EL PASO NATURAL GAS CO — Notice of Amendment

party submissionOfficial PDF420161006M_Operator Response to Notice_08182016.pdf#

420161006M_Closure Letter_04242017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED April 24, 2017 Mr. Gary Buchler Chief Operating Officer Kinder Morgan Inc. 1001 Louisiana Street, Suite 1000 Houston, TX 77002 CPF 4-2016-1006M Dear Mr. Buchler: On July 15, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to El Paso Natural Gas Company, L.L.C.(EPNG) a Notice of Amendment in the above-referenced case. EPNG is now part of Kinder Morgan. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Notice. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Frank Causey Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420161006M_Notice of Amendment_07142016_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED July 14, 2016 Mr. Gary Buchler El Paso Natural Gas Company 1001 Louisiana Street Houston, TX 77002-5089 CPF 4-2016-1006M Dear Gary Buchler: From November 19, 2013 through August 22, 2014, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected the El Paso Natural Gas West-North (EPNG) procedures and records for Operation and Maintenance (O&M) Plan and conducted field inspection of various pipelines and facilities located in Arizona, New Mexico and Texas. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: §192.605 Procedural manual for operations, maintenance, and emergencies (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (2) Controlling corrosion in accordance with the operations and maintenance requirements of Subpart I of this part.#

420161006M_Notice of Amendment_07142016_text.pdf, page 2The Kinder Morgan O&M procedures are inadequate and fail to comply with §192.463 External Corrosion Control: Cathodic Protection. Specifically, O&M procedure 903: External Corrosion Control for Buried or Submerged Pipelines, revised date: 2013-03-29, Section 3.3.1: Buried or Submerged Steel Structures CP Criteria does not meet the requirements of Appendix D, Section (3). For the 100 Millivolt Polarization Shift criteria, Kinder Morgan must add more detail to the First Method and remove the Second Method. Kinder Morgan must amend this procedure to meet the requirement of Appendix D, Section (3). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 45 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. 2#

420161006M_Notice of Amendment_07142016_text.pdf, page 3It is requested (not mandated) that El Paso Natural Gas Company maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2016-1006M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#