# CYPRESS INTERSTATE PIPELINE LLC — Corrective Action Order

- **operation:** document
- **citation:** CPF 520055020H
- **title:** CYPRESS INTERSTATE PIPELINE LLC — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2005-04-21
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520055020h
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520055020H
**body:**

Corrective Action Order involving CYPRESS INTERSTATE PIPELINE LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2005-04-21 and is reported as closed as of 2010-03-17. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520055020H_corrective action order_04212005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520055020H/520055020H_corrective%20action%20order_04212005.pdf

520055020h_corrective action order_04212005_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520055020H/520055020h_corrective%20action%20order_04212005_text.pdf

cpf_520055020H.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520055020H/cpf_520055020H.pdf

520055020h_corrective action order_04212005_text.pdf

U, S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
400 Seventh Street, S W
Washington, D. C 20590
APR 2 t I
Mr. Richard D. Kinder
Chairman, President, and CEO
Kinder Morgan Energy Partners, L. P.
500 Dallas Street, Suite 1000
Houston, TX 77002
Re: CPF No. 5-2005-5020H
Dear Mr. Kinder:
Enclosed is a Corrective Action Order issued by the Associate Administrator for Pipehne
Safety in the above-referenced case. It requires you to take certain corrective actions, mcluding a
pressure reduction, with respect to yoiu LS-11/12/13 Rocklin, CA to Reno, NV hazardous liquid
pipehne. Service is being made by certified mail and facsimile. Your receipt of this Corrective
Action Order constitutes service of that document under 49 C. F. R. ) 190. 5. The terms and
conditions of this Corrective Action Order are effective upon receipt.
Sincerely,
~es Reynolds
Pipehne Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Mr. Jerry Milhorn, Vice President, Operations
Mr. Thomas A. Bannigan, President, Products Pipehnes
Mr. Chris Hoidal, Regional Director, Western Region, OPS
VIA CERTIFIED MAIL RETURN RECEIPT RE UKSTED AND TKLKCOPY



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON) DC 20590
In the Matter of
)
)
Kinder Morgan Energy Partners, L. P.
, )
)
Respondent.
)
CPF No. 5-2005-5020H
CORRECTIVE ACTION ORDER
Pur ose and Back round
This Corrective Action Order is being issued, under authority of 49 U. S. C. $ 60112, to require
Kinder Morgan Energy Partners, L. P. (Respondent) to take the necessary corrective action to protect
the public, property, and the environment from potential hazards associated with a failure involving
Respondent's LS-11/12/13 Rockhn, CA to Reno, NV (Rocklin-Reno) hazardous liquid pipeline
At an unknown date and time, a failure occurred on Respondent's Rocklin-Reno line in Placer
County, CA resulting in the release of gasoline. The cause of failure has been preliminarily
attributed to damage from wrinkle bends made dming construction of the pipeline. Dents and pipe
associated with the wrinkle bends indicate stress corrosion cracking (SCC), disbonded coating, and
general corrosion. Pursuant to 49 U. S, C. ) 60117, the Western Region, Office of Pipehne Safety
(OPS) initiated an investigation of the incident. The California State Fire Marshal (CASFM), which
has authority to act as an mterstate agent for OPS, responded to the failure and continues
participating in the mvestigation along with OPS inspectors.
Preliminar Findin s
At an unknown date and time, Respondent's Rockhn-Reno hne experienced a failure m Placer
County, CA resultmg m the release of an unknown quantity of refined petroleum products in
a snow-packed area of the Sierra Mountains approximately three miles west of Truckee, CA.
The failure site is located approximately at Mile Post 75. 95.
~ Respondent became aware that the Rocklin-Reno line may have experienced a release at or
around 11:15 A. M. PST on April 1, 2005, after a skier reported the smell of gasoline in the
vicmity of the failure to authorities. Respondent shut down the Rocklin-Reno hne and reported
the possible failure to the National Response Center at 12:48 P. M. PST. At approximately 6:20



P. M. PST, Respondent de-pressured and emptied the Rockhn-Reno hne by draining it downhill
toward the pipehne terminal in Reno, NV.
Attempting to locate the source of the leak, Respondent began excavation activities in the
vicinity of the suspected failure on the morning of April 2. Snow over the pipeline of depths
exceeding twenty feet and blizzard conditions hampered access to the site and excavation
activities. On April 4, at approximately 6 P. M. PST, Respondent identified and confirmed the
location of the failure at Mile Post 75. 95 after injecting a gas tracer into the line. A boulder was
located over the pipeline in the immediate area of the identified failure location.
On April 5, Respondent removed and replaced a 14. 5-foot section of pipe containing the failure
site under the observation of the CASFM. Visual inspection of the removed pipe revealed
multiple dents ahgned in two axial rows on the top portion of the pipe. A crack found in one
of the dents appeared to be the likely source of the leak.
No fires, injuries, or fatalities were reported in connection with the incident. Refined products
were released into headwater streams of Donner Creek, an area designated by pipeline safety
regulations as unusually sensitive to environmental damage because of its connection to
drinking water resources and presence of certain ecological communities. Respondent used
booms to contain the spread of product into Donner Creek.
Respondent's Rocklin-Reno line transports refined petroleum products including diesel fuel,
~et fuel, and gasohne to tank farms, wholesalers, an airport, and defense facilities. Its total
length is approximately 120. 92 miles. Portions o f the pipehne traverse highways and are routed
though or near wildhfe habitats, drinking water resources, populated areas and bodies of water.
Respondent sent the failed portion of the pipeline to Exponent Failure Analysis in Menlo Park,
CA for metallurgical examination. Chain of custody of the pipe and the metallurgical
examination were observed by CASFM and OPS inspectors. Preliminarily, the cause of failure
has been attributed to damage from wrinkle bends made during construction of the pipeline
Dents and pipe associated with the wrinkle bends indicate stress corrosion cracking (SCC),
disbonded coating, and general corrosion.
On October 8, 2003, OPS issued an advisory bulletin to owners and operators of hazardous
liquid and gas pipelines advising them to assess their pipelines for susceptibihty to SCC. The
advisory bulletin has been published in the Federal Register (58 Fed. Reg. 58166) and on the
OPS website at http: //ops. dot. gov. The advisory bulletin contains detailed instructions on
identifying and addressing the SCC threat.
~ The Rocklin-Reno pipeline contains pipe of varying diameter, wall thickness, grade, and
coating. The LS-12 portion of the Rockhn-Reno pipeline containing the failure site was
installed in 1957 and is constructed of 8. 625-inch nominal diameter, 0. 250-inch wall thickness,
X-46 grade, seamless pipe manufactured by National Tube. The Rockhn-Reno hne is
cathodically protected by impressed current.



The maximum operating pressure (MOP) of the Rocklin-Reno line is 1920 psig at the Cisco
Grove Pump Station, as estabhshed by hydostratic pressure test in 1957. At the time of
notification of the possibihty of failure, the pressure at the failure site is estimated to have been
375 psig.
Respondent performed internal inspections on the Rocklin-Reno line with deformation and
magnetic flux leakage in-line inspection tools in June 1997.
In March 1997, Respondent experienced a release approximately 800 feet from the current
failure site. The 1997 release was attnbuted to third party damage from the mstallation of fiber
optic utility lines.
Respondent resumed limited operation of the Rocklin-Reno line at approximately 4 P. M. PST
on Apnl 5, 2005 at a discharge pressure of approximately 1536 psig at its Cisco Grove Pump
Station (80'/o of MOP).
Determination of Necessi for Corrective Action Order and Ri ht to Hearin
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 heanng, requiring corrective action, which
may mclude the suspended or restncted use of a pipeline facility, physical inspection, testing, repair,
replacement, or other action as appropriate. The basis for making the determination that a pipeline
facihty is hazardous, requinng 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, provides for the issuance of a Corrective
Action Order without prior opportunity for notice and heanng upon a finding that failure to issue the
Order expeditiously will result in likely 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 evaluatmg the foregoing preliminary findings of fact, I find that the continued operation of
Respondent's Rockhn-Reno hazardous liquid pipeline without corrective measures would be
hazardous to life, property and the environment. Additionally, after considenng the age of the pipe,
the proximity of the pipeline to unusually sensitive area dnnking water and ecological resources and
populated areas, the combustible nature o f the products the pipeline transports, the pressure required
for transporting the material, prelimmary indications of SCC, general corrosion, and other damage
at the failure site, and the ongomg investigation to make a final determination as to the cause of the
failure, I find that a failure to expeditiously issue this Order requiring immediate corrective action
would hkely result in senous harm to hfe, 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.
Withm 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, delivered
personally, by mail or by telecopy at (202) 366-4566. The hearing will be held in Lakewood, CO
or Washington, DC on a date that is mutually convenient to OPS and Respondent.
After receiving and analyzing additional data in the course of this investigation, OPS 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, Responder t will be afforded notice and an opportunity for a hearing prior to
the imposition of any additional corrective measures.
Re nired Corrective Action
Pursuant to 49 U. S. C. $ 60112, I hereby order IQnder Morgan Energy Partners, L. P. to immediately
take the following corrective actions with respect to its Rockhn-Reno hazardous hquid pipeline:
1. Do not exceed 80 percent (80%) of the actual operating pressure in effect at the Cisco Grove
Pump Station just prior to the April 1, 2005 notification of possible failure. Specifically, the
discharge pressure is not to exceed 1536 psig at the Cisco Grove Pump Station. If the ongoing
investigation reveals that the operating pressure of 1536 psig cannot be sustained because of
safety concerns, the Director, Western Region, may require a pressure reduction based on the
actual operating pressure at the failure site just prior to the April 1, 2005 notification of possible
failure. This pressure restriction will remain in effect until written approval to increase the
pressure or return the pipeline to its pre-failure operating pressure is obtained from the Director,
Western Region, OPS.
2. Re-evaluate the data from the in-hne inspection tool runs performed in 1997, including
information obtained from the resulting excavations, for the purpose of determining whether
any anomalies were present that could have contributed to the failure and whether any other
anomalies of a similar magnitude are present elsewhere on the pipehne. Make the 1997 in-hne
inspection results available to OPS or its representative. Re-evaluation must occur within 14
days of receipt of this Order. Make timely repairs as required by the pipeline safety regulations
and in accordance with your approved repair procedures.
3. Within 45 days of receipt of this Order, perform confirmatory digs on a statistically significant
sample of locations (a minimum of 10 sites) to corroborate the data obtained from the
1997 in-line inspection tool run. Use criteria (e. g. , change in elevation, pipeline alignment,
locations of known geological instabihty) to ensure that locations with dents, wrinkles, ripples,
buckles, and other flaws are identified.



A. Evaluate excavated pipe sections for evidence of dents or wrinkles, corrosion, disbonded
coating, and any crack-hke features, including SCC.
B. Make timely repairs as required by the pipeline safety regulations and in accordance with
your approved repair procedures.
C. Provide field non-destructive testing results, including the correlation of predicted dent
depth from the 1997 in-line inspections and actual field measurements, to the Director,
Western Region, OPS.
4. Within 90 days of receipt of this Order, perform an in-line inspection of the Rocklin-Reno
pipeline with a deformation tool capable of characterizing dent geometry and depth through
direct mechamcal measurement. The tool must utilize sufficient sensors to calculate pipe wall
strain. Prior to performing the inline inspection and other actions required by this item, submit
the proposed action to the Director, Western Region, OPS, for approval.
A. Evaluate and remediate any anomalies identified as required by the pipehne safety
regulations and in accordance with your approved repair procedures.
B. Perform representative digs of anomalies identified to verify and assess the characteristics
found in accordance with Item 3C.
5 Submit all required information to: Director, Western Region, Office of Pipehne Safety, Golden
Hills Center, Suite A-250, 12600 West Colfax Avenue, Lakewood, CO 80215-3736.
6. The Director, Western Region, OPS may grant an extension of time for comphance with any
of the terms of this Order for good cause. A request for an extension must be in writing.
The corrective actions required by this Corrective Action Order are in addition to and do not waive
any requirements that apply to the pipeline under 49 C. F. R. Part 195, including the integrity
management program regulations.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipehne
Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Order may result in the assessment of civil penalties of not more than
$100, 000 per day and in referral to the Attorney General for appropriate rehef in United States
Distri ourt.
S ceyGer rd
Ask ci e Administrator
for ipehne Safety
Date ssued
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