{"operation":"document","citation":"CPF 520131007H","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-06-19","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131007h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131007h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131007h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520131007H","body":"Corrective Action Order involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2013-06-19 and is reported as closed as of 2015-08-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520131007H_Corrective Action Order_06192013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131007H/520131007H_Corrective%20Action%20Order_06192013.pdf\n\n520131007H_Corrective Action Order_06192013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131007H/520131007H_Corrective%20Action%20Order_06192013_text.pdf\n\n520131007H_Region Response to CAO Status Report and Closure Letter_08142015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131007H/520131007H_Region%20Response%20to%20CAO%20Status%20Report%20and%20Closure%20Letter_08142015.pdf\n\n520131007H_Region Response to CAO Status Report and Closure Letter_08142015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131007H/520131007H_Region%20Response%20to%20CAO%20Status%20Report%20and%20Closure%20Letter_08142015_text.pdf\n\n520131007H_Corrective Action Order_06192013_text.pdf\n\nJUNE 19, 2013\nVIA CERTIFIED MAIL AND FAX TO: (913) 928-6006\nDavid G. Dehaemers, Jr., CEO\nTallgrass Interstate Gas Transmission, LLC\n6640 W. 143. St., Ste. 200\nOverland Park, Kansas 66223\nRe: CPF No. 5-2013-1007H\nDear Mr. Dehaemers:\nEnclosed is a Corrective Action Order issued by the Pipeline and Hazardous Materials Safety\nAdministration in the above-referenced case. It requires Tallgrass Interstate Gas Transmission,\nLLC, to take certain corrective actions with respect to the 12-inch Glenrock Natural Bridge\nPipeline that failed on June 13, 2013, near Henry, Nebraska. Service is being made by certified\nmail and facsimile. Service of this Corrective Action Order by facsimile or other electronic\nmeans is complete upon transmission or acknowledgement of receipt, as provided under\n49 C.F.R. § 190.5. The terms and conditions of this Order are effective immediately upon\nservice.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS\nMr. Chris Hoidal, Director, Western Region, OPS\nMr. Mick Rafter, Vice President of Operations, Tallgrass Interstate Gas Transmission, LLC\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 )\nTallgrass Interstate Gas Transmission, LLC, ) CPF No. 5-2013-1007H\n)\n)\n)\nRespondent. )\n__________________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C. § 60112\nand 49 C.F.R. § 190.233, to require Tallgrass Interstate Gas Transmission, LLC (Tallgrass or\nRespondent), to take the necessary corrective action to protect the public, property, and the\nenvironment from potential hazards associated with a recent failure involving Tallgrass’s 12-inch\nGlenrock Natural Bridge Lateral Pipeline.\nOn June 13, 2013, a failure occurred on Respondent’s 12-inch line, approximately seven miles to\nthe east of Torrington, Wyoming, and one mile west of Henry, Nebraska, resulting in the release\nof approximately 2.5 million cubic feet of natural gas into the atmosphere (Failure). The cause\nof the Failure has not yet been determined.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the Failure. The\npreliminary findings of the ongoing investigation are set forth below.\nPreliminary Findings\n• Tallgrass Interstate Gas Transmission, LLC, a subsidiary of Tallgrass Energy Partners,\nLP, owns and operates approximately 5,100 miles of natural gas transportation pipelines\nin Colorado, Kansas, Nebraska, Missouri and Wyoming.1\n• The affected pipeline is a 12-inch diameter line that runs from Lingle, Wyoming, and\nthrough Torrington, Wyoming, to Henry and Mitchel, Nebraska, a distance of\n1 See http://www.tallgrassenergylp.com/Pipelines/TIGT/ (last accessed June 17, 2013).\n\n\n\n2\n• approximately 32.98 miles (“Affected Segment”).2 The Failure occurred near milepost\n17.65 in the state of Wyoming outside of Torrington, Wyoming, and Henry, Nebraska.\n• The Affected Segment parallels and then loops with the Respondent’s 16-inch line\nstarting in Lingle, Wyoming. The 12-inch line takes a more southeasterly route and the\nRespondent’s 16-inch diameter pipeline takes a more northeasterly route. The lines\nrecombine in Mitchel, Nebraska. As originally configured, the overpressure protection\nfor both lines was provided by a relief valve installed on the 12-inch pipeline at the\nLingle takeoff. Since the release, the 12-inch pipeline has been isolated from the 16-inch\npipeline. Therefore, the 16-inch pipeline currently has no overpressure protection\ndownstream of the Guernsey Compressor Station. The Guernsey Compressor Station is\napproximately 19.33 miles upstream from Lingle, Wyoming.\n• The Affected Segment was originally constructed in 1963. The failed pipe is 12 inches in\ndiameter, has a wall thickness of 0.219,” and has a low frequency electric resistance weld\n(LF-ERW) pipe seam.\n• At approximately 8:58 pm CDT on June 13, 2013, Tallgrass’ Operations Control Center\nin Lakewood, Colorado, detected a pressure drop on the pipeline and suspected that a\nfailure had occurred on Respondent’s Glen Rock Natural Bridge Lateral Pipeline in\nGoshen County.\n• Upon learning of the pressure drop, Tallgrass began to close the valves downstream and\nupstream to isolate the Failure site. The valves were closed within 35 minutes of the\npressure drop. The distance between the valves is approximately eight miles.\n• The maximum allowable operating pressure (MAOP) of the pipeline at the Failure Site is\n865 psig. At the time of the Failure, the actual operating pressure of the pipeline was 812\npsig.\n• Various federal, state and local agencies, including PHMSA and first responders,\nresponded to the scene of the Failure. Due to their proximity to the Failure Site,\nemergency responders closed Highway 26 and State Road 63 during the release. The\ncause of the Failure is still undetermined and the investigation is ongoing. It appears that\nthe cause of the Failure may have been due to an LF-ERW pipe seam failure.\n• The Failure did not cause any known injuries, fatalities, fires or evacuations.\n• Portions of the Affected Segment and Respondent’s 16-inch pipeline run through\npopulated areas, along Highway 26 and State Road 63, and along a railroad right-of-way.\n• The line was brought back into service late in the day on Friday, June 14, 2013. The\noperator took a voluntary 20% reduction in pressure not to exceed 650 psig in the 12-inch\nsegment. Permanent repairs were scheduled for June 17, 2013 and have been completed.\n2 The Affected Segment runs from the pig launcher at MP 0.00 at Lingle, Wyoming, to the pig receiver at MP 32.98\nat Mitchel, Nebraska.\n\n\n\n3\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is hazardous, requiring corrective action, is set forth both in\nthe above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order without prior opportunity for notice and hearing, upon a finding that\nfailure to issue the Order expeditiously will likely result in serious harm to life, property, or the\nenvironment. In such cases, an opportunity for a hearing will be provided as soon as practicable\nafter the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures would be hazardous to life, property, and the environment.\nAdditionally, having considered the unknown cause of the Failure,; the location of the Failure;\nthe proximity of the Affected Segment and Respondent’s 16-inch pipeline to populated areas,\nhighways and a railroad; the current lack of adequate overpressure protection on Respondent’s\nsystem; and the nature of the product being transported, I find that a failure to issue this Order\nexpeditiously to require immediate corrective action would result in the likelihood of serious\nharm to life, property, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Western Region, PHMSA (Director). If a hearing is requested, it will be held\ntelephonically or in-person in Lakewood, CO or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, Respondent will be\nnotified of any additional measures required and amendment of this Order will be considered.\nTo the extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nPursuant to 49 U.S.C. § 60112, I hereby order Tallgrass to immediately take the following\ncorrective actions regarding the Affected Segment:\n1. Metallurgical Testing. Respondent has contracted with EN Engineering, Inc., located at\n28100 Torch Parkway, Warrenville, Illinois 60555 to perform its metallurgical testing.\nComplete the testing and analysis as follows:\n\n\n\n4\n2. 3. 4. A. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the Failure site;\nB. Prior to commencing the mechanical and metallurgical testing utilizing the\nPHMSA metallurgical protocol, provide the Director with the scheduled date,\ntime, and location of the testing to allow a PHMSA representative to witness the\ntesting; and\nC. Ensure that the testing laboratory distributes all resulting reports in their entirety\n(including all media), whether draft or final, to the Director at the same time as\nthey are made available to Respondent.\nHydrotest. Within 30 days after the metallurgical report is completed, submit a hydrotest\nplan, including a spike test to 110% SMYS held for a minimum of 30 minutes, to be\napproved by the Director. The Director will approve a pressure test level and duration\nbased upon the metallurgical report. Once the plan is approved, Respondent must\nperform a hydrotest, including a spike test, and submit the report to the Director within\n30 days.\nInline Inspection. Within 180 days after the metallurgical report is completed, perform\nan in-line inspection (ILI) of the Affected Segment. The Director must provide prior\napproval of the final criteria and specific technology considerations taken into account in\nselecting the specific inspection tool. Technology considerations and final criteria should\naccount for the size of the anomalies discovered. The data analysis must be completed\nexpeditiously, but no later than 60 days of successful completion of the ILI. The ILI\nvendor must evaluate the results per a performance specification, including consideration\nof the location and size of the defects. The ILI vendor must distribute all reports in their\nentirety (including all media), whether preliminary or final, to the Director and the\nRespondent at the same time. Results of the ILI must be compared with the results of the\nprevious ILIs in 2003 and 2010 in a report submitted to the Director that includes such\ncomparison, as well as criteria and a plan for remediation of anomalies requiring\nimmediate action.\nLeak Survey. Within 30 days of receipt of this Order, perform a leak survey and submit\nthe report to the Director.\n5. Root Cause Failure. Within 60 days of the receipt of the Final Metallurgical Report,\ncomplete a root cause failure analysis that is supplemented and facilitated by an\nindependent third-party acceptable to the Director. The root cause analysis must\ndocument all contributory factors and the decision making process. Submit a final report\nof the root cause process results to the Director including any lessons learned and\nwhether the findings are applicable to other locations within the Respondent’s system.\n6. Pressure Restriction. Lower the pressure on the overpressure protection valve on the\nAffected Segment not to exceed 650 psig. This pressure restriction will remain in effect\nuntil written approval is obtained from the Director.\n\n\n\n5\n7. Removal of Pressure Restriction. The Director may allow the removal or modification of\nthe pressure restriction upon a written request from Respondent demonstrating that\nrestoring the over-pressure protection valve to its pre-failure operating pressure is\njustified, based on a reliable engineering analysis showing that the pressure increase is\nsafe considering all known defects, anomalies and operating parameters of the pipeline.\n8. Monitoring. Controllers must closely monitor the pressures downstream of the Guernsey\ncompressor station (CS) on the 16-inch line that has been isolated from all overpressure\nprotection. Maintain a log of pressures and flow rates on the Affected Segment and 16-\ninch line downstream of the Guernsey CS until the lines are returned back to their\noriginal configuration. Respondent must immediately notify the Western Region office if\nthe MAOP of the lines are exceeded.\n9. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first quarterly report is due\non October 15, 2013. The Director may change the interval for the submission of these\nreports.\n10. Documentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action\nOrder. Include in each monthly report submitted, the to-date total costs associated with:\n(1) preparation and revision of procedures, studies and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, if applicable.\n11. Approvals. With respect to each submission that under this Order requires the approval\nof the Director, the Director may: (a) approve, in whole or part, the submission; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent\nmodify the submission, or (e) any combination of the above. In the event of approval,\napproval upon conditions, or modification by the Director, Respondent shall proceed to\ntake all action required by the submission as approved or modified by the Director. If the\nDirector disapproves all or any portion of the submission, Respondent must correct all\ndeficiencies within the time specified by the Director, and resubmit it for approval.\n12. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted demonstrating\ngood cause for an extension.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 192, under any\nother order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other\nprovision of Federal or State law.\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\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).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nIn your correspondence on this matter, please refer to CPF No. 5-2013-1007H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":17735}