# MOJAVE PIPELINE OPERATING COMPANY — Safety Order

- **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:** Not available
- **summary:** CLOSED safety order.
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- **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.

Official case documents:

520121008S_Closure Letter_04192013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Closure%20Letter_04192013.pdf

520121008S_Closure Letter_04192013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Closure%20Letter_04192013_text.pdf

520121008S_NOPSO_05042012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_NOPSO_05042012.pdf

520121008S_NOPSO_05042012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_NOPSO_05042012_text.pdf

520121008S_operator response_05042012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_operator%20response_05042012.pdf

520121008S_Safety Order_05082012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Safety%20Order_05082012.pdf

520121008S_Safety Order_05082012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121008S/520121008S_Safety%20Order_05082012_text.pdf

520121008S_Safety Order_05082012_text.pdf

MAY 8 2012
VIA CERTIFIED MAIL AND FAX TO: (719) 520-4899
Mr. Michael Catt
Vice President, Operations
Mojave Pipeline Operating Company
2 North Nevada, Suite 1000
Colorado Springs, CO 80944
Re: CPF No. 5-2012-1008S
Dear Mr. Catt:
Enclosed please find the Safety Order issued in the above-referenced case. It makes a finding
that the Mojave Pipeline has a condition or conditions that pose a pipeline integrity risk and
specifies actions that must be taken by Mojave Pipeline Operating Company to ensure that the
public, property, and the environment are protected from the risk. When the terms of the order
have been completed, as determined by the Director, Western Region, this enforcement action
will be closed. Service of the Safety Order by certified mail is deemed effective upon the date of
mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal, Director, Western Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Pipeline Safety, OPS
CERTIFIED MAIL – RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Mojave Pipeline Operating Company, ) CPF No. 5-2012-1008S
)
)
)
Respondent. )
____________________________________)
SAFETY ORDER
Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), conducted an investigation of the safety of the
Mojave Pipeline, an interstate gas transmission pipeline, arising at an incident that occurred on
May 2, 2012, near Arvin, California. The Mojave Pipeline is operated by Mojave Pipeline
Operating Company (MPOC or Respondent). MPOC, a subsidiary of the El Paso Natural Gas
Company, operates approximately 560 miles of pipeline that connect with other pipeline
systems, including the El Paso Natural Gas system near Cadiz, California; the El Paso Natural
Gas and Transwestern Pipeline Company, LLC systems at Topock, Arizona; and the Kern River
Gas Transmission Company system in California.
1
On May 2, 2012, at approximately 8:05 a.m. P.D.T., a reportable incident occurred near Arvin,
California, on the Mojave Pipeline. The incident resulted in the release of an undetermined
quantity of natural gas into the atmosphere (Failure).
As a result of a preliminary failure investigation of the Failure, the Director, Western Region,
OPS (Director), issued to Respondent, by letter dated May 4, 2012, a Notice of Proposed Safety
Order (Notice). In accordance with 49 C.F.R. § 190.239, the Notice proposed finding that
conditions exist on the Mojave Pipeline that pose a pipeline integrity risk to public safety,
property or the environment, and proposed that Respondent take certain measures to ensure that
the public, property, and the environment are protected from the risk.
MPOC responded to the Notice by letter dated May 4, 2012. In its letter, Respondent expressed
its intent to comply with the terms of the Notice as proposed, authorizing the entry of this Safety
Order. Respondent did not request a hearing, and therefore has waived its right to one.
1 http://www.sec.gov/Archives/edgar/data/31986/000119312512079791/d268735d10k.htm



2
Findings of Integrity Risk
Respondent did not contest the proposed findings in the Notice that the Mojave Pipeline has a
condition or conditions that pose a pipeline integrity risk. Accordingly, pursuant to
49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, I find as follows:
• The Mojave Pipeline is a 42” natural gas transmission line running approximately 560
miles from the Topock Compressor Station at the California-Arizona border to Kern
County, California. At the line’s compressor station in Daggett, California, located 143
miles downstream of the Topock compressor station, the Mojave Pipeline interconnects
with the Kern River Gas Transmission Company’s natural gas transmission pipeline
system. From Daggett to Arvin, the combined pipeline is known as the “Common
Facilities,
lateral lines. This junction is known generally as the Bifurcation Point (M.P. 118+1887).
”2 and ends at a junction point near Arvin, where the line divides into two
• Beginning at the Bifurcation Point, the 42-inch O.D. Line No. 1901 (West Lateral)
extends toward Taft, California, and the 30” O.D. Line No. 1902 (East Lateral) extends
toward Bakersfield, California.
• The Maximum Allowable Operating Pressure (MAOP) of the Mojave Pipeline is 1200
psig from Topock, Arizona, to the Bifurcation Point. The West Lateral and the East
Lateral leaving the Bifurcation Point each have MAOPs of 930 psig.
• According to MPOC, on May 2, 2012, at about 4 a.m. Mountain Daylight Time (MDT),
gas controllers for MPOC began noticing a drop of line pressure as measured at Main
Line Valve (MLV) 323, which is located at the Bifurcation Point. Approximately one
hour later, Kern River took its compressor station at Good Springs off-line.
3 The line
pressure on the Common Facilities continued to drop at a slow steady rate. At
approximately 5:45 a.m. MDT, there was a somewhat more significant drop of pressure
at the Bifurcation Point, as reported to MPOC Gas Control by the pressure transmitter at
MLV 323. MPOC Gas Control called an operations technician in the Bakersfield area to
investigate the dropping pressure.4
• At approximately 9:20 a.m. MDT, MPOC Gas Control received a call from the Sycamore
Golf Course, located near the Bifurcation Point, reporting blowing gas in the area.
Mojave field personnel in the field thereupon requested that the El Paso Operations
Control Center close the valve and the other valves downstream of the Failure site. The
line blew down at approximately 12:30 p.m. P.D.T.
2 These facilities are known as the “Common Facilities” because Mojave and Kern River have an undivided interest
in the facilities and each provides transportation services to its own customers on this portion of the pipe under its
own FERC-approved gas tariff.
3 Kern River’s Good Spring compressor station is located approximately 234 miles upstream of the Bifurcation
Point.
4 This information was received from MPOC and has not been independently verified.



3
• The Failure occurred approximately six miles southwest of the Arvin city limits near the
Sycamore Canyon golf course. The release occurred in a fenced area at the southwest
corner of the golf course. The north, east, and south sides of the facility are bordered by
an orchard; the entire area is in a relatively remote agricultural region. There were no
known injuries, fire, or evacuation resulting from the Failure.
• Mojave reported the Failure to the National Response Center (NRC Report No. 1010322)
on May 2, 2012, at approximately 9:28 a.m. (PDT). In the NRC Report, Mojave
estimated the duration of the release to have been approximately 40 minutes.
• When the lines were fully shut-in, personnel determined that all four relief valves at the
Bifurcation Point had been damaged. There were four (4) relief valves that came off of a
30” header downstream of MPOC’s 42” mainline isolation valve #323 to protect the two
lateral lines leaving the Bifurcation Point. The relief valves were set at 940, 950, 960,
and 970 psig, respectively. At the time of the Failure, the highest pressure was 916 psig
at the Failure site. The vent piping for these devices was supported by two vertical
members and a horizontal cross member at the Bifurcation Point.
• The Mojave Pipeline was built between 1991-1992.
• The cause of the failure is unknown and the investigation is still ongoing.
Issuance of Safety Order
Section 60117(l) of Title 49, United States Code, provides for the issuance of a safety order, after
reasonable notice and the opportunity for a hearing, requiring corrective measures, which may
include physical inspection, testing, repair, or other action, as appropriate. The basis for making
the determination that a pipeline facility has a condition or conditions that pose a pipeline
integrity risk to public safety, property, or the environment is set forth both in the above-
referenced statute and 49 C.F.R. §190.239.
After evaluating the foregoing findings and considering the age of the pipe involved, the
hazardous nature of the product transported, the circumstances surrounding the Failure, including
the uncertainties of the cause of the Failure and the potential for the conditions that caused the
Failure to be present elsewhere on the Mojave Pipeline, the fact that the Mojave Pipeline services
highly populated areas downstream, and the likelihood that the conditions could recur on other
areas of the pipeline and potentially impact its serviceability, PHMSA finds that Respondent’s
Mojave Pipeline has a condition or conditions that pose a pipeline integrity risk to public safety,
property, or the environment. Accordingly, PHMSA issues this Safety Order, which requires
that Respondent take measures specified below to address the risk.
Corrective Measures
Pursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, MPOC must take the following
remedial requirements with respect to the segment of the Mojave Pipeline running from the
Daggett Compressor station to the ends of the West Lateral and the East Lateral lines (Affected
Segment):



4
1. Submit and execute a return to “reduced” service plan, for the Director’s review, prior to
restart of the Affected Segment.
2. Within two weeks of receipt of the Notice, submit to the Director for approval a protocol
for conducting a metallurgical analysis (Metallurgical Analysis). Following approval by
PHMSA, have an independent third party perform the Metallurgical Analysis, to be
completed within 45 days following receipt of such approval. The testing and analysis shall
be completed as follows:
(A) Document the chain of custody when handling and transporting the failed pipe section
and other evidence originating from the Failure site;
(B) Utilize mechanical and metallurgical testing protocols, including selection of the
testing laboratory, approved by the Director;
(C) Prior to commencing the mechanical and metallurgical testing, provide the Director
with the scheduled date, time, and location of the testing to allow a PHMSA
representative to witness the testing; and
(D) Ensure that the testing laboratory distributes all resulting reports in their entirety,
whether draft or final, to the Director at the same time they are made available to
Respondent.
3. When the Affected Segment is returned to service, operate the Affected Segment at a
reduced pressure such that the pressure as measured at MLV 323 does not exceed 824 psig,
which is a 10% reduction from the pre-failure pressure. MOPC Gas Control, working in
conjunction with operations personnel in the field, must conduct remote monitoring and on-
site, in-person monitoring of the pressure at MLV 323 at the Bifurcation Point for 24 hours a
day, 7 days a week, until such time the Director agrees it is safe to return to full operating
pressure.
4. Prior to asking for a return to full operating pressure, provide independent, adequate
overpressure protection for the Bifurcation Station that does not rely on safety devices
provided by the Kern River Gas Transmission pipeline system or MOPC’s Daggett Station,
and ensure that the MAOP levels of the Mojave Pipeline both upstream and downstream of
the Bifurcation Station are not exceeded.
5. Conduct a forensic investigation of the SCADA data on the Common Facilities to
determine whether there was any tampering with, or corruption of, the SCADA pressure data.
6. Evaluate available methods to further test the validity of the data being collected by the
SCADA telemetry at the Bifurcation Point.
7. Assemble an internal root cause investigation team and prepare a report of the root cause
analysis (RCA)of the failure. The RCA report must be completed within 90 days after the
issuance of this Safety Order and submitted to the Director. At the request of the Director,
representatives of MPOC shall meet with PHMSA to discuss the findings and the need for
additional analysis before acceptance. At a minimum, the RCA should address the items in
the attached Appendix A.



5
8. If the RCA indicates that the cause of the Failure may be indicative of more systemic
operational issues (e.g., more widespread than a failure of one or two pieces of equipment),
the Director may direct MPOC to develop and submit an appropriate Integrity Verification
and Remediation Plan (IVRP) for other locations on the Common Facilities. If required, the
IVRP shall be submitted to the Director for approval within 45 days following the submittal
of the RCA report. The Director may approve plan elements incrementally. The IVRP, and
any revisions, will automatically be incorporated by reference into this Safety Order.
9. If an IVRP is required, MPOC must prepare and submit monthly progress reports,
starting 30 days after approval of the IVRP by the Director. The monthly reports must
provide sufficient detail to allow the Director to track the process of the IVRP. MPOC must
provide the Director an opportunity to have PHMSA personnel observe and inspect any
activities required by the IVRP as they occur.
10. The Director may grant an extension of time for compliance with any of the terms of this
Safety Order upon a written request timely submitted demonstrating good cause for an
extension.
11. The Director may allow the removal or modification of the pressure restriction set forth
in Item 3 above upon a written request from MPOC demonstrating that the hazard has been
abated and that restoring the Affected Segment to its pre-failure operation pressure is
justified based on a reliable engineering analysis showing that the pressure increase is safe,
considering all known defects, anomalies, and operating parameters of the Affected Segment.
12. Respondent may appeal any decision of the Director to the Associate Administrator for
Pipeline Safety. Decisions of the Associate Administrator shall be final.
13. It is requested, but not mandated, that the MPOC maintain documentation of the safety
improvement costs associated with fulfilling this Safety Order and submit the total to Chris
Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration.
It is requested that these costs be reported in two categories: 1) total cost associated with
preparation/revision of plans, procedures, studies and analyses; and 2) total cost associated
with replacements, additions and other changes to pipeline infrastructure.
On May 4, 2012, MPOC submitted a return to “reduced” service plan for the Director’s review in
compliance with Item 1 above.
In your correspondence on this matter, please refer to CPF No. 5-2012-1008S and for each
document you submit, please provide a copy in electronic format whenever possible.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. § 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted information
qualifies for confidential treatment under 5 U.S.C. § 552(b).
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.



6
The actions taken pursuant to this Safety Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199,
under any other order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under
any other provision of Federal or state law.
After receiving and analyzing additional data in the course of this proceeding and
implementation of the required tests and analysis, PHMSA may identify other safety measures
that need to be taken. In that event, Respondent will be notified of any proposed additional
measures and, if necessary, amendments to the Safety Order.
The terms and conditions of this Safety Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety



7
Appendix A
The RCA addressed above should include the following information:
1. A timeline of all pertinent actions executed by control room personnel, field personnel,
and supervisory personnel starting on May 2, 2012, at 3:00 a.m. PDT, through blow-down
completion at approximately 12:30 PDT p.m. on May 2, 2012. This should include all
personnel whose actions could have contributed to the release event at the Bifurcation
Point, affected the emergency response to the release or assisted in the immediate
investigation of the release. Please provide all names, titles and cell phone numbers for
each person.
2. Relevant SCADA data, including raw data and pressure and flow trends for the
Daggett Compressor Station (CS), each data point down the mainline up to the Bifurcation
Point, including two data points downstream (DS) of the Bifurcation Point on the West
Lateral and the East Lateral. Please include any additional SCADA information that is
pertinent to the investigation, even if not specifically identified here.
3. All alignment sheets and piping and instrumentation diagrams (P&ID) showing
pressure transmitters and valve installations, as well as telemetry points along the line from
the Kern River interconnect at Daggett CS through two data points or mainline valves DS
of Bifurcation Point.
4. Manufacturing specifications of all valves on the Affected Segment, from the Daggett
Compressor Station through the Bifurcation Point and including two valves DS of
Bifurcation Point on each lateral.
5. Pipe specifications for the 42” mainline from Daggett CS and the 30” line and 42” line
DS of the Bifurcation Point generally. Please include manufacturer, SMYS, API
designation, MAOP and how determined, wall thickness, coating type, and installation
date(s) for each separate line section.
6. Maintenance records for all mainline valves from Daggett CS through the Bifurcation
Point and two valves DS of the Bifurcation Point on each lateral and relief valves at
Bifurcation Point, to include the past two DOT inspections and any other maintenance
work performed at Bifurcation Point in the last two years.
7. Any facility work orders or project files for Bifurcation Point for the past two years.
8. Current/updated P&IDs for Daggett CS and Bifurcation Point.
9. Relief valve capacity calculations for each relief valve at Bifurcation Point.
10. Utilize a forensic specialist from the relief valve manufacturer on the MPOC RCA
investigation team.
11. Original design specifications for the relief piping and support system and any
subsequent modification and/or recalculations after each significant change in operational
parameters.

520121008S_Closure Letter_04192013_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 19, 2013
Mr. Dwayne Burton
Vice President, Engineering/Operations, KMI Pipeline
Mojave Pipeline Operating Company, L.L.C.
1001 Louisiana Street
P.O. Box 2511
Houston, TX 77002
CPF 5-2012-1008S
Closure Letter
Dear Mr. Burton:
On May 8, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Mojave Pipeline Operating Company a Safety Order in the above-referenced case.
It required Mojave Pipeline Operating Company to take certain corrective measures with
respect to the failure of four relieve valves causing a natural gas release at the Bifurcation
Point on Mojave Pipeline near Arvin, California. Based on our review of the documentation
you provided, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 T. Larson
Patrick Carey, Director, DOT Compliance Services, KMI Pipelines
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