective
actions to ensure the safe operation of the 26-inch OE #1 pipeline:
1. Develop and submit a written re-start plan for prior approval of the Director. Obtain
written approval from the Director prior to resuming operation of the pipeline. The
restart plan must address all damage to the pipeline facilities caused by the June 6, 2012
failure. Additionally, the restart plan must provide for adequate patrolling of the pipeline



4
segment during the restart process, must specify a daylight restart, and must specify
advance communications with local emergency response officials.
2. After receiving approval from the Director to restart the pipeline, maintain a twenty
percent (20%) pressure reduction in the operating pressure of the 26-inch Oklahoma
Extension pipeline running from Compressor Station 111 (MP 1) to Compressor Station
801 (MP 256). The operating pressure is not to exceed eighty percent (80%) of the actual
operating pressure in effect immediately prior to the failure. Submit the actual operating
pressures for each pump station on the pipeline at the time of failure and the reduced
discharge pressure limits for approval by the Director in the restart plan referenced in
Item 1. This pressure reduction requires any relevant remote or local alarm limits,
to be adjusted accordingly. If the results of any action undertaken pursuant to this Order
software programming set-points or control points, and mechanical over-pressure devices
necessitate a reduction in the operating pressure permitted by the Order, NGPA must
further reduce the operating pressure accordingly and notify the Director. This pressure
restriction will remain in effect until written approval to increase the pressure or return
the pipeline to its pre-failure operating pressure is obtained from the Director pursuant to
Item 8.
3. Within 45 days of receipt of this Order, complete third-party mechanical and
metallurgical testing of the failed pipe, including analysis of soil samples and any foreign
materials, and a root cause analysis of all factors that caused or contributed to the failure.
Complete the testing and analysis as follows:
A. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the failure site;
B. Use the testing protocol provided by PHMSA and submit the selection of the
testing laboratory to the Director for prior approval;
C. Prior to commencing the mechanical and metallurgical testing, provide the
Director with the scheduled date, time, and location of the testing to allow a PHMSA
representative to witness the testing; and
D. Ensure that the testing laboratory distributes all resulting reports in their entirety
(including all media), whether draft or final, to the Director at the same time as they
are made available to Respondent.
4. Within 90 days following completion of the testing and failure analysis required by Item
3, submit an integrity verification and remedial work plan to the Director for approval.
The plan must provide for the verification of the integrity of the pipeline and must
address all factors known or suspected in the failure. The plan must include:
A. Integration of the results of the testing and failure analysis performed pursuant to
Item 3, with all relevant system data, including all historical repair information,



5
construction, operating, maintenance, testing, metallurgical analysis or other
third-party consultation information, and assessment data for the line segment.
Data-gathering activities must include a review of the failure history (including
both in-service and pressure test failures) of the pipeline and development of a
written report containing all available information regarding locations, dates, and
causes of leaks and failures;
B. The performance of additional field testing, inspections, and evaluations to
determine whether and to what extent the conditions associated with the failure,
or any other integrity-threatening conditions, are present elsewhere on the
pipeline. The additional testing and inspections must include consideration of a
hydrostatic test of the section of OE #1 originating at Compressor Station 154 and
ending at the District 112 Station, additional in-line inspections, or other testing
and inspections as appropriate to the cause of the failure. Include a detailed
description of the criteria to be used for the evaluation and prioritization of any
integrity threats and anomalies that are identified;
C. A detailed description of the inspection and repair criteria to be used in the
evaluation and prioritization of identified integrity threats. This is to include a
description of how any defects are to be graded and a schedule for repairs or
replacement;
D. Provisions for continuing long-term periodic testing and integrity verification
measures, considering the results of the analyses, inspections, and corrective
measures undertaken pursuant to this Order, to ensure the ongoing safe operation
of the pipeline; and
E. A proposed schedule for completion of the actions required by paragraphs A-D of
this Item.
5. Upon approval by the Director, the integrity verification and remedial work plan becomes
incorporated into this Order and must be revised as necessary to incorporate the results of
actions undertaken pursuant to this Order and whenever necessary to incorporate new
information obtained during the failure investigation and remedial activities. Submit any
such plan revisions to the Director for prior approval. The Director may approve plan
elements incrementally.
6. Implement the work plan as approved by the Director, including any revisions to the plan.
7. Submit quarterly reports to the Director that: (1) include all available data and results of
the testing and evaluations required by this Order; and (2) describe the progress of the
repairs or other remedial actions being undertaken. The first quarterly report for the
period from June 6, 2012, through September 30, 2012, shall be due by October 31, 2012.



6
8. The Director may allow the removal or modification of the pressure restriction set forth
in Item 2 upon receipt of a written request from Respondent demonstrating that the
hazard has abated and that restoring the pipeline to its pre-failure operating pressure or
established MAOP is justified based on a reliable engineering analysis showing that the
pressure increase is safe, considering all known defects, anomalies and operating
parameters of the pipeline.
The Director may grant an extension of time for compliance with any of the terms of this Order
upon a written request timely submitted demonstrating good cause for an extension.
With respect to each submission that under this Order requires the approval of the Director, the
Director may: (a) approve, in whole or part, the submission; (b) approve the submission on
specified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove, in
whole or in part, the submission, directing that Respondent modify the submission; or (e) any
combination of the above. In the event of approval, approval upon conditions, or modification
by the Director, Respondent shall proceed to take all actions required by the submission as
approved or modified by the Director. If the Director disapproves all or any portion of the
submission, Respondent shall correct all deficiencies within the time specified by the Director,
and resubmit it for approval. If a resubmitted item is disapproved in whole or in part, the
Director may again require Respondent to correct the deficiencies in accordance with the
foregoing procedure, and the Director may otherwise proceed to enforce the terms of this Order.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. 552(b), you must provide, along with the complete original
document, a second copy of the document with those portions you believe qualify for
confidential treatment redacted, along with an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b).
In your correspondence on this matter, please refer to "CPF No. 4-2012-1011H" and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Order are in addition to and do not waive any requirements that apply to
Respondent's pipeline system under 49 C.F.R. Parts 190 through 199, under any other order
issued to NGPA under authority of 49 U.S.C. Chapter 601, or under any other provision of
Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator, whose
decision will be final.
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.



7
The terms and conditions of this Order are effective upon service in accordance with
49 C.F.R. § 190.5.
JUN 1 2 2012
Jeffrey D. Wiese
Associate Administrator
Date Issued
for Pipeline Safety

420121011H_Corrective Action Order 06122012_text.pdf

JUNE 12, 2012
VIA CERTIFIED MAIL [Mr. Dwayne Burton] AND FAX TO: (713)-495-7432
Mr. Dwayne Burton
Vice President, Gas Pipeline Operations
Natural Gas Pipeline Company of America (KMI)
500 Dallas Street, Suite 1000
Room 3180H
Houston, TX 77002
Re: CPF No. 4-2012-1011H
Dear Mr. Burton:
Enclosed please find the Corrective Action Order issued in the above-referenced case. It finds
that operation of Natural Gas Pipeline Company of America’s 26-inch Oklahoma Extension
natural gas pipeline is hazardous to life, property, and the environment without corrective action.
The Corrective Action Order requires you to take immediate action to protect the public,
property, and the environment in connection with the failure of the pipeline that occurred on or
about June 6, 2012, near Laketon, Texas.
Service of the Corrective Action Order is being made by certified mail and facsimile. Your
receipt of this Corrective Action Order constitutes service of that document under
49 C.F.R. § 190.5. The terms and conditions of the Order are effective upon receipt.
We look forward to a successful resolution of the concerns arising out of this failure to ensure
the safe operation of the pipeline. Please direct any questions on this matter to Rod Seeley,
Director, Southwest Region, OPS, at (713) 272-2852.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosures: Corrective Action Order and Copy of 49 C.F.R. § 190.233
cc: Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Rod Seeley, Director, Southwest Region, OPS



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Natural Gas Pipeline ) CPF No. 4-2012-1011H
Company of America (KMI), )
)
)
)
Respondent. )
____________________________________)
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (Order) is being issued under 49 U.S.C. § 60112 to Natural Gas
Pipeline Company of America (KMI) (NGPA or Respondent), the operator of the 26-inch
diameter Oklahoma Extension natural gas pipeline. This Order finds that operation of the
pipeline without corrective action is hazardous to life, property, or the environment and requires
Respondent to take immediate action to ensure the safe operation of the pipeline.
On or about June 6, 2012, Respondent experienced a failure on the Oklahoma Extension (OE #1)
pipeline near the town of Laketon, Texas, resulting in a release of gas that ignited and burned.
Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the accident. The cause
of the failure has not yet been determined. The preliminary findings of the investigation are as
follows:
Preliminary Findings
• At approximately 2:00 a.m. CDT on June 6, 2012, Respondent experienced a sudden
pressure drop on the OE #1 pipeline, requiring shut down of the line. Pampa local law
enforcement contacted Respondent’s Gas Control 800 number and reported a fire in the
vicinity of a compressor station in a rural farming area.
• The failure occurred at Compressor Station 154 located at Mile Post (MP) 52 in Gray
County, Texas, approximately four miles east of the town of Laketon.



2
• The escaping gas ignited, leaving a crater approximately 30 feet in diameter and burning
approximately two acres of an agricultural area including two 500-gallon plastic tanks
used to store liquid fertilizer. The fire also burned two telephone poles and associated
transformers and required State Highway 152 to be shut down for several hours.
• Following the failure, automated valves closed upstream and downstream of the failure
site and the main fire self-extinguished after about two hours, although a smaller fire
resulting from valve leakage continued to burn for about seven hours. The pipeline
remains out of service.
• NGPA reported the incident to the National Response Center at 4:07 EST a.m. (NRC
Report 1013669)
• On June 9, 2012, Respondent excavated the failure site and removed the section of pipe
containing the failed pipe. The preliminary visual inspection by NGPA at the scene
indicated the presence of a 50-foot-long longitudinal rupture in the body of the pipe at the
1 o’clock position that propagated through one girth weld and arrested at the next
upstream girth weld. The failed pipe section has been transported to a metallurgist in
Houston, Texas, for failure analysis.
• The cause of the failure is unknown and the investigation is ongoing.
• The OE #1 pipeline transports gas from its origin station near the town of Fritch in
Hutchinson County, Texas, across portions of Southern Oklahoma to its end station near
the town of Bridgeport in Wise County, Texas. Its total length is approximately 256
miles and portions of the pipeline are routed near populated areas and cross numerous
state and local highways.
• The 26-inch diameter OE #1 pipeline was constructed in 1957 of 0.250-inch wall
thickness, grade X52 pipe with an electric flash welded (EFW) seam. It was
manufactured by A. O. Smith and has an asphalt enamel coating and an impressed-
current cathodic protection system.
• The maximum allowable operating pressure (MAOP) of the pipeline is 720 psig. At the
time of the failure, the actual operating pressure of the pipeline was reported to be 688
psig.
• NGPA operates an interstate pipeline system consisting of approximately 9,800 miles of
pipeline and is the largest transporter of natural gas into the Chicago market.
1
1 Kinder Morgan, Inc., owns and operates a 20% interest in NGPA, while Myria Holdings, Inc., owns 80%.
http://www.kindermorgan.com/business/gas_pipelines/central/NGPL/ (last visited June 11, 2012).



3
Determination of Necessity for Corrective Action Order and Right to Hearing
Under 49 U.S.C. § 60112 and 49 C.F.R. § 190.233, the Associate Administrator for Pipeline
Safety (Associate Administrator) may issue a corrective action order after providing reasonable
notice and the opportunity for a hearing if he finds that a particular pipeline facility is or would
be hazardous to life, property, or the environment. The terms of such an order may include the
suspended or restricted use of a pipeline facility, physical inspection, testing, repair, replacement,
or any other action as appropriate. The Associate Administrator may also issue a corrective
action order without providing any notice or the opportunity for a hearing if he finds that a
failure to do so expeditiously will result in likely serious harm to life, property or the
environment. The opportunity for a hearing is provided as soon as practicable after the issuance
of the CAO in such cases.
After evaluating the preliminary findings, I find that the continued operation of the OE #1
pipeline without corrective measures would be hazardous to life, property, and the environment.
Additionally, having considered the age of the pipe, the manufacture of the pipe, the
circumstances surrounding the failure, the proximity of the pipeline to populated areas and public
roadways, the hazardous nature of the product being transported, the pressure required for
transporting the material, and the ongoing investigation to determine the cause of the failure, I
find that a failure to issue this Order expeditiously to require immediate corrective action would
result in likely serious harm to life, property, and the environment. Accordingly, this Corrective
Action Order is being issued without prior notice and opportunity for a hearing and the terms and
conditions are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, Southwest Region, PHMSA (Director). If a hearing is requested, it will be held
telephonically or in-person in Houston, Texas.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and amendment of this Order will be considered. To the extent
consistent with safety, NGPA will receive notice and an opportunity for a hearing prior to the
imposition of any additional corrective measures.
Required Corrective Action
Pursuant to 49 U.S.C. § 60112, NGPA is ordered to immediately take the following corrective
actions to ensure the safe operation of the 26-inch OE #1 pipeline:
1. Develop and submit a written re-start plan for prior approval of the Director. Obtain
written approval from the Director prior to resuming operation of the pipeline. The
restart plan must address all damage to the pipeline facilities caused by the June 6, 2012
failure. Additionally, the restart plan must provide for adequate patrolling of the pipeline



4
segment during the restart process, must specify a daylight restart, and must specify
advance communications with local emergency response officials.
2. After receiving approval from the Director to restart the pipeline, maintain a twenty
percent (20%) pressure reduction in the operating pressure of the 26-inch Oklahoma
Extension pipeline running from Compressor Station 111 (MP 1) to Compressor Station
801 (MP 256). The operating pressure is not to exceed eighty percent (80%) of the actual
operating pressure in effect immediately prior to the failure. Submit the actual operating
pressures for each pump station on the pipeline at the time of failure and the reduced
discharge pressure limits for approval by the Director in the restart plan referenced in
Item 1. This pressure reduction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-pressure devices
to be adjusted accordingly. If the results of any action undertaken pursuant to this Order
necessitate a reduction in the operating pressure permitted by the Order, NGPA must
further reduce the operating pressure accordingly and notify the Director. This pressure
restriction will remain in effect until written approval to increase the pressure or return
the pipeline to its pre-failure operating pressure is obtained from the Director pursuant to
Item 8.
3. Within 45 days of receipt of this Order, complete third-party mechanical and
metallurgical testing of the failed pipe, including analysis of soil samples and any foreign
materials, and a root cause analysis of all factors that caused or contributed to the failure.
Complete the testing and analysis as follows:
A. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the failure site;
B. Use the testing protocol provided by PHMSA and submit the selection of the
testing laboratory to the Director for prior approval;
C. Prior to commencing the mechanical and metallurgical testing, provide the
Director with the scheduled date, time, and location of the testing to allow a PHMSA
representative to witness the testing; and
D. Ensure that the testing laboratory distributes all resulting reports in their entirety
(including all media), whether draft or final, to the Director at the same time as they
are made available to Respondent.
4. Within 90 days following completion of the testing and failure analysis required by Item
3, submit an integrity verification and remedial work plan to the Director for approval.
The plan must provide for the verification of the integrity of the pipeline and must
address all factors known or suspected in the failure. The plan must include:
A. Integration of the results of the testing and failure analysis performed pursuant to
Item 3, with all relevant system data, including all historical repair information,



5
construction, operating, maintenance, testing, metallurgical analysis or other
third-party consultation information, and assessment data for the line segment.
Data-gathering activities must include a review of the failure history (including
both in-service and pressure test failures) of the pipeline and development of a
written report containing all available information regarding locations, dates, and
causes of leaks and failures;
B. The performance of additional field testing, inspections, and evaluations to
determine whether and to what extent the conditions associated with the failure,
or any other integrity-threatening conditions, are present elsewhere on the
pipeline. The additional testing and inspections must include consideration of a
hydrostatic test of the section of OE #1 originating at Compressor Station 154 and
ending at the District 112 Station, additional in-line inspections, or other testing
and inspections as appropriate to the cause of the failure. Include a detailed
description of the criteria to be used for the evaluation and prioritization of any
integrity threats and anomalies that are identified;
C. A detailed description of the inspection and repair criteria to be used in the
evaluation and prioritization of identified integrity threats. This is to include a
description of how any defects are to be graded and a schedule for repairs or
replacement;
D. Provisions for continuing long-term periodic testing and integrity verification
measures, considering the results of the analyses, inspections, and corrective
measures undertaken pursuant to this Order, to ensure the ongoing safe operation
of the pipeline; and
E. A proposed schedule for completion of the actions required by paragraphs A-D of
this Item.
5. Upon approval by the Director, the integrity verification and remedial work plan becomes
incorporated into this Order and must be revised as necessary to incorporate the results of
actions undertaken pursuant to this Order and whenever necessary to incorporate new
information obtained during the failure investigation and remedial activities. Submit any
such plan revisions to the Director for prior approval. The Director may approve plan
elements incrementally.
6. Implement the work plan as approved by the Director, including any revisions to the plan.
7. Submit quarterly reports to the Director that: (1) include all available data and results of
the testing and evaluations required by this Order; and (2) describe the progress of the
repairs or other remedial actions being undertaken. The first quarterly report for the
period from June 6, 2012, through September 30, 2012, shall be due by October 31, 2012.



6
8. The Director may allow the removal or modification of the pressure restriction set forth
in Item 2 upon receipt of a written request from Respondent demonstrating that the
hazard has abated and that restoring the pipeline to its pre-failure operating pressure or
established MAOP is justified based on a reliable engineering analysis showing that the
pressure increase is safe, considering all known defects, anomalies and operating
parameters of the pipeline.
The Director may grant an extension of time for compliance with any of the terms of this Order
upon a written request timely submitted demonstrating good cause for an extension.
With respect to each submission that under this Order requires the approval of the Director, the
Director may: (a) approve, in whole or part, the submission; (b) approve the submission on
specified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove, in
whole or in part, the submission, directing that Respondent modify the submission; or (e) any
combination of the above. In the event of approval, approval upon conditions, or modification
by the Director, Respondent shall proceed to take all actions required by the submission as
approved or modified by the Director. If the Director disapproves all or any portion of the
submission, Respondent shall correct all deficiencies within the time specified by the Director,
and resubmit it for approval. If a resubmitted item is disapproved in whole or in part, the
Director may again require Respondent to correct the deficiencies in accordance with the
foregoing procedure, and the Director may otherwise proceed to enforce the terms of this Order.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. 552(b), you must provide, along with the complete original
document, a second copy of the document with those portions you believe qualify for
confidential treatment redacted, along with an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b).
In your correspondence on this matter, please refer to “CPF No. 4-2012-1011H” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Order are in addition to and do not waive any requirements that apply to
Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order
issued to NGPA under authority of 49 U.S.C. Chapter 601, or under any other provision of
Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator, whose
decision will be final.
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.



The terms and conditions of this Order are effective upon service in accordance with
49 C.F.R. § 190.5.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
7
- **truncated:** false
- **body characters:** 37840