{"operation":"document","citation":"CPF 420165027M","title":"KINDER MORGAN WINK PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-08-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165027m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165027m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165027m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420165027M","body":"Notice of Amendment involving KINDER MORGAN WINK PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2016-08-03 and is reported as closed as of 2016-10-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420165027M_Closure Letter_10272016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165027M/420165027M_Closure%20Letter_10272016.pdf\n\n420165027M_Closure Letter_10272016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165027M/420165027M_Closure%20Letter_10272016_text.pdf\n\n420165027M_Notice of Amendment_08032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165027M/420165027M_Notice%20of%20Amendment_08032016.pdf\n\n420165027M_Notice of Amendment_08032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165027M/420165027M_Notice%20of%20Amendment_08032016_text.pdf\n\n420165027M_Operator Response to Notice and Request For Time Extension_09012016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165027M/420165027M_Operator%20Response%20to%20Notice%20and%20Request%20For%20Time%20Extension_09012016.pdf\n\n420165027M_Closure Letter_10272016_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 27, 2016\nMr. Charles Fox\nKinder Morgan - Wink Pipeline, LLC\n500 Dallas, Suite 1000\nHouston, TX 77002\nCPF 4-2016-5027M\nDear Mr. Charles Fox:\nOn multiple occasions between October 6, 2014 and February 18, 2015, representatives from the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of\n49 United States Code, conducted an on-site pipeline safety inspection of the Kinder Morgan -\nWink Pipeline, LLC (Wink) procedures in Wink, TX. As a result of the inspection, Wink was\nissued a Notice of Amendment on August 3, 2016, which proposed amendment of your\nprocedures.\nWink submitted its amended procedures on October 18, 2016. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nR. M. Seeley\nDirector, SW Region\nPipeline and Hazardous Materials Safety Administration\n\n420165027M_Notice of Amendment_08032016_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 3, 2016\nMr. Charles Fox\nKinder Morgan - Wink Pipeline LP\n500 Dallas, Suite 1000\nHouston, TX 77002\nCPF 4-2016-5027M\nDear Charles Fox:\nOn multiple occasions between October 6, 2014 through February 18, 2015, representatives of\nthe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), pursuant to Chapter 601 of 49 United States Code inspected the Kinder Morgan - Wink\n(KM Wink) procedures for operations, maintenance, integrity management, and emergency\nresponse in Wink, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within the\nKM Wink plans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies.\nThis manual shall be reviewed at intervals not exceeding 15 months, but at\nleast once each calendar year, and appropriate changes made as necessary to\ninsure that the manual is effective. This manual shall be prepared before initial\noperations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted.\n\n\n\nKM Wink procedures regarding repairs for internal metal loss/internal corrosion lack guidance or\nlimitation on the term ‘temporary’ with regard to the use of Type B sleeve repairs. KM Wink\ninstalls Type B sleeves on internal metal loss anomalies as permanent repairs knowing that their\npipeline has a high internal corrosion threat.\nAs required by §195.402(c)(3), the procedures must be in accordance with subpart F and subpart\nH of this part. The KM Liquid O&M Manual Procedure L-O&M 213 Leaks, Pipe and Weld\nDefects (Evaluation and Repair) section 3.7.5 Internal Metal Loss states,\n“The limitations for areas with internal metal loss and areas with\na combination of internal metal loss and external corrosion are the\nsame as for external corrosion (RSTRENG). When dealing with\ninternal metal loss, treat it as a manufacturing anomaly and not\nconsidered a defect unless an internal corrosion threat has been\nidentified thru product conditions, unique NDE evaluations, ILI\npattern recognition or prior history. If internal corrosion is\nidentified, then repairs consistent with Table 1 are considered\ntemporary unless the internal corrosion has been successfully\nmitigated, the pressure reduction as noted in Section 3.4 and\nSection 3.7.2 apply.” (underlined for emphasis)\nTable 1 in the procedure does not note the Type B sleeve repair as a temporary repair for internal\ncorrosion. The Type B sleeve is a permanent repair only if it can be proven the internal corrosion\nhas been mitigated. Internal corrosion is repaired using Type B sleeves, which are a temporary\nrepair technique. There is no guidance or limitation on the term “temporary” in the process. KM\ninstalls Type B sleeves for all corrosion repairs, internal or external.\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies.\nThis manual shall be reviewed at intervals not exceeding 15 months, but at least\nonce each calendar year, and appropriate changes made as necessary to insure\nthat the manual is effective. This manual shall be prepared before initial\noperations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted.\nKM Wink does not have procedures that provide the basis for quantifying and adjusting the\ncorrosion inhibitor injection rates within their pipeline systems. KM does not have a process or\nprocedure to give adequate direction for the monitoring of corrosion inhibitors.\nParagraph §195.579 directs an operator to things that must be done to mitigate internal corrosion.\nKM Wink uses both corrosion inhibitor and corrosion coupons/probes in an attempt to monitor\nand control internal corrosion in their pipeline system. KM Liquid O&M Manual Procedure L-\nO&M 906 Internal Corrosion Control, section 3.3.2 Coupon/Probe Monitoring states,\n2\n\n\n\n“If corrosion inhibitors are added in the product service to\nmitigate internal corrosion, it must be used in a sufficient quantity\nto protect the pipeline and corrosion probes and/or coupons shall\nbe used to determine its effectiveness in mitigating internal\ncorrosion.”\nIn section 3.4 Remedial Action, it further states,\n“Pitting of the coupon/probe is an indication of insufficient\ninhibitor to protect the internal surface of the pipe. Indications of\ninsufficient inhibitor to protect the internal surface of the pipe may\nbe if inspections reveal internal corrosion in excess of 1 mpy, or if\nthe coupon/probe surface rust is greater than 50% of the surface\narea for consecutive inspection periods. Corrective actions to\nmitigate insufficient inhibitor protection include:\n• Increasing dosage rate of inhibitor at injection points\n• Increasing coupon inspection interval\n• Investigating source point (refinery) product received into the\npipeline system\n• Increase frequency of cleaning scrapers/pigs\nThe KM representative(s) responsible for internal corrosion\nensures that sufficient inhibitors are used to protect the assigned\nsegment of pipeline.”\nThe process that KM Wink uses for internal corrosion control makes no reference to\nusing/applying manufacturer’s suggested corrosion inhibitor injection rates. The KM process\nshows no correlation between the coupon/probe corrosion rating and the adjustment of the\ncorrosion inhibitor injection rate.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised 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). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\n3\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Kinder Morgan - Wink Pipeline, LP maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to R. M. Seeley, Director, SW\nRegion, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning\nthis matter, please refer to CPF 4-2016-5027M and, for each document you submit, please\nprovide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, SW Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4","truncated":false,"body_characters":10638}