{"operation":"document","citation":"CPF 42020008CAO","title":"FLORIDA GAS TRANSMISSION CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-09-18","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020008cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020008cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020008cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42020008CAO","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 2020-09-18 and is reported as closed as of 2026-01-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42020008CAO_Amended Corrective Action Order_10012020_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Amended%20Corrective%20Action%20Order_10012020_(20-190995).pdf\n\n42020008CAO_Amended Corrective Action Order_10012020_(20-190995)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Amended%20Corrective%20Action%20Order_10012020_(20-190995)_text.pdf\n\n42020008CAO_Closure Letter_01202026_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Closure%20Letter_01202026_(20-190995).pdf\n\n42020008CAO_Closure Letter_01202026_(20-190995)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Closure%20Letter_01202026_(20-190995)_text.pdf\n\n42020008CAO_Corrective Action Order_09182020_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Corrective%20Action%20Order_09182020_(20-190995).pdf\n\n42020008CAO_Corrective Action Order_09182020_(20-190995)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Corrective%20Action%20Order_09182020_(20-190995)_text.pdf\n\n42020008CAO_Operator Hearing Request Withdrawn_10302020_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Operator%20Hearing%20Request%20Withdrawn_10302020_(20-190995).pdf\n\n42020008CAO_Operator Request for Hearing and Request Statement of Issues_10132020_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Operator%20Request%20for%20Hearing%20and%20Request%20Statement%20of%20Issues_10132020_(20-190995).pdf\n\n42020008CAO_PHC Hearing Scheduled_10232020_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_PHC%20Hearing%20Scheduled_10232020_(20-190995).pdf\n\n42020008CAO_PHC Hearing Scheduled_10232020_(20-190995)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_PHC%20Hearing%20Scheduled_10232020_(20-190995)_text.pdf\n\n42020008CAO_Second Amended Corrective Action Order_10222020_(20-190995).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Second%20Amended%20Corrective%20Action%20Order_10222020_(20-190995).pdf\n\n42020008CAO_Second Amended Corrective Action Order_10222020_(20-190995)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020008CAO/42020008CAO_Second%20Amended%20Corrective%20Action%20Order_10222020_(20-190995)_text.pdf\n\n42020008CAO_Second Amended Corrective Action Order_10222020_(20-190995)_text.pdf\n\nOctober 22, 2020\nVIA ELECTRONIC MAIL TO: matthew.ramsey@energytransfer.com\nMatthew Ramsey\nChief Operating Officer\nEnergy Transfer Partners, LP\n8111 Westchester Drive\nDallas, Texas 75225\nCPF No. 4-2020-008-CAO\nDear Mr. Ramsey:\nEnclosed please find a Second Amended Corrective Action Order (Second ACAO) issued by the\nPipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, in the above-\nreferenced case to Florida Gas Transmission Company (FGT), which is operated by Energy\nTransfer Partners, LP. The Second ACAO continues to require that FGT take corrective actions\npreviously ordered on September 18, 2020, and October 1, 2020, with respect to an incident that\noccurred on the 12-inch Sanford Lateral on September 10, 2020, located in Sandford, Florida, and\na rupture that occurred on September 24, 2020, on FGT’s 18-inch FLMEA-21 pipeline located in\nLake Worth, Florida.\nThe Second ACAO modifies a few of the preliminary findings, including clarifying the location\nof the September 24, 2020 incident and the prior Corrective Action Orders PHMSA issued for\nFGT’s pre-1970 low-frequency electric resistance welded pipe. The Second ACAO also amends\nthe definition of the Affected Pipeline for the September 24, 2020 incident, and corrects\ninconsistencies for two of the corrective actions regarding operating pressure restrictions of the\naffected pipeline for the September 24, 2020 incident and documentation of costs. Finally, the\nSecond ACAO does not amend any of the deadlines in the Amended Corrective Action Order\nissued on October 1, 2020.\nService of the Second ACAO by electronic transmission is deemed complete upon transmission\nand acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms\nand conditions of this Order are effective upon completion of service.\n\n\n\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: Second ACAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMs. Mary L. McDaniel, P.E., Director, Southwestern Region, OPS\nMr. Eric Amundsen, Senior Vice President, Energy Transfer Partners, LP,\neric.amundsen@energytransfer.com\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 )\nFlorida Gas Transmission Company, )\n)\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 4-2020-008-CAO\nSECOND AMENDED CORRECTIVE ACTION ORDER\nPurpose and Background:\nOn September 18, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued a Corrective Action Order under the authority of 49 U.S.C. § 60112 to require Florida Gas\nTransmission Company (FGT or Respondent), which is operated by Energy Transfer Partners,\nLP,1 to take necessary corrective actions to protect the public, property, and the environment from\npotential hazards associated with a rupture that occurred on September 10, 2020, on FGT’s 12-\ninch Sanford Lateral natural gas pipeline in Sanford, Florida (Incident 1). On October 1, 2020,\nPHMSA issued an Amended Corrective Action Order to require Respondent take corrective\nactions due to Incident 1 and a second rupture that occurred on September 24, 2020, on its 18-inch\nFLMEA-21 line located in Lake Worth, Florida (Incident 2). FGT responded to the Amended\nCorrective Action Order on October 13, 2020, to request a hearing.\nPHMSA now issues this Second Amended Corrective Order (Second ACAO or Order), which\nmakes certain amendments to the Amended Corrective Action Order issued on October 1, 2020.\nThis Second ACAO supersedes both the September 18, 2020 Corrective Action Order and the\nOctober 1, 2020 Amended Corrective Action Order.\nIncident 1: In the early morning of September 10, 2020, FGT’s 12-inch Sanford Lateral ruptured\nand subsequently ignited. Prior to the rupture, at 12:47am EDT, the line was operating at 695\npounds per square inch (psig) between the Sanford station and the DeBary station. At 12:52 am\nEDT, the pressure reading at Sanford dropped to 409 psig and steadily decreased from that point.\nFGT’s Control Room detected the drop in pressure and had the valves upstream and downstream\n(upstream Valve 17-22U and downstream Valve 17-22ERB) of the failure site manually closed.\n1 FGT is an approximately 5,300-mile system that transports natural gas from South Texas to South Florida. FGT is\nowned by Florida Gas Transmission Company, LLC, a 100 percent owned subsidiary of Citrus Corp. Citrus Corp is\na 50/50 joint venture between Kinder Morgan, Inc. and Energy Transfer Partners, LP. FGT is operated by Energy\nTransfer. See https://www.kindermorgan.com/Operations/Natural-Gas/Index (last accessed September 14, 2020).\n\n\n\nCPF No. 4-2020-008-CAO\nPage 2\nAt 2:08 am EDT the line was shut in. The size of the burn area around the rupture site was\ndetermined to be 515 feet by 100 feet.\nReverse 911 notified 800 area homes and the local sheriff reported 20 homes were evacuated. The\nfire was extinguished, and evacuated residents were allowed to return home within hours of\nIncident 1. There were no reports of injuries or fatalities.\nIncident 2: At approximately 9:50 am EDT on September 24, 2020, FGT’s FLMEA-21 18-inch\npipeline ruptured and ejected multiple pieces of pipeline into the air. FGT’s gas control was\nnotified by a representative of the Lake Worth Drainage District that their pipeline was blowing\nnatural gas. FGT’s representative confirmed the leak on the 18-inch pipeline and the line was\nisolated between FGT’s two compressor stations (FGT CS 21 and CS 21.5). At the incident site,\nFGT found a 13-foot portion of ejected pipeline that landed approximately 400 feet downstream\nfrom the rupture site on the median of Lake Worth Road, and an additional 8.3-foot piece of ejected\npipeline was located approximately 200 feet east of the rupture site in a retaining pond behind a\nFlorida Turnpike toll booth. The outside lane of northbound traffic on the Florida Turnpike was\nclosed while FGT assessed the damage and initiated repairs. A mobile phone emergency alert was\nsent to those within a half-mile of the gas rupture notifying those persons to shelter-in-place or\nevacuate. An unknown number of people were evacuated from commercial businesses and a\nnearby elementary school. Evacuees were allowed to return to the area once the gas flow at the\nrupture site was secured.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS), initiated investigations\nof both Incident 1 and Incident 2. The preliminary findings of the agency’s ongoing investigations\nare as follows:\nPreliminary Findings for Incident 1:\n FGT initially reported Incident 1 to the National Response Center (NRC) at 2:24 am\nEDT on September 10, 2020 (NRC Report No. 1286952), indicating that Reverse 911\nnotified 800 area homes and that the local sheriff reported the evacuation of 20 homes\nwhen the 12-inch Sanford Lateral ruptured and ignited a fire. FGT provided an update\nto NRC after 48 hours that indicated an estimated release of 22 million cubic feet\n(MMCF) of natural gas and caused the evacuation of 20 homes. FGT also reported that\nall evacuees had returned to their homes.\n There were no injuries or fatalities associated with Incident 1; however, there is burn\ndamage to the surrounding vegetation measuring 515 feet by 100 feet. Additionally,\nthree overhead powerlines owned by Duke Energy, that shared the right-of-way\n(ROW), were damaged and knocked down.\n The rupture occurred near Mile Post 15 on the 12-inch Sanford Lateral (12-inch line or\nSanford Lateral) that feeds a Duke Energy Power Plant and several local distribution\ncompany (LDC) meter stations.\n\n\n\nCPF No. 4-2020-008-CAO\nPage 3\n The Sanford Lateral was constructed in 1959 with a 12-inch nominal diameter, 0.219-\ninch wall thickness, X-42 grade pipe that was manufactured by Youngstown Sheet and\nTube. The pipe has a low-frequency electric resistance welded (LF ERW) seam and\nis coated with a tape coating. The length of the 12-inch Sanford Lateral was measured\nat 15.9 miles by a 2019 in-line inspection (ILI) run. The Sanford Lateral is part of a\nlarger FGT unit with a total of 654 miles.\n The Sanford Lateral was manually shut in between upstream Valve 17-22U and\ndownstream Valve 17-22ERB. On the evening of September 10, 2020, FGT cut the\nfailed 12-inch pipeline and installed a pre-tested weld cap downstream from the lateral\nto Sanford FPU meter station. The weld cap location is approximately 0.5 miles\nupstream of rupture location and downstream of an FPU lateral to two customers\n(Sanford West and Sanford FPU) line, allowing a return to service of the remainder of\nthe line.\n Service has been restored to all 125 customers that initially lost service. The isolated\nsegment of pipeline, including the site of the rupture, is approximately 1.4 miles in\nlength and remains out of service.\n The Maximum Operating Pressure of the 12-inch Sanford Lateral is 713 psig. The\noperating pressure at the time of the rupture was 695 psig. The portion of the Sanford\nLateral that resumed operations is currently operating at 344 psig, which is fifty percent\n(50%) of operating pressure at the time of rupture. This pressure restriction was put\ninto place by FGT.\n The operator reported that it performed ILI runs of the Sanford Lateral in 2014 and\n2019. ILI correlation data from these runs show corrosion growth rates as high as 17\nthousandths of an inch per year. The 2019 ILI run had a large amount of corrosion\nindications in the vicinity of rupture, many over forty percent (40%).\n Most of the pipeline ROW appears to be located in swamp areas with heavy vegetation\nalong its borders, making the 12-inch line more susceptible to active external corrosion\nthan other locations. The line also reportedly has river weights in the vicinity of the\nrupture, and throughout the entire area where high corrosion rates are present.\n Aerial mapping and alignment sheets show a mix of sparsely populated swamp and\nresidential and commercial properties in close proximity to ROW.\n There have been no previous reportable incidents on the Sanford Lateral. FGT reports\nthat a 2012 rupture occurred in Melbourne, Florida and a 2014 rupture occurred in Port\nSt. John, Florida. Both were on different pipelines in the unit that includes the Sanford\nLateral. The 2012 rupture involved 20-inch 1959 vintage Youngstown Sheet and Tube\nLF ERW pipe and was classified as original manufacturing related (not weld). The\n2014 rupture involved an 8-inch 1962 vintage LF ERW pipe manufactured by Lonestar,\nand was also classified original manufacturing related (not weld).\n\n\n\nCPF No. 4-2020-008-CAO\nPage 4\n Pre-1970 LF ERW pipe has been the focus of many studies and reviews. A final report\nTTO Number 5, Integrity Management Program Delivery Order DTRS56-02-D-70036,\nIntegrity Management Program regarding Low Frequency ERW and Lap Welded\nLongitudinal Seam Evaluation (Revision 3) was prepared by Michael Baker in\nassociation with Kiefner and Associates, Inc., CorrMet Engineering Services, PC in\nApril 2004.2 The report was written to support the importance of operators correctly\nselecting integrity assessment methods capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n PHMSA has issued Advisory Bulletins on the safety risks of Low-Frequency Welded\nERW and Flash-welded Pipe manufactured prior to 1970. It also issued Alert Notice,\nALN-88-01, in January 1988, advising owners and operators of natural gas and\nhazardous liquids pipelines to consider the threat from ERW pipe manufactured prior\nto 1970. The operators were advised to determine whether their pipelines were\nsusceptible to ERW seam failures and address the potential impact on pipeline\nintegrity.\nPreliminary Findings for Incident 2:\n FGT initially reported Incident 2 to the NRC at 10:53 am EDT on September 24, 2020\n(NRC Report No. 1288141), indicating that a rupture, with no fire, occurred on FGT’s\n18-inch FLMEA-21 pipeline. FGT provided an update to NRC (NRC Report No.\n1288281) after 48 hours that indicated an estimated release of 12 MMCF of natural gas.\nThere were no injuries or fatalities associated with Incident 2.\n The rupture occurred approximately 350 feet north of the intersection of the Florida\nTurnpike exit ramp and Lake Worth Road in Lake Worth, Florida. The rupture location\nis about six miles south of FGT’s upstream compressor station, and 24 miles north of\nFGT’s downstream compressor station.\n The FLMEA-21 pipeline was constructed in 1959 with an 18-inch nominal diameter,\n0.25-inch wall thickness, X-52 grade pipe that was manufactured by Youngstown Sheet\nand Tube. The pipe has an LF ERW seam and is coated with cold applied tape. The\nlength of the FLMEA-21 pipeline is 67.04 miles.\n The FLMEA-21 pipeline supplies gas to power plants, industrial facilities, and LDCs\nin South Florida. The 18-inch FLMEA-21 pipeline shares the ROW with FGT’s 24-\ninch, FLMEB-21 pipeline, which runs parallel to the FLMEA-21 pipeline and is located\napproximately 20 feet away. The FLMEB-21 pipeline experienced no apparent\ncollateral damage due to Incident 2.\n The FLMEA-21 pipeline is currently shut in between FGT’s Main Line Valve (MLV)\n20-3 and MLV 20-4, approximately 15 miles. The segment is shut in and isolated from\n2 See https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/technical-resources/pipeline/hazardous-liquid-\nintegrity-management/64376/tto5lowfrequencyerwfinalreportrev3april2004.pdf (last accessed September 14, 2020).\n\n\n\nCPF No. 4-2020-008-CAO\nPage 5\nthe FLMEB-21 mainline from CS 21 (MP 838.5) to MLV 20-5R (MP 871.8). The\nsegment continues to remain out of service.\n The Maximum Operating Pressure of the FLMEA-21 is 866 psig. The operating\npressure at the time of the rupture was 846 psig.\n In 2017, FGT performed an ILI of the FLMEA-21 pipeline with no actionable\nindications of anomalies reported within the area near the Florida Turnpike exit ramp\nand Lake Worth Blvd.\n Much of FGT’s FLMEA-21 pipeline shares the ROW with FGT’s FLMEB-21 pipeline\nand the Florida Turnpike.\n Aerial mapping shows heavily populated and travelled area in the vicinity of the\npipeline. The pipeline is parallel and in close proximity (4 to 5 feet) from a retaining\nwall for the Florida Turnpike. The retaining wall was severely damaged as a result of\nthis incident.\n There has been one reportable incident on the FLMEA-21 pipeline since 2012 that was\nattributed to Stress Corrosion Cracking (SCC). The reportable incident was a leak on\nthe pipeline that occurred in December 2012 in Lake Worth, Florida approximately\n400-feet north of the rupture site for Incident 2. In addition, FGT experienced two in-\nservice incidents on pre-1970 LF-ERW pipe manufactured by Youngstown Sheet and\nTube. One involving SCC occurred in 2009 on the FLMEA-20 18-inch mainline and\nresulted in Corrective Action Order CPF No. 2-2009-1002H. The second involved a\nhook crack and hard spot (not SCC) and occurred in 2012 on the FLMEA-18 20-inch\nmainline and resulted in Corrective Action Order CPF No. 2-2012-1005H.\n As discussed in the Preliminary Findings for Incident 1, pre-1970 LF ERW pipe has\nbeen the focus of many studies and reviews, including those reports cited above.\nPHMSA has also issued notices, including Advisory Bulletins and Alert Notices, on\nthe safety risks of LF ERW and Flash-welded Pipe manufactured prior to 1970, as well\nas advising operators to determine whether their pipelines were susceptible to ERW\nseam failures and address the potential impact on pipeline integrity.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and, if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\n\n\n\nCPF No. 4-2020-008-CAO\nPage 6\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling\nthe equipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material are transported, and\nthe pressure required for transporting the material; (3) the aspects of the area in which the\npipeline facility is located, including climatic and geologic conditions and soil characteristics;\n(4) the proximity of the area in which the pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) other factors PHMSA may consider appropriate.\nAfter evaluating the foregoing preliminary findings of fact, I find that the continued operation of\nthe Affected Pipelines, as defined below, without corrective measures is or would be hazardous to\nlife, property and the environment. Given that both Incident 1 and Incident 2 involved pre-1970\nLF ERW pipe, and that there is an increased likelihood that there are other locations along the\npipelines subject to the same operational cycles and fatigue, there is a heightened risk for imminent\nfailures along the pipe. Furthermore, given that the area of the rupture for Incident 1 appears to\nbe at a low point in the line which is located in a swamp, there is an increased possibility of the\npresence of moisture that may increase the likelihood of increased external corrosion. In fact,\nrecent ILI data of the Sanford Lateral showed indications of increased corrosion in the vicinity of\nthe rupture. As for Incident 2, the location of the pipeline and the rupture site is in close proximity\nto populated areas, including the Florida Turnpike. Therefore, after considering the age of the\npipelines, the manufacturing methods, the hazardous nature of the products being transported, the\npressure required for transporting the materials, and the attributes of the ROWs for each pipeline,\nas well as the uncertainties as to the causes of the incidents and the ongoing investigation, I find\nthat a failure to issue this Order expeditiously to require immediate corrective action would result\nin likely serious harm to life, property, and the environment.\nAccordingly, this Second ACAO mandating immediate corrective action is issued without prior\nnotice and opportunity for a hearing. The terms and conditions of this Order are effective upon\nreceipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Southwest Region, PHMSA (Director). If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nDefinitions for Incident 1:\n\n\n\nCPF No. 4-2020-008-CAO\nPage 7\nIncident 1 Affected Pipeline3 – Means the entire 15.9 miles of the 12-inch Sanford Lateral\noperated by Florida Gas Transmission that transports natural gas from FGT’s 26-inch\nmainline to the Sanford West and Sanford FPU meter station.\nIncident 1 Isolated Segment – Means the portion of the Incident 1 Affected Pipeline\nbetween the weld cap location (approximately MP 14.8) and Valve 17-22ERB that remains\nout of service.\nDefinitions for Incident 2:\nIncident 2 Affected Pipeline – Means approximately 124.6 miles of pre-1970 LF ERW\npipe contained in the 18-inch FLMEA pipeline system.\nIncident 2 Isolated Segment– Means the approximate 15 miles of the 18-inch FLMEA-21\npipeline (i.e. Incident 2 Affected Pipeline) between FGT’s MLV 20-3 and FGT’s MLV 20-\n4.\nPursuant to 49 U.S.C. 60112, I hereby order FGT to immediately take the following corrective\nactions:\n1. Shutdown of the Isolated Segments. The Incident 1 Isolated Segment and Incident 2\nIsolated Segment (collectively Isolated Segments) are currently out of service and must\nremain shut down until their restart in accordance with this Order.\n2. Operating Pressure Restriction of the Affected Pipelines. FGT must maintain a fifty\npercent (50%) pressure reduction in the actual operating pressure along the entire length of\nthe Incident 1 Affected Pipeline such that the operating pressure along the pipeline will not\nexceed fifty percent (50%) of the actual operating pressure in effect immediately prior to\nthe failure on September 10, 2020. FGT must initiate and maintain a twenty percent (20%)\npressure reduction in the actual operating pressure along the entire length of the Incident 2\nAffected Pipeline such that the operating pressure along the pipeline will not exceed eighty\npercent (80%) of the actual operating pressure in effect immediately prior to the failure on\nSeptember 24, 2020.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipelines to their pre-failure operating pressure is obtained\nfrom the Director.\nb. FGT must provide the Director by October 2, 2020 for Incident 1 and October 15,\n2020 for Incident 2, the actual operating pressures of each compressor station and\neach main line pressure regulating station on the Incident 1 Affected Pipeline and\nIncident 2 Affected Pipeline (collectively Affected Pipelines) at the time of failure\nand the reduced pressure restriction set-points at these same locations.\n3 The Corrective Action Order issued on September 18, 2020, referred to this pipeline as the “Affected Segment.”\nTo avoid confusion with the “Isolated Segment,” the pipeline is hereafter referred to as the “Incident 1 Affected\nPipeline.”\n\n\n\nCPF No. 4-2020-008-CAO\nPage 8\nc. This pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to\nbe adjusted accordingly.\nd. When determining the pressure restriction set-points, FGT must take into account\nany ILI features or anomalies present in the Affected Pipelines to provide for\ncontinued safe operation while further corrective actions are completed.\ne. FGT must review the pressure restriction monthly by analyzing the operating\npressure data. FGT must take into account any ILI features or anomalies present in\nthe Affected Pipelines and immediately reduce the operating pressure to maintain\nthe safe operations of the Affected Pipelines, if warranted by the monthly review.\n3. Repair/Restart Plan. Prior to resuming operation of the Isolated Segments, FGT must\ndevelop and submit a written Repair/Restart Plan for each of the Isolated Segments to the\nDirector for approval.\na. The Director may approve the Repair/Restart Plan incrementally without approving\nthe entire plan, but the Isolated Segments cannot resume operation until the\nRepair/Restart Plan is approved in its entirety.\nb. Once approved by the Director, the Repair/Restart Plan will be incorporated by\nreference into this Order.\nc. The Repair/Restart Plan must provide plans and procedures for the repair of the\nisolated segment of the pipelines.\nd. The Repair/Restart Plan must provide for adequate patrolling of the Isolated\nSegment during the restart process and must include incremental pressure increases\nduring start up, with each increment to be held for at least two hours.\ne. The Repair/Restart Plan must include sufficient surveillance of the pipeline during\neach pressure increment to ensure that no leaks are present when operation of the\nline resumes.\nf. The Repair/Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\ng. The Repair/Restart Plan must provide for a review of the Isolated Segments for\nconditions similar to those of the failure, including a review of construction,\noperating and maintenance and integrity management records such as ILI results,\nhydrostatic pressure tests, root cause failure analysis of prior failures, aerial and\nground patrols, corrosion, cathodic protection, excavations and pipe\nreplacements. FGT must address any findings that require remedial measures to be\nimplemented prior to restart.\nh. The Repair/Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\n\n\n\nCPF No. 4-2020-008-CAO\nPage 9\nmodifications are incorporated into FGT’s operations and maintenance procedures\n4. 5. 6. 7. manual.\ni. The Repair/Restart Plan must provide for hydrostatic pressure testing of the Isolated\nSegments.\nReturn to Service. After the Director approves the Repair/Restart Plan, FGT may return\nthe Isolated Segments to service, but the operating pressures must not exceed the pressure\nrestriction in accordance with Item 2 above.\nRemoval of Pressure Restriction. The Director may allow the removal or modification of\nthe pressure restriction in Item 2 above upon a written request from FGT demonstrating\nthat restoring the pipeline to its pre-failure operating pressure is justified based on a reliable\nengineering analysis showing that the pressure increase is safe considering all known\ndefects, anomalies, and operating parameters of the pipeline.\na. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from FGT demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on the known or suspected failure cause and provision\nof evidence that preventative and mitigative actions taken by the operator provide\nfor the safe operation of the Affected Pipelines during the temporary removal or\nmodification of the pressure restriction. Appeals to determinations of the Director\nin this regard will be decided by the Associate Administrator for Pipeline Safety.\nInstrumented Leakage Survey. By October 18, 2020 for Incident 1, and October 31, 2020\nfor Incident 2, FGT must perform an aerial or ground instrumented leakage survey of the\nAffected Pipelines. FGT must investigate all leak indications and remedy all leaks\ndiscovered. FGT must submit documentation of this survey to the Director by November\n2, 2020 for Incident 1, and within 45 calendar days of receipt of this Order for Incident 2.\nRecords Verification. As recommended in PHMSA Advisory Bulletin 2012-06, FGT must\nverify the records for the Affected Pipelines to confirm the maximum allowable operating\npressure. FGT must submit documentation of this record verification to the Director by\nNovember 2, 2020 for Incident 1, and within 45 calendar days of receipt of this Order for\nIncident 2.\n8. Review of Prior Inline Inspection Results. By October 18, 2020 for Incident 1, and\nOctober 31, 2020 for Incident 2, FGT with the assistance of an outside third party, approved\nby PHMSA, must conduct a review of any previous ILI results of the Affected Pipelines to\nre-evaluate all ILI results from the past five calendar years, include a review of the ILI\nvendors' raw data and analysis, and determine whether any features were present in the\nfailed pipe joint and any other pipe removed. Also, determine if any features with similar\ncharacteristics are present elsewhere on the Affected Pipelines. FGT must submit\ndocumentation of this ILI review to the Director by November 2, 2020 for Incident 1, and\nNovember 15, 2020 for Incident 2.\n\n\n\nCPF No. 4-2020-008-CAO\nPage 10\na. List all ILI tool runs, tool types, and the calendar years of the tool runs. Provide ILI\nresults data, as requested, to PHMSA.\nb. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present in the failed joint and/or other pipe removed.\nc. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Pipelines.\nd. Explain the process used to review the ILI results and the results of the reevaluation.\n9. Mechanical and Metallurgical Testing. By November 2, 2020 for Incident 1, and\nNovember 15, 2020 for Incident 2, FGT must submit for approval a plan for mechanical\nand metallurgical testing and failure analysis of the failed pipe, including an analysis of\nsoil samples and any foreign materials, by an approved independent third-party laboratory.\nComplete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsections and other evidence from the failure sites.\nb. Within 10 calendar days of receipt of this Order for Incident 2, FGT must develop\nand submit the testing protocol and the proposed testing laboratory to the Director\nfor prior approval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to FGT.\n10. Root Cause Failure Analysis. By December 17, 2020 for Incident 1, and December 30,\n2020 for Incident 2, FGT must complete a root cause failure analysis (RCFA) and submit\na final report of this RCFA to the Director. The RCFAs must be supplemented or\nfacilitated by an independent third-party acceptable to the Director and must document the\ndecision-making process and all factors contributing to the failure. The final reports must\ninclude findings and any lessons learned and whether the findings and any lessons learned\nare applicable to other locations within FGT’s pipeline system.\n11. Remedial Work Plan.\na. By December 17, 2020 for Incident 1, and December 30, 2020 for Incident 2, FGT\nmust submit Remedial Work Plan(s) (RWP) to the Director for approval. The\nDirector may approve the RWPs incrementally without approving the entire RWP.\nFGT may also submit one RWP for both Incidents by December 17, 2020.\nb. Once approved by the Director, the RWP(s) will be incorporated by reference into\nthis Order, and FGT must implement the RWP(s) as it is approved by the Director,\nincluding any revisions to the plan.\n\n\n\nCPF No. 4-2020-008-CAO\nPage 11\nc. The RWP(s) must specify the tests, inspections, assessments, evaluations, and\nremedial measures FGT will use to verify the integrity of the Affected Pipelines. It\nmust address all known or suspected factors and causes of the September 10, 2020\nand September 24, 2020 failures. FGT should consider both the risk of another\nfailure and the consequence of another failure to develop a prioritized schedule for\nRWP related work along the Affected Pipelines.\nd. The RWP must include a procedure or process to:\ni. Identify pipe in the Affected Pipelines and other pipelines in the FGT\noperating areas with characteristics similar to the contributing factors\nidentified for the September 10, 2020 and September 24, 2020 failures.\nii. Gather all data necessary to review the failure history (in service and\npressure test failures) of the Affected Pipelines and to prepare a written\nreport containing all the available information such as the locations, dates,\nand causes of leaks and failures.\niii. Integrate the results of the metallurgical testing, root cause failure analysis,\nand other corrective actions required by this Order with all relevant pre-\nexisting operational and assessment data for the Affected Pipelines. Pre-\nexisting operational data includes, but is not limited to, manufacturing and\nconstruction, operations, maintenance, testing, repairs, prior metallurgical\nanalyses, and any third-party consultation information. Pre-existing\nassessment data includes, but is not limited to, ILI tool runs, hydrostatic\npressure testing, direct assessments, close interval surveys, and direct or\nalternating current voltage gradient surveys.\niv. Determine if conditions similar to those contributing to the failures on\nSeptember 10, 2020 and September 24, 2020 are likely to exist elsewhere\non FGT’s operational pipelines.\nv. Conduct additional field tests, inspections, assessments, and/or evaluations\nnecessary to determine whether, and to what extent, the conditions\nassociated with the failures on September 10, 2020 and September 24, 2020,\nand other failures from the failure history in Item 11(d)(ii) above or any\nother integrity threats are present elsewhere on the Affected Pipelines or\nother systems operated by FGT. At a minimum, this process must consider\nall failure causes and specify the use of one or more of the following:\n1. ILI tools that are technically appropriate for assessing the pipeline\nsystem based on the cause of failures on September 10, 2020 and\nSeptember 24, 2020, and that can reliably detect and identify\nanomalies;\n2. Hydrostatic pressure testing;\n3. Close-interval surveys;\n\n\n\ne. f. CPF No. 4-2020-008-CAO\nPage 12\n4. Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities,\noverhead 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\nfor the failure causes.\nFGT may use the results of previous tests, inspections, assessments, and\nevaluations if approved by the Director, provided the results of the tests,\ninspections, assessments, and evaluations are analyzed with regard to the\nfactors known or suspected to have caused the September 10, 2020 and\nSeptember 24, 2020 failures.\nvi. Describe the inspection and repair criteria FGT will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded\nand a schedule for repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipelines,\ndescribe the methods FGT will use to repair, replace, or take other\ncorrective measures to remediate the conditions associated with the pipeline\nfailures on September 10, 2020 and September 24, 2020, and to address\nother known integrity threats along the Affected Pipelines. The repair,\nreplacement, or other corrective measures must meet the criteria specified\nin Item 11(d)(vi) above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipelines\nconsidering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to the Order.\nThe RWP must include a schedule for completion.\nFGT must revise the RWP(s) as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of\nactions undertaken pursuant to this Order, and to incorporate any modifications\nrequired by the Director.\ni. Submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\n\n\n\nCPF No. 4-2020-008-CAO\nPage 13\niii. Any and all revisions to the RWP(s) after it has been approved and\nincorporated by reference into this Order will be fully described and\ndocumented in the CAO Documentation Report (CDR).\n12. CAO Documentation Report. When FGT has concluded all the items in this Order, it will\nsubmit the final CDR in its entirety to the Director. This will allow the Director to complete\na thorough review of all actions taken by FGT with regards to this Order prior to approving\nthe closure of this Order. The intent is for the CDR to summarize all activities and\ndocumentation associated with this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire\nCDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nc. The CDR must include, but is not necessarily limited to, the following elements:\ni. Table of Contents;\nii. Summary of the pipeline failures of September 10, 2020 and September 24,\n2020, and the response acti","truncated":true,"body_characters":121767}