# FLORIDA GAS TRANSMISSION CO — Corrective Action Order

- **operation:** document
- **citation:** CPF 420131014H
- **title:** FLORIDA GAS TRANSMISSION CO — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-06-24
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420131014H
**body:**

Corrective Action Order involving FLORIDA GAS TRANSMISSION CO. The dataset does not identify a cited regulation for this case. The case was opened on 2013-06-24 and is reported as closed as of 2016-07-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420131014H_Closure Letter_07272016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131014H/420131014H_Closure%20Letter_07272016.pdf

420131014H_Closure Letter_07272016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131014H/420131014H_Closure%20Letter_07272016_text.pdf

420131014H_Corrective Action Order_06242013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131014H/420131014H_Corrective%20Action%20Order_06242013.pdf

420131014H_Corrective Action Order_06242013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131014H/420131014H_Corrective%20Action%20Order_06242013_text.pdf

420131014H_Closure Letter_07272016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 27, 2016
Mr. Ryan Coffey
Executive Vice President, Operations
Florida Gas Transmission Company, LLC
800 Sonterra Blvd., #400
San Antonio, TX 78258
CPF No. 4-2013-1014H
Dear Mr. Coffey:
On June 18, 2013, a failure occurred on Florida Gas Transmission’s (FGT) Line 200 pipeline
near the town of Enon in Washington Parish, Louisiana. The accident was reported to the
National Response Center (NRC Report # 1050774) on April June 18, 2013, at approximately
07:30, local time.
PHMSA issued the Corrective Action Order (CAO) CPF 4-2013-1014H, to FGT on June 24,
2013, requiring a pressure restriction on the affected segment, development of a remedial work
plan and mitigative actions necessary for the safe operation of the pipeline.
On July 26, 2016, FGT submitted an amended Remedial Work Plan and requested that upon its
approval, the CAO be closed. The amended RWP, Final Version, Rev. 1 is hereby approved.
PHMSA monitored the actions taken within the integrity verification process and reviewed
records submitted by FGT. FGT has completed all of the requirements of the CAO.
Consequently, no further action is necessary under this CAO and this case is now closed.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Eric Amundsen, VP Technical Services, Energy Transfer

420131014H_Corrective Action Order_06242013_text.pdf

JUNE 24, 2013
VIA CERTIFIED MAIL AND FAX TO: (210) 403-7578
Ryan Coffey, Executive Vice President, Operations
Florida Gas Transmission Company, LLC
800 E. Sonterra Blvd., #400
San Antonio, TX 78258
Re: CPF No. 4-2013-1014H
Dear Mr. Coffey:
Enclosed is a Corrective Action Order issued by the Pipeline and Hazardous Materials Safety
Administration in the above-referenced case. It requires Florida Gas Transmission Company,
LLC, to take certain corrective actions with respect to its Line 200 natural gas pipeline that failed
on June 18, 2013, near the town of Enon in Washington Parish, Louisiana. Service is being
made by certified mail and facsimile. Service of this Corrective Action Order by facsimile or
other electronic means is complete upon transmission or acknowledgement of receipt, as
provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are effective
immediately upon service.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
cc: Enclosure
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Rod Seeley, Director, Southwest Region, OPS
Mr. Jeff Whippo, Vice President Operations Services, Florida Gas Transmission Company,
LLC
Mr. Eric Amundsen, Vice President Technical Services, Florida Gas Transmission Company,
LLC



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
__________________________________________
In the Matter of )
Florida Gas Transmission Company, LLC, ) CPF No. 4-2013-1014H
)
)
)
Respondent. )
__________________________________________)
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C. § 60112
and 49 C.F.R. § 190.233, to require Florida Gas Transmission Company, LLC (FGT or
Respondent), to take the necessary corrective action to protect the public, property, and the
environment from potential hazards associated with a recent failure involving FGT’s Line 200
natural gas pipeline in Louisiana.
On June 18, 2013, a failure occurred on a 30-inch diameter section of Respondent’s Line 200
pipeline near the town of Enon in Washington Parish, Louisiana, resulting in the release of an
unknown quantity of natural gas. The cause of the failure has not yet been determined.
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 incident. The
preliminary findings of the ongoing investigation are set forth below.
Preliminary Findings
• FGT, an affiliate of Panhandle Eastern Pipe Line Company, LP, operates approximately
5,400 miles of interstate pipelines that transport natural gas from south Texas to south
Florida.1 Approximately 674 miles of the pipelines in FGT’s system are in the State of
Louisiana. FGT’s natural gas pipelines in Louisiana include an original 24-inch diameter
1 Panhandle Eastern Pipe Line Company, LP, is a subsidiary of Southern Union Company, which is owned by
Energy Transfer Partners, LP, through ETP Holdco Corporation. See
http://www.panhandleenergy.com/comp fld.asp; http://www.energytransfer.com/overview sug.aspx (last accessed
June 21, 2013).



mainline, designated as “Line 100,” that was constructed in the 1950s and later “looped”
with parallel of 26-inch diameter, 30-inch diameter, and 36-inch diameter pipelines.2
• The “Line 200” pipeline is a loop line that includes a 26-inch diameter section that starts
at the Buller Compressor Station at Mile Post (MP) 440.6 in western Louisiana and runs
to the Zachary Compressor Station in Zachary, Louisiana at MP 559.3; and a 30-inch
diameter section that starts west of the Zachary Compressor Station at MP 520.1 and runs
approximately 548 miles to Brooker, Florida. Portions of the 30-inch diameter section of
Line 200 run through populated areas, environmentally sensitive areas, and cross state
and local highways.
• The 30-inch diameter section of Line 200 includes two adjacent sections on the upstream
and downstream sides of the Franklinton Compressor Station (located at MP 64.8) that
are designated as LAMEB-8 and LAMEB-9, respectively.
• The pipeline failed on June 18, 2013, at approximately 6:49 a.m. CST on the 30-inch
diameter LAMEB-9 segment near MP 65.3, approximately 0.5 miles east of the
Franklinton Compressor Station.
• The force of the rupture ejected a 75-foot-long section of pipe from the ground and the
escaping natural gas ignited, causing a fire that burned a nearby forest area and damaged
a residential dwelling and power transmission lines in the area. Various federal, state and
local agencies, including PHMSA, responded to the scene of the failure. One person was
hospitalized and emergency responders evacuated the area and extinguished the fire.
• FGT shut down the pipeline compressors and closed the nearest upstream and
downstream main line valves to minimize further release of product. FGT reported the
failure to the National Response Center at 7:30 a.m. on June 18, 2013 (NRC Report No.
1050774).
• The 30-inch diameter section of Line 200 was originally constructed in 1966. It consists
of Grade X60 pipe manufactured by Kaiser, has a wall thickness of 0.344,” has a double
submerged arc welded (DSAW) seam, and has Bucote coating.
• The maximum allowable operating pressure (MAOP) of the Line 200 segment on which
the failure occurred is 974 psig. At the time of the failure, the actual operating pressure
of the pipeline at the failure site was approximately 952 psig.
• Respondent has removed a 125-foot portion of the pipeline, including the failure origin,
and is transporting it to a metallurgical lab for failure analysis. The LAMEB-9 portion of
Line 200 remains out of service between Main Line Valve (MLV) 9-0 at the Franklinton
Compressor Station and MLV 9-1.
• The cause of the failure is still undetermined and the investigation is ongoing. A
preliminary visual examination of the failed pipe at the scene indicated the possible
presence of external corrosion.
2 The system also includes various laterals.



• This is the second failure on Line 200 in the past 16 months. On February 13, 2012, a
failure at pressures corresponding to similar pipe stress levels occurred on LAMEB-8
between the Zachary Compressor Station and MP 8.1. This failure was determined to
have been caused by external corrosion.3
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is hazardous, requiring corrective action, is set forth both in
the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order without prior opportunity for notice and hearing, upon a finding that
failure to issue the Order expeditiously will likely result in serious harm to life, property, or the
environment. In such cases, an opportunity for a hearing will be provided as soon as practicable
after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
pipeline without corrective measures would be hazardous to life, property, and the environment.
Additionally, having considered the unknown cause of the failure; the location of the failure; the
proximity of the pipeline to populated areas, highways, and environmentally sensitive areas; and
the nature of the product being transported; and the prior failure on the pipeline, I find that a
failure to issue this Order expeditiously to require immediate corrective action would result in
the likelihood of serious harm to life, property, or the environment.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The terms and conditions of this Order 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 or Washington, D.C.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, Respondent will be
notified of any additional measures required and amendment of this Order will be considered.
To the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
3 The LAMEB-8 pipe that failed in 2012 was also constructed in 1966, consisted of 30-inch diameter, Grade X60
pipe manufactured by Kaiser, had a wall thickness of 0.344,” and had a double submerged arc welded (DSAW)
seam. On February 24, 2012, PHMSA issued a Notice of Proposed Safety Order [CPF No. 4-2012-1001S] in
connection with this failure and resulted in a pressure reduction and other required remedial actions.



Required Corrective Actions
Pursuant to 49 U.S.C. § 60112, I hereby order Florida Gas Transmission Company, LLC, to
immediately take the following corrective actions with respect to the 30-inch section of Line
200:
1. Metallurgical Testing. Complete metallurgical testing and analysis of the failed pipe as
follows:
A. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the failure site;
B. Within 10 days of receipt of this Order, submit to the Director a proposed
selection of the testing laboratory and proposed metallurgical testing protocol if
different from PHMSA’s testing protocol 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.
2. Root Cause Failure Analysis. Amend the Root Cause Failure Analysis (RCFA) of the
2012 in-service failure of the LAMEB-8 line to incorporate the June 18, 2013 LAMEB-9
failure, and expand its scope to include the contributing factors as identified in the
metallurgical analysis for both failures. The RCFA must ensure that the management
practices applied to the oversight of FGT’s corrosion and integrity programs are included
in the scope of the failure analysis and proposed remedial actions. The RCFA must
document all contributory factors and the basis for recommended actions. Submit a final
report of the RCFA results to the Director, including any lessons learned and whether the
findings are applicable to other locations on Line 200.
3. Restart Plan. Develop and submit a written re-start plan for prior approval of the
Director, Southwest Region. The restart plan must provide for the completion of all
necessary repairs at the failure site, provide for adequate patrolling of the pipeline during
the restart process, and specify a daylight restart and provide for advance
communications with local emergency response officials. Obtain written approval from
the Director prior to resuming operation.
4. Pressure Restricted Segment. After receiving approval from the Director to restart the
pipeline, the pressure in the LAMEB-9 segment running from the Franklinton
Compressor Station at MP 64.8 to the Wiggins Compressor Station at MP 128.8
(Pressure Restricted Segment) is not to exceed 80% of the actual operating pressure in
effect immediately prior to the failure, or 762 psig. Further, FGT must ensure that the
reduced operating pressures in the Pressure Restricted Segment will not exceed 65% of
specified minimum yield strength (SMYS) for this segment. This pressure restriction



requires that any relevant pressure control equipment, including remote or local alarm
limits, software programming set-points or control points, and mechanical over-pressure
protection devices, be adjusted accordingly. If the results of any action undertaken
pursuant to the Order necessitate a reduction in the operating pressure permitted by the
Order, FGT must further reduce the operating pressure accordingly and notify the
Director. This pressure restriction will remain in effect on the Pressure Restricted
Segment until written approval to increase the pressure or return the segment to its pre-
failure operating pressure is obtained from the Director.
5. Removal of Pressure Restriction. The Director may allow the removal or modification of
the pressure restriction set forth above upon a written request from Respondent
demonstrating that restoring the Pressure Restricted Segment to its pre-failure operating
pressure 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
pipe in this segment.
6. Remedial Work Plan. Within 90 days after completing the metallurgical testing and
RCFA, submit a remedial work plan (“Work Plan”) to the Director for approval. The
Work Plan must provide for the verification of the integrity of the 30-inch section of Line
200 and must address all factors known or suspected in the failure, including but not
limited to the following:
A. A written plan for: (1) the identification and remediation of areas of failed coating
through methods capable of finding failed coating; and (2) the re-evaluation of
FGT’s integrity management process for determining corrosion growth rates and
determining appropriate inspection and integrity assessment intervals in areas
where failed coating may exist, to ensure that assessments and repairs are
completed prior to external corrosion failures.
B. The integration of the results of the failure analyses and other actions required by
this Order with all relevant operating data for the 30-inch section of Line 200,
including all historical repair information, construction, operating, maintenance,
testing, metallurgical analysis or other third-party consultation information, and
assessment data;
C. 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 results of the inspections, field excavations, and evaluations must be made
available to PHMSA or its representative;
D. The performance of repairs or other corrective measures that fully remediate the
identified risk conditions associated with the pipeline failure and any other
integrity-threatening condition identified under this Order. Based on the known
history and condition of the pipeline, the plans for repairs must include continuing
long-term periodic testing and integrity verification measures to ensure the
ongoing safe operation of the pipeline, considering the results of the analyses,
inspections, and corrective measures undertaken pursuant to the Order;



E. A proposed schedule for completion of Items A−D.
7. Incorporation and Revisions. The Work Plan will be incorporated by reference into this
Order. Respondent must revise the Work Plan 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.
8. Implementation. Implement the Work Plan as approved by the Director, including any
revisions to the plan.
9. Reporting. Submit quarterly reports to the Director that: (1) include all available data and
results of the testing and evaluations conducted pursuant to this Order; and (2) describe
the progress of the repairs or other remedial actions being undertaken. The first quarterly
report is due on September 15, 2013. The Director may change the interval for the
submission of these reports.
10. Documentation of the Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Corrective Action
Order. Include in each monthly report submitted, the to-date total costs associated with:
(1) preparation and revision of procedures, studies and analyses; (2) physical changes to
pipeline facilities, including repairs, replacements and other modifications; and (3)
environmental remediation, if applicable.
11. Approvals. 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 action required by the submission as approved or modified by the Director. If the
Director disapproves all or any portion of the submission, Respondent must correct all
deficiencies within the time specified by the Director, and resubmit it for approval.
12. Extensions of Time. 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.
The actions required by this Corrective Action Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 192, under any
other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other
provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.



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), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted information
qualifies for confidential treatment under 5 U.S.C. 552(b).
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.
In your correspondence on this matter, please refer to CPF No. 4-2013-1014H and for each
document you submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Corrective Action Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
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