{"operation":"document","citation":"CPF 420151009H","title":"TENNESSEE GAS PIPELINE COMPANY — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-08-06","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420151009h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420151009h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420151009h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420151009H","body":"Corrective Action Order involving TENNESSEE GAS PIPELINE COMPANY. The dataset does not identify a cited regulation for this case. The case was opened on 2015-08-06 and is reported as closed as of 2016-08-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420151009H_Closure Letter_08112016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151009H/420151009H_Closure%20Letter_08112016.pdf\n\n420151009H_Closure Letter_08112016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151009H/420151009H_Closure%20Letter_08112016_text.pdf\n\n420151009H_Corrective Action Order_08062015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151009H/420151009H_Corrective%20Action%20Order_08062015.pdf\n\n420151009H_Corrective Action Order_08062015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151009H/420151009H_Corrective%20Action%20Order_08062015_text.pdf\n\n420151009H_Corrective Action Order_08062015_text.pdf\n\nAugust 6, 2015\nVIA CERTIFIED MAIL AND FAX TO: (832) 397-4536\nMr. Gary Buchler\nVice President, Operations and Engineering\nTennessee Gas Pipeline Company, LLC\n1001 Louisiana Street\nHouston, TX, 77002\nRe: CPF No. 4-2015-1009H\nDear Mr. Buchler:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires Tennessee\nGas Pipeline Company, LLC, to take certain corrective actions with respect to the San Salvador\nLine 400-1 natural gas pipeline, which failed on August 3, 2015, in Brooks County, Texas.\nService is being made by certified mail and facsimile. Service by electronic transmission is\ndeemed complete upon transmission and acknowledgement of receipt, or as otherwise provided\nunder 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion\nof service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. R. M. Seeley, Director, Southwest Region, OPS\nMr. Reji George, Director, Compliance Codes and Standards, Natural Gas Pipeline\nCompany of America, LLC\nMr. Steven J. Kean, President and Chief Operating Officer, Kinder Morgan, Inc.\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nTennessee Gas Pipeline ) CPF No. 4-2015-1009H\nCompany, LLC, )\n)\n)\n)\nRespondent. )\n___________________________________ )\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to\nrequire Tennessee Gas Pipeline Company, LLC (TGP or Respondent), to take the necessary\ncorrective actions to protect the public, property, and the environment from potential hazards\nassociated with the recent failure on Respondent’s San Salvador Line 400-1 natural gas\npipeline.1\nA reportable accident occurred on the San Salvador Line 400-1 pipeline in Brooks County,\nTexas, on August 3, 2015, resulting in the release of an estimated 11 million cubic feet (mmcf)\nof natural gas into the atmosphere. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an\ninvestigation of the accident. The preliminary findings of the ongoing investigation are as\nfollows.\nPreliminary Findings:\n• On August 3, 2015, at approximately 8:30 p.m. Central Standard Time (CST), a failure\noccurred on Respondent’s 16-inch diameter Line 400-1 pipeline approximately 1.5 miles\nsouthwest of the town of Falfurrias, Texas. The accident was reported to the National\nResponse Center (NRC Report # 1124690) on August 3, 2015, at approximately\n9:49 p.m. CST.\n1 Tennessee Gas Pipeline Company, LLC operates an approximately 11,900-mile pipeline system that transports\nnatural gas from Louisiana, the Gulf of Mexico and south Texas to the northeastern U.S. and is a subsidiary of\nKinder Morgan, Inc. See http://www kindermorgan.com/pages/business/gas_pipelines/east/TGP/default.aspx (last\naccessed August 5, 2015).\n\n\n\nCPF No. 4-2015-1009H\nPage 2\n• The Line 400-1 pipeline extends approximately 98.79 miles from Agua Dulce Station to\nEdinburg Station and is part of a system of several parallel pipelines. The segment on\nwhich the failure occurred extends approximately 11.16 miles from VS 403-1 to\nVS 404-1. The pipeline crosses public roads and traverses areas near residences.\nPortions of the pipeline are located in Class 2 populated areas.\n• As a result of the failure, an estimated 11 mmcf of natural gas was released. The blow\nout resulted in an approximate 70- by 30-foot crater.\n• The failure site is located at Station 517+92.2 and is approximately 350 feet away from a\nresidence. Local emergency responders evacuated an area within a five-mile radius of\nthe failure site.\n• In response, TGP depressurized the pipeline and isolated the 11.16-mile section by\nclosing valves VS 403-1 and VS 404-1.\n• The pipeline remains shut down. The cause of the failure has not yet been confirmed, but\na longitudinal split in the pipe approximately 55 feet long could be observed. TGP\nintends to transport the failed pipe section to a metallurgist for testing and failure\nanalysis.\n• The Line 400-1 pipeline was originally constructed in 1947. It consists of Grade X-42\n16-inch diameter electric resistance weld (ERW) seam pipe manufactured by\nYoungstown Steel and has a nominal wall thickness of 0.250 inches, with a coal tar\nenamel coating and an impressed current cathodic protection system.\n• The maximum allowable operating pressure (MAOP) of the pipeline is 903 psig. The\npipeline was hydrostatically tested in 1997. The operating pressure at the time of the\nfailure was approximately 827 psig.\n• PHMSA issued Alert Notice ALN-88-01 in January 1988, advising owners and operators\nof natural gas and hazardous liquids pipelines to consider the threat from ERW pipe\nmanufactured prior to 1970. The operators were to determine whether their pipelines\nwere susceptible to ERW seam failures and address the potential impact on pipeline\nintegrity.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\n\n\n\nCPF No. 4-2015-1009H\nPage 3\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, having considered the nature of the failure; the proximity of the\npipeline to public road crossings and residences; the age and manufacture of the pipeline; the\nhazardous nature of the product the pipeline transports; the pressure required for transporting the\nmaterial; the uncertainties as to the cause of the failure; the potential for ERW seam issues not\npreviously identified; and the ongoing investigation to determine the cause of the failure, I find\nthat a failure to issue this Order expeditiously to require immediate corrective action would result\nin the likelihood of serious harm to life, property, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,\nPHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person\nin Southwest Region Office or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order TGP to immediately take the following corrective\nactions on the San Salvador Line 400-1 pipeline:\nDefinitions:\n“Affected Segment” - The “Affected Segment” means TGP's San Salvador Line 400-1\npipeline extending 98.79 miles from Agua Dulce Station 1 to Edinburg Station 409.\n\"Isolated Segment\" - The \"Isolated Segment\" means the 11.16-mile segment of Line 400-1\nextending from VS 403-1 to VS 404-1.\n\"Director\"\n- The \"Director\" means the Director, Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Southwest Region. The Director’s\naddress is 8701 S. Gessner, Suite 1110, Houston, Texas 77074.\nOperating Restriction. TGP must not operate the Isolated Segment until authorized to do so\nby the Director.\n1.\n\n\n\nCPF No. 4-2015-1009H\nPage 4\n2. Pressure Restriction. TGP must reduce and maintain a twenty percent (20%) pressure\nreduction in the actual operating pressure along the entire length of the Affected Segment\nsuch that the operating pressure along the Affected Segment will not exceed eighty percent\n(80%) of the actual operating pressure in effect immediately prior to the failure on August 3,\n2015.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is obtained from the\nDirector.\nb. This pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\nadjusted accordingly.\n3. Restart Plan. Prior to resuming operation of the Isolated Segment develop and submit a\nwritten Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan, but the Isolated Segment cannot resume operation until the Restart Plan is approved\nin its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment during the\nrestart process and must include incremental pressure increases during start-up, with each\nincrement to be held for at least 2 hours.\nd. The Restart Plan must include sufficient surveillance of the pipeline during each pressure\nincrement to ensure that no leaks are present when operation of the line resumes.\ne. The Restart Plan must specify a day-light restart and include advance communications\nwith local emergency response officials.\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions similar\nto those of the failure, including a review of construction, operating and maintenance\n(O&M) and integrity management records such as in-line inspection (ILI) results,\nhydrostatic tests, root cause failure analysis of prior failures, aerial and ground patrols,\ncorrosion, cathodic protection, excavations and pipe replacements. TGP must address\nany findings that require remedial measures to be implemented prior to restart.\ng. The Restart Plan must also include documentation of the completion of all required\nactions, and a management of change plan to ensure that all procedural modifications are\nincorporated into TGP’s operations and maintenance procedures manual.\n4. Return to Service. After the Director approves the Restart Plan, TGP may return the\nIsolated Segment to service but the operating pressure must not exceed eighty percent (80%)\nof the actual operating pressure in effect immediately prior to the failure on August 3, 2015,\nin accordance with Item 2 above.\n5. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from TGP demonstrating that restoring the pipeline to its pre-failure\noperating pressure is justified based on a reliable engineering analysis showing that the\n\n\n\nCPF No. 4-2015-1009H\nPage 5\npressure increase is safe considering all known defects, anomalies, and operating\nparameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from TGP demonstrating that temporary mitigative\nand preventive measures are implemented prior to and during the temporary removal or\nmodification of the pressure restriction. The Director's determination will be based on the\nfailure cause and provision of evidence that preventative and mitigative actions taken by\nthe operator provide for the safe operation of the Affected Segment during the temporary\nremoval or modification of the pressure restriction. Appeals to determinations of the\nDirector in this regard will be decided by the Associate Administrator for Pipeline Safety.\n6. Mechanical and Metallurgical Testing. Within 45 days of receipt of this Order, complete\nindependent third-party mechanical and metallurgical testing and failure analysis of the failed\npipe, including an analysis of soil samples and any foreign materials. Complete the testing\nand analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the failure site and transport the pipe in accordance with\napplicable protocols to ensure the fracture surface is not damaged.\nb. Within 10 days of receipt of this Order, develop and submit the testing protocol and the\nproposed testing laboratory to the Director for prior approval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director with the\nscheduled date, time, and location of the testing to allow for an OPS representative to\nwitness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their entirety\nto the Director at the same time they are made available to TGP.\n7. Root Cause Failure Analysis. Within 90 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\nThe RCFA must be supplemented/facilitated by an independent third party acceptable to the\nDirector and must document the decision making process and all factors contributing to the\nfailure. The RCFA should include a review of TGP’s approach to monitoring its system for\npotential longitudinal seam issues. The final report must include findings and any lessons\nlearned and whether the findings and any lessons learned are applicable to other locations\nwithin TGP’s pipeline system.\n8. Remedial Work Plan (RWP).\na. Within 90 days following receipt of this Order, TGP must submit a Remedial Work Plan\n(RWP) to the Director for approval.\nb. The Director may approve the RWP incrementally without approving the entire RWP.\nc. Once approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nd. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures TGP will use to verify the integrity of the Affected Segment. It must address all\nknown or suspected factors and causes of the August 3, 2015 failure. TGP should\nconsider both the risk of another failure and the consequence of another failure to develop\n\n\n\nCPF No. 4-2015-1009H\nPage 6\ne. a prioritized schedule for RWP-related work along the Affected Segment.\nThe RWP must include a procedure or process to:\ni. Identify pipe in the Affected Segment with characteristics similar to the contributing\nfactors identified for the August 3, 2015 failure.\nii. Gather all data necessary to review the failure history (in service and pressure test\nfailures) of the Affected Segment and to prepare a written report containing all the\navailable information such as the locations, dates, and causes of leaks and failures.\niii. Integrate the results of the metallurgical testing, root cause failure analysis, and other\ncorrective actions required by this Order with all relevant pre-existing operational and\nassessment data for the Affected Segment. Pre-existing operational data includes, but\nis not limited to, construction, operations, maintenance, testing, repairs, prior\nmetallurgical analyses, and any third-party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic pressure\ntesting, direct assessments, close interval surveys, and DCVG/ACVG surveys.\niv. Determine if conditions similar to those contributing to the failure on August 3, 2015\nare likely to exist elsewhere within the TGP pipeline systems.\nv. Conduct additional field tests, inspections, assessments, and/or evaluations to\ndetermine whether, and to what extent, the conditions associated with the failure on\nAugust 3, 2015, and other failures from the failure history or any other integrity\nthreats are present elsewhere on the Affected Segment. At a minimum, this process\nmust consider all failure causes and specify the use of one or more of the following:\n1) ILI tools that are technically appropriate for assessing the pipeline system, based\non the cause of failure and that can reliably detect and identify anomalies;\n2) Hydrostatic pressure testing;\n3) Close-interval surveys;\n4) Cathodic protection surveys, to include interference surveys in coordination with\nother utilities (e.g. underground utilities, overhead power lines, etc.) in the area;\n5) Coating surveys;\n6) Stress corrosion cracking surveys;\n7) Selective seam corrosion surveys; and\n8) Other tests, inspections, assessments, and evaluations appropriate for the failure\ncauses.\nNote: TGP may use the results of previous tests, inspections, assessments, and\nevaluations if approved by the Director, provided the results of the tests, inspections,\nassessments, and evaluations are analyzed with regard to the factors known or\nsuspected to have caused the failure.\nvi. Describe the inspection and repair criteria TGP will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity threats.\nInclude a description of how any defects will be graded and a schedule for repairs or\nreplacement.\nvii. Based on the known history and condition of the Affected Segment, describe the\nmethods TGP will use to repair, replace, or take other corrective measures to\n\n\n\nCPF No. 4-2015-1009H\nPage 7\nf. g. h. remediate the conditions associated with the pipeline failure and to address other\nknown integrity threats along the Affected Segment.\nviii. Implement continuing long-term periodic testing and integrity verification measures\nto ensure the ongoing safe operation of the Affected Segment, considering the results\nof the analyses, inspections, evaluations, and corrective measures undertaken\npursuant to the Order.\nInclude a proposed schedule for completion of the RWP.\nTGP must revise the RWP as necessary to incorporate new information obtained during\nthe failure investigation and remedial activities, to incorporate the results of actions\nundertaken pursuant to this Order, and/or to incorporate modifications required by the\nDirector.\ni. ii. iii. Submit any plan revisions to the Director for prior approval.\nThe Director may approve plan revisions incrementally.\nAny and all revisions to the RWP after it has been approved and incorporated by\nreference into this Order will be fully described and documented.\nImplement the RWP as it is approved by the Director, including any revisions to the plan\nand maintain records of all actions taken pursuant to this Corrective Action Order for a\nperiod of not less than 10 years.\nOther Requirements:\n1. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; (2) document any approved\nrevisions to the RWP and their implementation; and (3) describe the progress of the\nrepairs or other remedial actions being undertaken. The first quarterly report is due on\nNovember 1, 2015. The Director may change the interval for the submission of these\nreports.\n2. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; and (2) physical changes to pipeline facilities, including\nrepairs, replacements and other modifications.\n3. Approvals. With respect to each submission requiring the approval of the Director, the\nDirector may: (a) approve the submission in whole or in part; (b) approve the submission\non specified conditions; (c) modify the submission to cure any deficiencies;(d)\ndisapprove the submission in whole or in part and direct Respondent to modify the\nsubmission; or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission, as approved or modified by the Director. If the Director\ndisapproves all or any portion of a submission, Respondent must correct all deficiencies\nwithin the time specified by the Director and resubmit it for approval.\n\n\n\nCPF No. 4-2015-1009H\nPage 8\n4. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted and demonstrating\ngood cause for an extension.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190-199, under\nany other order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or under any\nother provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 4-2015-1009H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420151009H_Closure Letter_08112016_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 11, 2016\nMr. Gary Buchler\nVice President, Operations and Engineering\nTennessee Gas Pipeline Company, LLC\n1001 Louisiana Street\nHouston, TX 77002\nCPF 4-2015-1009H\nDear Mr. Buchler:\nOn August 3, 2015, a failure occurred on TGP’s Line 400-1 approximately 1.5 miles from the\nCity of Falfurrias, Texas. The incident was reported to the National Response Center (NRC\nReport # 1124690) on August 3, 2015 at approximately 9:49 p.m. CST.\nPHMSA issued the Corrective Action Order (CAO) 4-2015-1009H to Tennessee Gas Pipeline\nCompany (TGP) on August 6, 2015 requiring a pressure restriction on the affected segment,\ndevelopment of a remedial work plan and mitigative actions necessary for the continued safe\noperation of the pipeline.\nBased on our review of the documentation you provided, it has been determined that you have\ncomplied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":25583}