{"operation":"document","citation":"CPF 520121008S","title":"MOJAVE PIPELINE OPERATING COMPANY — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-05-04","effective_on":null,"summary":"CLOSED safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121008s.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121008s.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121008s","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520121008S","body":"Safety Order involving MOJAVE PIPELINE OPERATING COMPANY. The dataset does not identify a cited regulation for this case. The case was opened on 2012-05-04 and is reported as closed as of 2013-04-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520121008S_Closure Letter_04192013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Closure%20Letter_04192013.pdf\n\n520121008S_Closure Letter_04192013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Closure%20Letter_04192013_text.pdf\n\n520121008S_NOPSO_05042012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_NOPSO_05042012.pdf\n\n520121008S_NOPSO_05042012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_NOPSO_05042012_text.pdf\n\n520121008S_operator response_05042012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_operator%20response_05042012.pdf\n\n520121008S_Safety Order_05082012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Safety%20Order_05082012.pdf\n\n520121008S_Safety Order_05082012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Safety%20Order_05082012_text.pdf\n\n520121008S_Safety Order_05082012_text.pdf\n\nMAY 8 2012\nVIA CERTIFIED MAIL AND FAX TO: (719) 520-4899\nMr. Michael Catt\nVice President, Operations\nMojave Pipeline Operating Company\n2 North Nevada, Suite 1000\nColorado Springs, CO 80944\nRe: CPF No. 5-2012-1008S\nDear Mr. Catt:\nEnclosed please find the Safety Order issued in the above-referenced case. It makes a finding\nthat the Mojave Pipeline has a condition or conditions that pose a pipeline integrity risk and\nspecifies actions that must be taken by Mojave Pipeline Operating Company to ensure that the\npublic, property, and the environment are protected from the risk. When the terms of the order\nhave been completed, as determined by the Director, Western Region, this enforcement action\nwill be closed. Service of the Safety Order by certified mail is deemed effective upon the date of\nmailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Chris Hoidal, Director, Western Region, OPS\nMr. Alan Mayberry, Deputy Associate Administrator for Pipeline Safety, OPS\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\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 )\nMojave Pipeline Operating Company, ) CPF No. 5-2012-1008S\n)\n)\n)\nRespondent. )\n____________________________________)\nSAFETY ORDER\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), conducted an investigation of the safety of the\nMojave Pipeline, an interstate gas transmission pipeline, arising at an incident that occurred on\nMay 2, 2012, near Arvin, California. The Mojave Pipeline is operated by Mojave Pipeline\nOperating Company (MPOC or Respondent). MPOC, a subsidiary of the El Paso Natural Gas\nCompany, operates approximately 560 miles of pipeline that connect with other pipeline\nsystems, including the El Paso Natural Gas system near Cadiz, California; the El Paso Natural\nGas and Transwestern Pipeline Company, LLC systems at Topock, Arizona; and the Kern River\nGas Transmission Company system in California.\n1\nOn May 2, 2012, at approximately 8:05 a.m. P.D.T., a reportable incident occurred near Arvin,\nCalifornia, on the Mojave Pipeline. The incident resulted in the release of an undetermined\nquantity of natural gas into the atmosphere (Failure).\nAs a result of a preliminary failure investigation of the Failure, the Director, Western Region,\nOPS (Director), issued to Respondent, by letter dated May 4, 2012, a Notice of Proposed Safety\nOrder (Notice). In accordance with 49 C.F.R. § 190.239, the Notice proposed finding that\nconditions exist on the Mojave Pipeline that pose a pipeline integrity risk to public safety,\nproperty or the environment, and proposed that Respondent take certain measures to ensure that\nthe public, property, and the environment are protected from the risk.\nMPOC responded to the Notice by letter dated May 4, 2012. In its letter, Respondent expressed\nits intent to comply with the terms of the Notice as proposed, authorizing the entry of this Safety\nOrder. Respondent did not request a hearing, and therefore has waived its right to one.\n1 http://www.sec.gov/Archives/edgar/data/31986/000119312512079791/d268735d10k.htm\n\n\n\n2\nFindings of Integrity Risk\nRespondent did not contest the proposed findings in the Notice that the Mojave Pipeline has a\ncondition or conditions that pose a pipeline integrity risk. Accordingly, pursuant to\n49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, I find as follows:\n• The Mojave Pipeline is a 42” natural gas transmission line running approximately 560\nmiles from the Topock Compressor Station at the California-Arizona border to Kern\nCounty, California. At the line’s compressor station in Daggett, California, located 143\nmiles downstream of the Topock compressor station, the Mojave Pipeline interconnects\nwith the Kern River Gas Transmission Company’s natural gas transmission pipeline\nsystem. From Daggett to Arvin, the combined pipeline is known as the “Common\nFacilities,\nlateral lines. This junction is known generally as the Bifurcation Point (M.P. 118+1887).\n”2 and ends at a junction point near Arvin, where the line divides into two\n• Beginning at the Bifurcation Point, the 42-inch O.D. Line No. 1901 (West Lateral)\nextends toward Taft, California, and the 30” O.D. Line No. 1902 (East Lateral) extends\ntoward Bakersfield, California.\n• The Maximum Allowable Operating Pressure (MAOP) of the Mojave Pipeline is 1200\npsig from Topock, Arizona, to the Bifurcation Point. The West Lateral and the East\nLateral leaving the Bifurcation Point each have MAOPs of 930 psig.\n• According to MPOC, on May 2, 2012, at about 4 a.m. Mountain Daylight Time (MDT),\ngas controllers for MPOC began noticing a drop of line pressure as measured at Main\nLine Valve (MLV) 323, which is located at the Bifurcation Point. Approximately one\nhour later, Kern River took its compressor station at Good Springs off-line.\n3 The line\npressure on the Common Facilities continued to drop at a slow steady rate. At\napproximately 5:45 a.m. MDT, there was a somewhat more significant drop of pressure\nat the Bifurcation Point, as reported to MPOC Gas Control by the pressure transmitter at\nMLV 323. MPOC Gas Control called an operations technician in the Bakersfield area to\ninvestigate the dropping pressure.4\n• At approximately 9:20 a.m. MDT, MPOC Gas Control received a call from the Sycamore\nGolf Course, located near the Bifurcation Point, reporting blowing gas in the area.\nMojave field personnel in the field thereupon requested that the El Paso Operations\nControl Center close the valve and the other valves downstream of the Failure site. The\nline blew down at approximately 12:30 p.m. P.D.T.\n2 These facilities are known as the “Common Facilities” because Mojave and Kern River have an undivided interest\nin the facilities and each provides transportation services to its own customers on this portion of the pipe under its\nown FERC-approved gas tariff.\n3 Kern River’s Good Spring compressor station is located approximately 234 miles upstream of the Bifurcation\nPoint.\n4 This information was received from MPOC and has not been independently verified.\n\n\n\n3\n• The Failure occurred approximately six miles southwest of the Arvin city limits near the\nSycamore Canyon golf course. The release occurred in a fenced area at the southwest\ncorner of the golf course. The north, east, and south sides of the facility are bordered by\nan orchard; the entire area is in a relatively remote agricultural region. There were no\nknown injuries, fire, or evacuation resulting from the Failure.\n• Mojave reported the Failure to the National Response Center (NRC Report No. 1010322)\non May 2, 2012, at approximately 9:28 a.m. (PDT). In the NRC Report, Mojave\nestimated the duration of the release to have been approximately 40 minutes.\n• When the lines were fully shut-in, personnel determined that all four relief valves at the\nBifurcation Point had been damaged. There were four (4) relief valves that came off of a\n30” header downstream of MPOC’s 42” mainline isolation valve #323 to protect the two\nlateral lines leaving the Bifurcation Point. The relief valves were set at 940, 950, 960,\nand 970 psig, respectively. At the time of the Failure, the highest pressure was 916 psig\nat the Failure site. The vent piping for these devices was supported by two vertical\nmembers and a horizontal cross member at the Bifurcation Point.\n• The Mojave Pipeline was built between 1991-1992.\n• The cause of the failure is unknown and the investigation is still ongoing.\nIssuance of Safety Order\nSection 60117(l) of Title 49, United States Code, provides for the issuance of a safety order, after\nreasonable notice and the opportunity for a hearing, requiring corrective measures, which may\ninclude physical inspection, testing, repair, or other action, as appropriate. The basis for making\nthe determination that a pipeline facility has a condition or conditions that pose a pipeline\nintegrity risk to public safety, property, or the environment is set forth both in the above-\nreferenced statute and 49 C.F.R. §190.239.\nAfter evaluating the foregoing findings and considering the age of the pipe involved, the\nhazardous nature of the product transported, the circumstances surrounding the Failure, including\nthe uncertainties of the cause of the Failure and the potential for the conditions that caused the\nFailure to be present elsewhere on the Mojave Pipeline, the fact that the Mojave Pipeline services\nhighly populated areas downstream, and the likelihood that the conditions could recur on other\nareas of the pipeline and potentially impact its serviceability, PHMSA finds that Respondent’s\nMojave Pipeline has a condition or conditions that pose a pipeline integrity risk to public safety,\nproperty, or the environment. Accordingly, PHMSA issues this Safety Order, which requires\nthat Respondent take measures specified below to address the risk.\nCorrective Measures\nPursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, MPOC must take the following\nremedial requirements with respect to the segment of the Mojave Pipeline running from the\nDaggett Compressor station to the ends of the West Lateral and the East Lateral lines (Affected\nSegment):\n\n\n\n4\n1. Submit and execute a return to “reduced” service plan, for the Director’s review, prior to\nrestart of the Affected Segment.\n2. Within two weeks of receipt of the Notice, submit to the Director for approval a protocol\nfor conducting a metallurgical analysis (Metallurgical Analysis). Following approval by\nPHMSA, have an independent third party perform the Metallurgical Analysis, to be\ncompleted within 45 days following receipt of such approval. The testing and analysis shall\nbe completed as follows:\n(A) Document the chain of custody when handling and transporting the failed pipe section\nand other evidence originating from the Failure site;\n(B) Utilize mechanical and metallurgical testing protocols, including selection of the\ntesting laboratory, approved by the Director;\n(C) Prior to commencing the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow a PHMSA\nrepresentative to witness the testing; and\n(D) Ensure that the testing laboratory distributes all resulting reports in their entirety,\nwhether draft or final, to the Director at the same time they are made available to\nRespondent.\n3. When the Affected Segment is returned to service, operate the Affected Segment at a\nreduced pressure such that the pressure as measured at MLV 323 does not exceed 824 psig,\nwhich is a 10% reduction from the pre-failure pressure. MOPC Gas Control, working in\nconjunction with operations personnel in the field, must conduct remote monitoring and on-\nsite, in-person monitoring of the pressure at MLV 323 at the Bifurcation Point for 24 hours a\nday, 7 days a week, until such time the Director agrees it is safe to return to full operating\npressure.\n4. Prior to asking for a return to full operating pressure, provide independent, adequate\noverpressure protection for the Bifurcation Station that does not rely on safety devices\nprovided by the Kern River Gas Transmission pipeline system or MOPC’s Daggett Station,\nand ensure that the MAOP levels of the Mojave Pipeline both upstream and downstream of\nthe Bifurcation Station are not exceeded.\n5. Conduct a forensic investigation of the SCADA data on the Common Facilities to\ndetermine whether there was any tampering with, or corruption of, the SCADA pressure data.\n6. Evaluate available methods to further test the validity of the data being collected by the\nSCADA telemetry at the Bifurcation Point.\n7. Assemble an internal root cause investigation team and prepare a report of the root cause\nanalysis (RCA)of the failure. The RCA report must be completed within 90 days after the\nissuance of this Safety Order and submitted to the Director. At the request of the Director,\nrepresentatives of MPOC shall meet with PHMSA to discuss the findings and the need for\nadditional analysis before acceptance. At a minimum, the RCA should address the items in\nthe attached Appendix A.\n\n\n\n5\n8. If the RCA indicates that the cause of the Failure may be indicative of more systemic\noperational issues (e.g., more widespread than a failure of one or two pieces of equipment),\nthe Director may direct MPOC to develop and submit an appropriate Integrity Verification\nand Remediation Plan (IVRP) for other locations on the Common Facilities. If required, the\nIVRP shall be submitted to the Director for approval within 45 days following the submittal\nof the RCA report. The Director may approve plan elements incrementally. The IVRP, and\nany revisions, will automatically be incorporated by reference into this Safety Order.\n9. If an IVRP is required, MPOC must prepare and submit monthly progress reports,\nstarting 30 days after approval of the IVRP by the Director. The monthly reports must\nprovide sufficient detail to allow the Director to track the process of the IVRP. MPOC must\nprovide the Director an opportunity to have PHMSA personnel observe and inspect any\nactivities required by the IVRP as they occur.\n10. The Director may grant an extension of time for compliance with any of the terms of this\nSafety Order upon a written request timely submitted demonstrating good cause for an\nextension.\n11. The Director may allow the removal or modification of the pressure restriction set forth\nin Item 3 above upon a written request from MPOC demonstrating that the hazard has been\nabated and that restoring the Affected Segment to its pre-failure operation pressure is\njustified based on a reliable engineering analysis showing that the pressure increase is safe,\nconsidering all known defects, anomalies, and operating parameters of the Affected Segment.\n12. Respondent may appeal any decision of the Director to the Associate Administrator for\nPipeline Safety. Decisions of the Associate Administrator shall be final.\n13. It is requested, but not mandated, that the MPOC maintain documentation of the safety\nimprovement costs associated with fulfilling this Safety Order and submit the total to Chris\nHoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration.\nIt is requested that these costs be reported in two categories: 1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses; and 2) total cost associated\nwith replacements, additions and other changes to pipeline infrastructure.\nOn May 4, 2012, MPOC submitted a return to “reduced” service plan for the Director’s review in\ncompliance with Item 1 above.\nIn your correspondence on this matter, please refer to CPF No. 5-2012-1008S and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nBe advised 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).\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\n\n\n\n6\nThe actions taken pursuant to this Safety Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199,\nunder any other order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under\nany other provision of Federal or state law.\nAfter receiving and analyzing additional data in the course of this proceeding and\nimplementation of the required tests and analysis, PHMSA may identify other safety measures\nthat need to be taken. In that event, Respondent will be notified of any proposed additional\nmeasures and, if necessary, amendments to the Safety Order.\nThe terms and conditions of this Safety Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n\n\n7\nAppendix A\nThe RCA addressed above should include the following information:\n1. A timeline of all pertinent actions executed by control room personnel, field personnel,\nand supervisory personnel starting on May 2, 2012, at 3:00 a.m. PDT, through blow-down\ncompletion at approximately 12:30 PDT p.m. on May 2, 2012. This should include all\npersonnel whose actions could have contributed to the release event at the Bifurcation\nPoint, affected the emergency response to the release or assisted in the immediate\ninvestigation of the release. Please provide all names, titles and cell phone numbers for\neach person.\n2. Relevant SCADA data, including raw data and pressure and flow trends for the\nDaggett Compressor Station (CS), each data point down the mainline up to the Bifurcation\nPoint, including two data points downstream (DS) of the Bifurcation Point on the West\nLateral and the East Lateral. Please include any additional SCADA information that is\npertinent to the investigation, even if not specifically identified here.\n3. All alignment sheets and piping and instrumentation diagrams (P&ID) showing\npressure transmitters and valve installations, as well as telemetry points along the line from\nthe Kern River interconnect at Daggett CS through two data points or mainline valves DS\nof Bifurcation Point.\n4. Manufacturing specifications of all valves on the Affected Segment, from the Daggett\nCompressor Station through the Bifurcation Point and including two valves DS of\nBifurcation Point on each lateral.\n5. Pipe specifications for the 42” mainline from Daggett CS and the 30” line and 42” line\nDS of the Bifurcation Point generally. Please include manufacturer, SMYS, API\ndesignation, MAOP and how determined, wall thickness, coating type, and installation\ndate(s) for each separate line section.\n6. Maintenance records for all mainline valves from Daggett CS through the Bifurcation\nPoint and two valves DS of the Bifurcation Point on each lateral and relief valves at\nBifurcation Point, to include the past two DOT inspections and any other maintenance\nwork performed at Bifurcation Point in the last two years.\n7. Any facility work orders or project files for Bifurcation Point for the past two years.\n8. Current/updated P&IDs for Daggett CS and Bifurcation Point.\n9. Relief valve capacity calculations for each relief valve at Bifurcation Point.\n10. Utilize a forensic specialist from the relief valve manufacturer on the MPOC RCA\ninvestigation team.\n11. Original design specifications for the relief piping and support system and any\nsubsequent modification and/or recalculations after each significant change in operational\nparameters.\n\n520121008S_Closure Letter_04192013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 19, 2013\nMr. Dwayne Burton\nVice President, Engineering/Operations, KMI Pipeline\nMojave Pipeline Operating Company, L.L.C.\n1001 Louisiana Street\nP.O. Box 2511\nHouston, TX 77002\nCPF 5-2012-1008S\nClosure Letter\nDear Mr. Burton:\nOn May 8, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Mojave Pipeline Operating Company a Safety Order in the above-referenced case.\nIt required Mojave Pipeline Operating Company to take certain corrective measures with\nrespect to the failure of four relieve valves causing a natural gas release at the Bifurcation\nPoint on Mojave Pipeline near Arvin, California. Based on our review of the documentation\nyou provided, it has been determined that you have complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Larson\nPatrick Carey, Director, DOT Compliance Services, KMI Pipelines","truncated":false,"body_characters":21842}