{"operation":"document","citation":"CPF 520071002M","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-03-05","effective_on":null,"summary":"CLOSED notice of amendment citing 192.911(k), 192.935(a), 192.937(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520071002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520071002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520071002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520071002M","body":"Notice of Amendment involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.911(k),  192.935(a),  192.937(b). The case was opened on 2007-03-05 and is reported as closed as of 2007-06-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n5-2007-1002M Kinder Morgan Extension Letter 4-10-07.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071002M/5-2007-1002M%20Kinder%20Morgan%20Extension%20Letter%204-10-07.pdf\n\n5-2007-1002m kinder morgan extension letter 4-10-07_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071002M/5-2007-1002m%20kinder%20morgan%20extension%20letter%204-10-07_text.pdf\n\n520071002M_notice letter_03052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071002M/520071002M_notice%20letter_03052007.pdf\n\n520071002m_notice letter_03052007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071002M/520071002m_notice%20letter_03052007_text.pdf\n\n520071002M_operator_response_to_notice_05302007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520071002M/520071002M_operator_response_to_notice_05302007.pdf\n\n520071002m_notice letter_03052007_text.pdf\n\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\nEÃ7 TO COMpL[~NCE REGJSVR40 W Dakota A\"e, Su'te 110\n/Lakewood, CO 80228\nHardcopy Electromc lly\n8 of Copies&/ Date\nNOTICE OF AMKNDMKNT\nCERTIFIED MAIL - RETURN RECEIPT RK UESTKD\nMarch 5, 2007\nMr. Dwayne Burton\nVP Engineering, Operations and Project Management\nKinder Morgan, Inc.\n500 Dallas Street, Suite 1000\nHouston, TX 77002\nCPF 5-2007-1002M\nDear Mr. Burton:\nOn August 14-18 and August 28 — September 1, 2006, a representative of the Pipeline and\nHazardous Materials Safety Administration {PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Kinder Morgan, Inc. {KMI) procedures for the Integrity Management\nProgram in Lakewood, Colorado.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nKMI's. plan or procedure and are described below:\nPreventive and Mitigative Measures\n$192. 911 What are the elements of an integrity management program?\n(h)Provisions meeting the requirements of $192. 935 for adding preventive and\nmitigative measures to protect the high consequence area.\n$192. 935 What additional preventive and mitigative measures must an operator\ntake'?\n(a) General requirements. An operator must take additional measures beyond those\nalready required by Part 192 to prevent a pipeline failure and to mitigate the\nconsequences of a pipeline failure in a high consequence area. An operator must base\nthe additional measures on the threats the operator has identified to each pipeline\nsegment. (See g 192. 917) An operator must conduct, in accordance with one of the\nrisk assessment approaches in ASMK/ANSI 831. 8S (ibr, see g 192. 7), section 5, a risk\n\n\n\nanalysis of its pipeline to identify additional measures to protect the high\nconsequence area and enhance public safety. Such additional measures include, but\nare not limited to, installing Automatic Shut-off Valves or Remote Control Valves,\ninstalling computerized monitoring and leak detection systems, replacing pipe\nsegments with pipe of heavier wall thickness, providing additional training to\npersonnel on response procedures, conducting drills with local emergency\nresponders and implementing additional inspection and maintenance programs.\n$192. 937 (b) Evaluation. An operator must conduct a periodic evaluation as\nfrequently as needed to assure the integrity of each covered segment. The periodic\nevaluation must be based on a data integration and risk assessment of the entire\npipeline as specified in g 192. 917. For plastic transmission pipelines, the periodic\nevaluation is based on the threat analysis specified in g 192. 917(d) For all other\ntransmission pipelines, the evaluation must consider the past and present integrity\nassessment results, data integration and risk assessment information (g 192. 917), and\ndecisions about remediation {g 192. 933) and additional preventive and mitigative\nactions (g 192. 935). An operator must use the results from this evaluation to identify\nthe threats specific to each covered segment and the risk represented by these\nthreats.\n~ Item 1A: $192. 911(h) and $192. 937(b)\nThe KMI procedure for establishing when continual evaluations are needed do not\nexplicitly require that a reevaluation be conducted in response to significant leaks,\nfailures, or incidents.\n~ Item 1B: $192. 911(h) and $192. 935(a)\nIMP I 0070 provides a framework describing requirements for the P&M Measures\nprogram. However, KMI has not defined the detailed process steps used for\nidentifying additional measures based on identified threats to each pipeline\nsegment and the risk analysis.\nManagement of Change\n$192. 911 What are the elements of an integrity management program?\n(k) A management of change process as outlined in ASME/ANSI B31. 8S, section 11.\n$192. 909(b) Notification. An operator must notify OPS, in accordance with $192. 949,\nof any change to the program that may substantially affect the program's\nimplementation or may significantly modify the program or schedule for carrying\nout the program elements. An operator must also notify a State or local pipeline\nsafety authority when either a covered segment is located in a State where OPS has\nan interstate agent agreement, or an intrastate covered segment is regulated by that\nState. An operator must provide the notification within 30 days after adopting this\ntype of change into its program.\n\n\n\nASMK B31. 8S-2001, Section 11\n(a) Formal management of change procedures shall be developed in order to\nidentify and consider the impact of changes to pipeline systems and their\nintegrity. These procedures should be flexible enough to accommodate both\nmajor and minor changes, and must be understood by the personnel that use\nthem. Management of change shall address technical, physical, procedural and\norganizational changes to the system whether permanent or temporary. The\nprocess should incorporate planning for each of these situations and consider the\nunique circumstances of each.\nA management of change process includes the following:\n(1) Reason for change\n(2) Authority for approving changes\n{3) Analysis of implications\n(4) Acquisition of required work permits\n(5) Documentation\n(6) Communication of change to affected parties\n{7) Time limitations\n(8) Qualification of staff\n(b) The operator shall recognize that system changes can require changes in the\nintegrity management program and conversely, results from the program can\ncause system changes. The following are examples that are gas pipeline specific\nbut are by no means all inclusive.\n~ Item 2A: $192. 911{k) and ASMK B31. 8S-2001, Section 11{a)\nKMICD Lander Hudson Lateral was listed as an HCA in the 2004 BAP. This\nHCA was removed from the BAP in the 12/17/2005 BAP. KMI did not document\nthe reason for change, authority for approving change, analysis of implications, or\nthe communication of the change to affected parties.\nRes onse 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 Campliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U. S. C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days of receipt of\nthis Notice, this constitutes a waiver of your right to contest the allegations in this Notice and\nauthorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue a Final Order.\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the madequacies (49\nC. 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.\nIn correspondence concerning this matter, please refer to CPF 5-2007-1002M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincer\ns Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Comp1iance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 J. Gilliam (¹116S69)","truncated":false,"body_characters":9248}