SFPP, LP — Notice of Amendment

party submissionOfficial PDF520085043M_operator response_11192008.pdf#

520085043m_notice of amendment_10152008_text.pdf, page 1Official PDFU, S DePGftment of Tf GrfsPoftGtlofl Pmpellmne and Hazardous Maffermalls Safety Adminttslfratmon 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 NOTICE OF AMKNDMKXT October 15, 2008 Mr Ron McClain Vice President, Engineering/Operation launder Morgan Energy Partners, L P 500 Dallas Street Houston, TX 77002 CPF 5-2008-5043M Dear Mr McClain On May 12-16, 2008, representatives of the Pipehne and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Kinder Morgan's procedures for Operations and Maintenance (OkM) Procedural Manuals in Fairfield, Cahfornia On the basis of the inspection, PHMSA identified apparent inadequacies found within launder Morgan's plans or procedures They are (a) Welding must be performed by a quahfied welder in accordance with welding procedures quahfied under Section 5 of APl 1104 or Section IX of the ASMK Boiler and Pressure Vessel Code (ibr, see g 195. 3) . The qualflty of the test welds used to quahfy the welding procedure shall be deternuned by destructive testing.#

520085043m_notice of amendment_10152008_text.pdf, page 2Kinder Morgan does not specify in its OKM manuals what section and edition of API 1104 needs to be used to quahfy its Welding Procedures Kinder Morgan's OkM Procedural Manuals only refer to "apphcable section of API 1104" or reference the "CFR 49 Part 195 Referenced Edition" The welding procedures did not exphcitly reference the appropriate industry standard that will be used to qualify their weldmg procedures Kinder Morgan does not specify in its OAM manuals what section and edition of API 1104 need to be used to quahfy its welders Kinder Morgan's Operations and Maintenance Manuals only require its welders to be quahfied in conformance with 49 CFR Part 195, and the latest DOT-approved edition of API 1104 KM's OkM manual must explicitly reference the appropriate industry standard to be used to quahfy its welders Kinder Morgan does not specify in its OAM manuals what section and edition of API 1104 need to be used to inspect its welds IQnder Morgan's Operations and Maintenance states, "NDT testing shall conform, or exceed requirements of the 49 CFR Part 195 most recent edition and apphcable section of API 1104 most recent DOT approved edition" KM's OKM manual must exphcitly reference the industry standard to be used to inspect and accept their welds#

520085043m_notice of amendment_10152008_text.pdf, page 3Res onse 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 m response to this enforcement action is subject to being made pubhcly available If you beheve that any portion of your responsive material quahfies for confidential treatment under 5 U S C 552(b), along with the complete origmal document you must provide a second copy of the document with the portions you beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted information quahfies 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 Pipehne Safety to find facts as alleged in this Notice without fuither 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 [number of days] 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. In correspondence concerning this matter, please refer to CPF 5-2008-5043M and, for each document you submit, please provide a copy in electronic format whenever possible Sincerely, Chris Hoidal Director, Western Region Pipehne and Hazardous Materials Safety Administration cc PHP-60 Compliance Registry PHP-500 H. Monfared (0121147) Enclosure Response Options for Pipeline Operators rn Compliance Proceedings#