{"operation":"document","citation":"CPF 520185007S","title":"SFPP, LP — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-12-28","effective_on":null,"summary":"CLOSED safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520185007s.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520185007s.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520185007s","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520185007S","body":"Safety Order involving SFPP, LP. The dataset does not identify a cited regulation for this case. The case was opened on 2018-12-28 and is reported as closed as of 2021-11-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520185007S_Closure Letter_11012021_(18-163784S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Closure%20Letter_11012021_(18-163784S).pdf\n\n520185007S_Closure Letter_11012021_(18-163784S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Closure%20Letter_11012021_(18-163784S)_text.pdf\n\n520185007S_Notice of Proposed Safety Order_12282018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Notice%20of%20Proposed%20Safety%20Order_12282018.pdf\n\n520185007S_Notice of Proposed Safety Order_12282018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Notice%20of%20Proposed%20Safety%20Order_12282018_text.pdf\n\n520185007S_Operator Response to Notice_01222019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Operator%20Response%20to%20Notice_01222019.pdf\n\n520185007S_Safety Order_08082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Safety%20Order_08082019.pdf\n\n520185007S_Safety Order_08082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520185007S/520185007S_Safety%20Order_08082019_text.pdf\n\n520185007S_Safety Order_08082019_text.pdf\n\nAugust 8, 2019\nMr. James Holland\nPresident of Pipeline Products\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: CPF No. 5-2018-5007S\nDear Mr. Kinder:\nEnclosed please find the Safety Order issued by the Pipeline and Hazardous Materials Safety\nAdministration to your subsidiary, Santa Fe Pacific Pipeline Partners, LP (SFPP), in the above-\nreferenced case. It finds that SFPP’s El Paso-to-Tucson 12-inch refined products pipeline has a\ncondition or conditions that pose a pipeline integrity risk and specifies actions that SFPP must\ntake to ensure that the public, property, and the environment are protected from such risk. When\nthe terms of the order have been completed, as determined by the Director, Western Region, this\nenforcement action will be closed. Your receipt of the Safety Order constitutes service of the\ndocument as provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Dustin Hubbard, Director, Western Region, Office of Pipeline Safety, PHMSA\nMr. Wayne Simmons, Chief Operating Officer, Products Pipeline, Kinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000, Houston, Texas 77002\nMr. Edward A. “Buzz” Fant, Director, Compliance, Codes and Standards, Products\nPipeline, Kinder Morgan Energy Partners, 1001 Louisiana Street, Suite 1000, Houston,\nTexas 77002\nMs. Nancy Van Burgel, Assistant General Counsel, Kinder Morgan Inc., 370 Van\nGordon Street, Lakewood, Colorado 80228\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 )\n)\n)\nSanta Fe Pacific Pipeline Partners, LP, a subsidiary of Kinder Morgan Inc., )\n)\nRespondent. )\n____________________________________)\n) CPF No. 5-2018-5007S\nSAFETY ORDER\nPursuant to Chapter 601 of Title 49, United States Code, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), U.S. Department of Transportation, initiated an investigation\nand information review of the safety of Santa Fe Pacific Pipeline Partners, LP’s (SFPP), 12-inch-\ndiameter El Paso-to-Tucson (12-inch EPT) pipeline. SFPP is a subsidiary of Kinder Morgan\nEnergy Partners, LP.1 The investigation was initiated following a gasoline release in Dona Ana\nCounty, near Anthony, New Mexico. The pipeline ruptured and an initially-reported release\nvolume of 6,000 barrels of gasoline was discharged into a drainage ditch at approximately 2348\nMST on December 13, 2018 (Failure).2\nAs a result of the investigation, and pursuant to 49 U.S.C. § 60117(l), the Director, Western\nRegion, OPS (Director)3, issued a Notice of Proposed Safety Order (Notice) to Kinder Morgan\nInc. (KMI or Respondent)4 on December 28, 2018, alleging that the 12-inch EPT Pipeline had a\ncondition or conditions that posed a pipeline integrity risk to public safety, property, or the\nenvironment related to the Failure. The Notice alleged facts and circumstances that supported\nthe issuance of a Safety Order for the 12-inch EPT Pipeline or a portion thereof and proposed\nthat KMI’s SFPP take necessary corrective actions, including a pressure reduction to provide an\nadditional level of safety while the corrective actions were being completed.\nOn January 22, 2019, KMI responded to the Notice (Response). In the Response, KMI neither\n1 Kinder Morgan Energy Partners, LP, transports crude oil, refined petroleum products, and highly volatile liquids\nthrough more than 9,000 miles of pipelines in the United States. See\nhttps://www.kindermorgan.com/pages/business/products_pipelines/ (last accessed June 16, 2019).\n2 As discussed below, the volume of the release was updated to 11,000 barrels.\n3At the time of the Failure, Western Region had an Acting Director with the permanent Director position yet to be\nfilled.\n4 Kinder Morgan Energy Partners, LP, is a wholly-owned subsidiary of KMI.\n\n\n\nCPF No. 5-2018-5007S\nPage 2\ncontested the proposed findings or remedial requirements contained in the Notice nor requested\nan informal consultation under 49 C.F.R. § 190.239(b)(2), but provided an update on the work it\nwas in the process of completing or had completed to date to ensure the safe operation of the 12-\ninch EPT Pipeline. Additionally, Respondent did not request a hearing and therefore has waived\nits right to one. For the reasons stated below, I find continued operation of the 12-inch EPT\nPipeline without corrective measures would pose a pipeline integrity risk to public safety,\nproperty, or the environment. PHMSA hereby issues this Safety Order.\nFINDING OF PIPELINE INTEGRITY RISK\nRespondent did not contest the preliminary findings in the Notice that the 12-inch EPT Pipeline\nhas a condition or conditions that pose a pipeline integrity risk. Accordingly, pursuant to 49\nU.S.C. § 60117(1) and 49 C.F.R. § 190.239, I find as follows:\n• On December 14, 2018, at 0258 MST, KMI notified the National Response Center\n(NRC) of a release of gasoline from its 12-inch EPT Pipeline (LS-18) near Anthony, New\nMexico. PHMSA deployed two investigators to the scene of the accident and PHMSA\npersonnel were on-site from December 15, 2018, through December 21, 2018.\n• The Affected Segment is the 288-mile-long 12-inch EPT Pipeline, which delivers refined\npetroleum products westward from KMI’s El Paso Tank Farm to the company’s Tucson,\nArizona products terminal.5\n• Initial estimates by KMI to the NRC reported (NRC Reports # 1232949 and #1232959) a\nrelease of 6,000 barrels of gasoline from the 12-inch EPT Pipeline. The volume of\nreleased product was last updated in the Accident Report submitted to PHMSA (Form\nPHMSA F 7000.1) on March 25, 2019, to approximately 11,000 barrels. The release was\nin a north-south trending drainage ditch located to the east and parallel to 3 Saints Road\nin Dona Ana County, New Mexico (Failure Site). The ditch appears to discharge\neventually into the Rio Grande River; however, the drainage ditch was dry at the time of\nthe release and no gasoline entered the river or any environmentally sensitive areas.\n• The ruptured, east-west flowing 12-inch EPT Pipeline section was exposed at the bottom\nof an Elephant Butte Irrigation District (EBID) drainage ditch for approximately 25 feet.\nSpecifically, the upper half of the 12-inch EPT line was exposed to the atmosphere for\nthe entire width of the ditch. A second 8-inch-diameter SFPP pipeline lies parallel to the\n12-inch EPT Pipeline and was also visible at the bottom of the ditch. KMI reported the\n8-inch line to be purged and filled with inert nitrogen. A third, more recently installed,\n16-inch-diameter KMI pipeline is in the same right-of-way, carries refined product, and is\nbored under the drainage ditch.\n5 For the purposes of this Safety Order, the term \"Affected Segment\" means the entire SFPP 12-inch EPT Pipeline\nrunning from El Paso, Texas, to Tucson, Arizona, a distance of approximately 288 miles. The pipeline includes\nSFPP-designated line sections (LSs) generally known as LS-17 (portion west of the El Paso Breakout Tank Pump\nStation), LS-18 (failed segment), LS-19, LS-21, and LS-22.\n\n\n\nCPF No. 5-2018-5007S\nPage 3\n• The 12-inch EPT Pipeline consists of 1964-vintage steel pipe manufactured by US Steel.\nThe pipe is constructed of 0.188-inch-thick, rolled X-52 steel joined by high-frequency\nelectric resistance welded (HF-ERW) longitudinal pipe seams.\n• The pipeline utilizes an impressed cathodic protection system to guard against external\ncorrosion. A corrosion-control rectifier was located immediately to the northeast of the\nFailure Site. However, because the exposed pipeline that failed was in an above-ground\nspan that crossed an irrigation ditch, it could not be fully protected from corrosion by the\nimpressed current corrosion control system despite its proximity to a rectifier.\n• The pipe coating at the Failure Site appears to be a tape wrap coat; however, the specific\ncoating manufacturer is unknown. The portion of the coating exposed to the atmosphere\nand in the partially-buried pipeline segment appeared to be degraded and disbonded from\nthe steel pipe. This poor coating condition could have led to the creation of a corrosive\nenvironment or inhibited the effectiveness of the impressed cathodic protection system.\n• The release occurred from a longitudinal split approximately 22 to 24 inches long,\nlocated at the 5:30 o’clock position (looking downstream) of the pipe. The split appeared\nto be concurrent with an area of general external corrosion and the failure edges exhibited\nareas of pipe-wall thinning. The black-colored tape wrap was not adhered well to the\npipe, i.e., it appeared to be “disbonded.” Part of the circumference of the pipe opposite\nthe split appeared to have been painted yellow where it had originally been exposed to\nthe atmosphere.\n• An inline inspection (ILI) survey of the 12-inch EPT Pipeline was conducted in 2010 and\nagain in 2015, utilizing a high-resolution magnetic flux tool to detect metal loss.\nDeformation ILI surveys were conducted at the same time as the 2010 and 2015 ILI\nmetal loss surveys.\n• There were two previous repairs made immediately east of the rupture location and in the\nsame drainage ditch as the failure. They were reported by KMI to be two\n“ClockSpring®” wraps applied in 2011 over dents detected by KMI’s 2010 ILI survey.\nThese two repairs were conducted to (1) confirm the condition of a previously\n“undocumented” dent repair, and (2) repair a dent close to the undocumented repair.\n• The 2015 ILI survey noted external corrosion anomalies ranging from 13 to 17 percent in\ntotal wall thickness loss in the immediate vicinity of the rupture location. Preliminary\nvisual examination of the failed pipe segment, however, indicates wall thinning in the\nrupture area of the pipe. This overt thinning may indicate rapid external corrosion after\nthe 2015 ILI metal loss tool was run and resulting data analyzed.\n• While there was no fire, injuries or fatalities resulting from the release, local emergency\nofficials required the evacuation of three residences in the area. An “Unusually Sensitive\nArea” (USA), as defined by 49 C.F.R. § 195.6, and agricultural fields are located\nimmediately to the west of 3 Saints Road, as is the Rio Grande River, approximately one\nmile away.\n\n\n\nCPF No. 5-2018-5007S\nPage 4\n• While the Failure Site is not located directly in a USA, the release occurred on a segment\nthat “could affect” a USA, should water be flowing in the drainage ditch. Review of the\nPHMSA National Pipeline Mapping System (NPMS) indicates the 12-inch EPT Pipeline\ntraverses or is located within proximity to numerous High Consequence Areas (HCAs),\nincluding USAs. There are numerous portions of the EPT Pipeline system that could\naffect an HCA, as defined by 49 C.F.R. § 195.450.\n• The mainline valves on both sides of the Failure Site are manually-operated valves\n(MOVs) and are near the same elevation as the drainage ditch. The topography of the\narea indicates that the pipeline descends approximately 900 vertical feet from the east\ndownwards and towards the Failure Site. Much smaller elevation changes occur between\nthe MOV to the west and the Failure Site. PHMSA anticipates that a large percentage of\nthe released volume of gasoline was a result of the pipeline draining down from the\nhigher areas to the east. (Note: The 12-inch-diameter pipeline contains approximately\n785 barrels of line fill per mile of length).\n• This line provides refined products to Tucson, Arizona, and other State of Arizona\npetroleum markets.\n• The PHMSA investigation is ongoing and the causal factors of the Failure are unknown\nat this time.\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 aggressive external corrosion in\nexposed pipeline areas and exhibited areas of pipe-wall thinning; the degraded tape wrap coating\nor ineffective cathodic protection; the potential rate of corrosion exceeding maximum time\nintervals allowed by 49 C.F.R. Part 195; the location of the Failure Site, including its proximity\nto numerous HCAs, rivers, streams, and other pathways to water; the hazardous nature of the\nmaterial transported; and the investigation to determine the cause of the failure, I find that the\n12-inch EPT Pipeline has a condition or conditions that pose a pipeline integrity risk to public\nsafety, property, or the environment. Accordingly, PHMSA issues this Safety Order, which\nrequires that Respondent take measures specified below to address the risk.\nCORRECTIVE MEASURES\nThe Notice proposed certain corrective measures with respect to the Affected Segment. As\ndescribed below, KMI has completed certain actions relating to Items 1, 3, 4, 5, 6, 7 and 11. As\n\n\n\nCPF No. 5-2018-5007S\nPage 5\nfor the remaining compliance terms, pursuant to 49 U.S.C. § 60117(1) and 49 C.F.R. § 190.239,\nKMI must take the following remedial requirements with respect to the Affected Segment:\n1. 2. 3. 4. Pressure Restriction. Continue to maintain a pressure restriction of 80 percent of the\noperating pressure at the time of the accident for the 12-inch EPT Pipeline sections\ndesignated LS-17 (6.56 miles) and LS-18 (85.69 mile). LS-17 and LS-18 are located\nbetween the SFPP El Paso, Texas Breakout Tank Farm and the Deming, New Mexico\npump station.\nRemoval of Pressure Restriction. The Director may allow the removal or modification\nof the pressure restriction described above upon a written request from Respondent\ndemonstrating that restoring the 12-inch EPT Pipeline to its pre-failure operating\npressure is justified, based on a reliable engineering analysis showing that the pressure\nincrease is safe, considering all known defects, anomalies, and operating parameters of\nthe pipeline. The Director's determination will be based on the information provided by\nthe ongoing failure investigation, including the metallurgical testing results mandated in\nItem 3 below.\nMechanical, Metallurgical and other Testing. On March 4, 2019, KMI issued a final\nmetallurgical report, which PHMSA is currently reviewing. Until the Director\ndetermines this item has been completed, the terms of this order are as follows. Within\n60 days of receipt of this Safety Order, Respondent must complete mechanical, coating,\nand metallurgical testing of the failed pipe segment by a third party independent testing\nlaboratory. Additionally, the Respondent must complete in-situ soil testing. The\nresults must be summarized in a written analysis. Testing and analysis requirements\nare as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the Failure Site;\nb. Utilize the testing protocol provided by PHMSA;\nc. Prior to beginning the mechanical and metallurgical testing, provide the\nDirector with the scheduled date, time, and location of the testing to allow for\nan OPS representative to witness the testing; and\nd. Ensure that the testing laboratory distributes all reports, whether draft or final,\nin their entirety to the Director at the same time they are made available to\nRespondent.\nUse of Appropriate ILI Tool. KMI completed ILI surveys in February 2019. While\nthe ILI surveys were conducted utilizing a high resolution Magnetic Flux Leakage tool\ncoupled with a deformation tool prior to completing the metallurgical failure analyses,\nKMI has shown these were the correct tools to assess similar pipe conditions that\ncaused the failure. Accordingly, KMI has completed the requirements of this item.\n\n\n\nCPF No. 5-2018-5007S\nPage 6\n5. 6. 7. 8. 9. Immediate-Repair Conditions. KMI has confirmed that there were no “immediate\nrepair-conditions” identified by the ILI that met the proposed repair criteria and that all\nthe other immediate repair conditions as defined by § 195.452(h) have been repaired.\nAccordingly, KMI has completed the requirements of this item.\nSurvey of Exposed Pipeline Crossings. KMI completed a survey of exposed crossings\nand identified 18 sites for further review. Resolution of the exposed pipe areas by KMI\nper Corrective Measures 1 and 2 are under review by PHMSA. Until the Director\ndetermines this item has been completed, the terms of this order are as follows.\nComplete a survey of all exposed pipeline crossings of the 12-inch EPT Pipeline within\n90 days of receipt of this Safety Order, and identify any segments where the existing\ncoating is 1) not appropriate for above-ground use, and 2) in areas where the pipeline\nsegment should be lowered to provide external-damage protection and cathodic\nprotection.\nUpdated Emergency Flow Restricting Devices (EFRD) Study. KMI provided an\nEFRD analysis to PHMSA in April 2019. PHMSA is currently evaluating the\nsubmittal. Until the Director determines this item has been completed, the terms of this\norder are as follows. Complete and submit within 120 days of receipt of this Safety\nOrder an updated EFRD study (per § 195.452(i)(4)) for areas where a spill from the 12-\ninch EPT Pipeline could affect an HCA (as defined by § 195.450). The revised EFRD\nstudy shall identify where existing valves can be remotely actuated so that closure of a\nmainline valve to isolate the pipeline can commence within 15 minutes of a confirmed\nrupture.\nRoot Cause Failure Analysis. Within 180 days following receipt of this Safety Order,\ncomplete a root cause failure analysis (RCFA) and submit a final report of the RCFA to\nthe Director. The RCFA must document the decision-making processes and all factors\ncontributing to the Failure, including all findings revealed from Corrective Measures 3,\n4, 6, and 7 above. The final report must include findings and lessons learned. The\nRCFA must also include a discussion of whether the findings and lessons learned are\napplicable to other locations within the 12-inch EPT Pipeline system.\nRemedial Work Plan. Within 45 days following receipt of the Root Cause Failure\nReport, Respondent must submit a Remedial Work Plan (RWP) to the Director for\napproval. The Director may approve the RWP incrementally without approving the\nentire RWP. Once approved by the Director, the RWP will be incorporated by\nreference into this Safety Order. The RWP must:\na) Specify the tests, inspections, assessments, evaluations, and remedial measures\nRespondent will use to verify the integrity of the 12-inch EPT Pipeline. It must\naddress all known or suspected factors and causes of the Failure. Respondent\nshould consider both the risk and consequence of another failure to develop a\nprioritized schedule for RWP-related work along the Affected Segment;\n\n\n\nCPF No. 5-2018-5007S\nPage 7\nb) A schedule to assess and remediate any pipeline anomalies where metal loss\nexceeds the criteria of § 195.452(h), and are not immediate repairs, as defined in\nCorrective Measure 5;\nc) An implementation schedule to recoat any exposed pipeline crossing where there\nis degraded coating or the coating is not appropriate for protection the pipeline\nagainst atmospheric corrosion; and\nd) Integrate the results of the metallurgical testing, root cause failure analysis, and\nother corrective actions required by this Safety Order with all relevant pre-\nexisting operational and assessment data for the 12-inch EPT Pipeline. Pre-\nexisting operational data includes, but is not limited to, construction, operations,\nmaintenance, testing, repairs, and prior metallurgical analyses. Pre-existing\nassessment data includes, but is not limited to, in-line inspection (ILI) tool runs,\nhydrostatic pressure testing, direct assessments, atmospheric corrosion surveys,\nexposed crossing surveys, close interval surveys, and DCVG/ACVG surveys.\n10. Revisions to the RWP. Revise the RWP as necessary to incorporate new information\nobtained during the implementation of the RWP as approved the Director.\n11. Quarterly Reports. Continue to submit quarterly reports to the Director that: (1)\ninclude available data and results of the testing and evaluations required by this Safety\nOrder; and (2) describe the progress of the repairs and other remedial actions being\nundertaken.\nWith respect to each submission under this Safety Order that requires the approval of the\nDirector, the Director may: (a) approve, in whole or part, the submission; (b) approve the\nsubmission on specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove, in whole or in part, the submission, directing that Respondent modify the\nsubmission; or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall take all required actions in the\nsubmission as approved or modified by the Director. If the Director disapproves all or any\nportion of the submission, Respondent shall correct all deficiencies within the time specified by\nthe Director, and resubmit it for approval. If a resubmitted item is disapproved in whole or in\npart, the Director may again require Respondent to correct the deficiencies in accordance with\nthe foregoing procedure, and the Director may otherwise proceed to enforce the terms of this\nSafety Order.\nIt is requested (not mandated) that Respondent maintain documentation of the safety\nimprovement costs associated with fulfilling this Safety Order and submit the total to the\nDirector. It is requested that these costs be reported in two categories: (1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated\nwith replacements, additions and other changes to pipeline infrastructure.\nThe Director may grant an extension of time for compliance with any of the terms of this Safety\nOrder upon a written request timely submitted demonstrating good cause for an extension. KMI\nmay appeal any decision of the Director to the Associate Administrator for Pipeline\n\n\n\nCPF No. 5-2018-5007S\nPage 8\nSafety. Decisions of the Associate Administrator shall be final.\nIn your correspondence on this matter, please refer to CPF No. 5-2018-5007S and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nBe advised that all materials 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).\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 49\nC.F.R. § 190.5.\nAugust 8, 2019\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520185007S_Notice of Proposed Safety Order_12282018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 28, 2018\nMr. Richard D. Kinder\nExecutive Chairman\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nCPF 5-2018-5007S\nDear Mr. Kinder:\nEnclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case to\nyour subsidiary, Santa Fe Pacific Pipeline Partners, LP (SFPP). The Notice proposes that SFPP\ntake certain measures with respect to SFPP’s El Paso-to-Tucson 12-inch refined products pipeline.\nThese measures are needed to ensure public safety and to protect the environment. SFPP’s options\nfor responding are set forth in the Notice. Your receipt of the Notice constitutes service of that\ndocument under 49 C.F.R. § 190.5.\nWe look forward to a successful resolution of this matter to ensure pipeline safety. Please direct\nany questions on this matter to me at (720) 963-3160.\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Notice of Proposed Safety Order\n\n\n\ncc: Mr. Alan K. Mayberry, Associate Administrator for Pipeline Safety, OPS\nMs. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Wayne Simmons, Chief Operating Officer, Kinder Morgan, Inc.\nMr. Edward Fant, Compliance Director, Kinder Morgan, Inc.\n2\n\n\n\n3\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\n____________________________________\nIn the Matter of )\nSanta Fe Pacific Pipeline Partners, LP, ) CPF No. 5-2018-5007S\na subsidiary of Kinder Morgan, Inc., )\n)\n)\n)\nRespondent )\n____________________________________)\nNOTICE OF PROPOSED SAFETY ORDER\nBackground and Purpose\nPursuant to Chapter 601 of Title 49, United States Code, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), has initiated an investigation\ninto the safety of Santa Fe Pacific Pipeline Partners, LP’s (SFPP or Respondent) 12-inch-\ndiameter El Paso-to-Tucson (12-inch EPT) Pipeline following a gasoline release in Dona Ana\nCounty, near Anthony, New Mexico. The pipeline ruptured and spilled approximately 6000\nbarrels of gasoline into a drainage ditch at approximately 2348 MST on December 13, 2018\n(Failure). SFPP operates the SFPP 12-inch EPT Pipeline as a subsidiary of Kinder Morgan, Inc.\n(KMI).\nBased on our preliminary investigation, it appears that conditions potentially related to the cause\nof the Failure may exist on other segments of the 12-inch EPT Pipeline. PHMSA believes these\nconditions may pose similar pipeline integrity risks to public safety, property or the environment\nalong other portions of the 12-inch EPT Pipeline right-of-way (ROW). Pursuant to 49 U.S.C.\n§ 60117(l), PHMSA issues this Notice of Proposed Safety Order (Notice), notifying you of the\npreliminary findings of the investigation and proposing that you take immediate and near-term\nmeasures to ensure that public safety, property, and the environment are protected from the\npotential integrity risks.\nFor the purposes of this Notice, the term “Affected Pipeline” means the entire SFPP 12-inch EPT\nPipeline running from El Paso, Texas, to Tucson, Arizona, a distance of approximately 288 miles.\nThe pipeline includes SFPP-designated line sections (LS) generally known as LS-17, LS-18 (failed\nsegment), LS-19, LS-21, and LS-22.\nPreliminary Findings:\n• On December 14, 2018, at 0258 MST, KMI notified the National Response Center\n(NRC) of a release of gasoline from its 12-inch EPT Pipeline (LS-18) near Anthony, New\n\n\n\n4\nMexico. PHMSA deployed two investigators to the scene of the accident and PHMSA\npersonnel were on-site from December 15, 2018, through December 21, 2018.\n• The 288-mile-long, 12-inch EPT Pipeline delivers refined petroleum products westward\nfrom KMI’s El Paso Tank Farm to the company’s Tucson, Arizona products terminal.\n• Initial estimates by KMI to the NRC reported (NRC Reports # 1232949 and #1232959) a\nrelease of 6000 barrels of gasoline from the 12-inch EPT Pipeline. The release was in a\nnorth-south trending drainage ditch located to the east and parallel to 3 Saints Road in\nDona Ana County, New Mexico (Failure Site). The ditch appears to discharge eventually\ninto the Rio Grande River; however, the drainage ditch was dry at the time of the release\nand no gasoline entered the river or any environmentally sensitive areas.\n• While there was no fire, injuries or fatalities resulting from the release, local emergency\nofficials required the evacuation of three residences in the area. An “Unusually Sensitive\nArea” (USA), as defined by 49 CFR § 195.6, and agricultural fields are located\nimmediately to the west of 3 Saints Road, as is the Rio Grande River, approximately one\nmile away.\n• The ruptured, east-west flowing 12-inch EPT pipe section was exposed at the bottom of\nthe drainage ditch for approximately 25 feet. Specifically, the upper half of the 12-inch\nEPT line was exposed to the atmosphere for the entire width of the ditch. A second 8-\ninch-diameter SFPP pipeline lies parallel to the 12-inch EPT Pipeline and was also\nvisible at the bottom of the ditch. KMI reported the 8-inch line to be purged and filled\nwith inert nitrogen. A third, more recently installed, 16-inch-diameter KMI pipeline is in\nthe same ROW, carries refined product, and is bored under the drainage ditch.\n• The 12-inch EPT Pipeline consists of 1964-vintage steel pipe manufactured by US Steel.\nThe pipe is constructed of 0.188-inch-thick, rolled X-52 steel joined by high-frequency\nelectric resistance welded (HF-ERW) longitudinal pipe seams.\n• The pipeline utilizes an impressed cathodic protection system to guard against external\ncorrosion. A corrosion-control rectifier was located immediately to the northeast of the\nFailure Site. At this time, PHMSA has not confirmed which pipeline(s) the rectifier was\nprotecting from external corrosion.\n• The pipe coating at the Failure Site appears to be a tape wrap coat; however, the specific\ncoating manufacturer is unknown. The portion of the coating exposed to the atmosphere\nand in the partially-buried pipeline segment appeared to be degraded and disbonded from\nthe steel pipe. This poor coating condition could have led to the creation of a corrosive\nenvironment or inhibited the effectiveness of the impressed cathodic protection system.\n• The release occurred from a longitudinal split approximately 22 to 24 inches long,\nlocated at the 5:30 o’clock position (looking downstream) of the pipe. The split appeared\nto be concurrent with an area of general external corrosion and the failure edges exhibited\nareas of pipe-wall thinning. The black-colored tape wrap was not adhered well to the\n\n\n\n5\npipe, i.e., it appeared to be “disbonded.” Part of the circumference of the pipe opposite\nthe split appeared to have been painted yellow where it had originally been exposed to\nthe atmosphere.\n• An inline inspection (ILI) survey of the 12-inch EPT Pipeline was conducted in 2010 and\nagain in 2015, utilizing a high-resolution magnetic flux tool to detect metal loss.\nDeformation ILI surveys were conducted at the same time as the 2010 and 2015 ILI\nmetal loss surveys.\n• There were two previous repairs made immediately east of the rupture location and in the\nsame drainage ditch as the failure. They were reported by KMI to be two “ClockSpring\n®” wraps applied in 2011 over dents detected by KMI’s 2010 ILI survey. These two\nrepairs were conducted to 1) confirm the condition of a previously “undocumented” dent\nrepair, and 2) repair a dent close to the undocumented repair.\n• The 2015 ILI survey noted external corrosion anomalies ranging from 13 to 17 percent in\ntotal wall thickness loss in the immediate vicinity of the rupture location. Preliminary\nvisual examination of the failed pipe segment, however, indicates wall thinning in the\nrupture area of the pipe. This overt thinning may indicate rapid external corrosion after\nthe 2015 ILI metal loss tool was run and resulting data analyzed.\n• The Failure Site is not located directly in a USA, but the accident occurred on a segment\nthat “could affect” a USA, should water be flowing in the drainage ditch. Review of the\nPHMSA National Pipeline Mapping System (NPMS) indicates the 12-inch EPT Pipeline\ntraverses or is located within proximity to numerous High Consequence Areas (HCAs),\nincluding USAs. PHMSA believes that there are numerous portions of the EPT Pipeline\nsystem that could affect an HCA, as defined by 49 CFR §195.450.\n• The mainline valves on both sides of the Failure Site are manually-operated valves\n(MOVs) and are near the same elevation as the drainage ditch. The topography of the\narea indicates that the pipeline descends approximately 900 vertical feet from the east\ndownwards and towards the Failure Site. Much smaller elevation changes occur between\nthe MOV to the west and the Failure Site. PHMSA anticipates that a large percentage of\nthe released volume of gasoline was a result of the pipeline draining down from the\nhigher areas to the east. (Note: The 12-inch-diameter pipeline contains approximately\n785 barrels of line fill per mile of length).\n• This line is critical for refined product supply to Tucson, Arizona, and other State of\nArizona petroleum markets. Kinder Morgan informed PHMSA staff that because of the\nhigher pressures needed to move product over mountainous terrain west of Deming, New\nMexico, that their ability to reduce operating pressure and still be able to deliver product\nto Tucson is limited on LS-19, LS-21, and LS-22.\n• Based on the Preliminary Findings set forth above, PHMSA believes that the following\nrisks must be promptly addressed on the 12-inch EPT Pipeline:\n\n\n\n6\n1. 2. 3. 4. 5. The occurrence of highly aggressive corrosion in exposed pipeline areas where\ndegraded tape wrap coating or ineffective cathodic protection may lead to corrosion-\ninduced failure;\nThe rate of corrosion growth that may exceed the operator’s ability to identify and\nrespond using ILI surveys that are conducted at operator determined intervals which\ncoincide with maximum time intervals allowed by CFR Part 195;\nThe relatively thin-wall pipe in the 12-inch EPT Pipeline system has very limited\nability to withstand aggressive corrosion and still maintain safe containment at\nnormal operating pressures established by original design and testing;\nDynamic erosion caused by the topography, geology, and climate which may result in\nother pipeline segments of the 12-inch EPT Pipeline being unintentionally exposed,\nthereby rendering the designed corrosion-control systems ineffective; and\nProximity to numerous HCAs, rivers, streams, and other pathways for spill migration\ncoupled with the time required to close the MOVs in order to isolate the pipeline\nfollowing a confirmed rupture or release.\nProposed Issuance 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 that may include\nphysical inspection, testing, repair, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility has a condition or conditions that pose a pipeline integrity\nrisk to public safety, property, or the environment is set forth both in the above-referenced statute\nand 49 C.F.R. § 190.239, a copy of which is enclosed.\nAccordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the\nproposed issuance of a safety order and to propose that Respondent take measures specified herein\nto address the potential risks identified in the Preliminary Findings and other risks that may be\ndetermined as a result of the proposed corrective measures.\nProposed Corrective Measures\nPursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, PHMSA proposes to issue to SFPP a\nsafety order incorporating the following remedial requirements with respect to the company’s 12-\ninch EPT Pipeline. SFPP must take the following corrective measures:\n1. Pressure Restriction. Maintain a pressure restriction of 80% of the operating pressure at\nthe time of the accident for the SFPP 12-inch EPT Pipeline sections designated LS- 17\n\n\n\n7\n2. 3. 4. 5. (6.56 miles) and LS-18 (85.69 mile). LS 17 and LS -18 are located between the SFPP El\nPaso, Texas Breakout Tank Farm and the Deming, New Mexico pump station.\nRemoval of Pressure Restriction. The Director may allow the removal or modification\nof the pressure restriction described above upon a written request from Respondent\ndemonstrating that restoring the SFPP 12-inch EPT Pipeline to its pre-failure operating\npressure is justified, based on a reliable engineering analysis showing that the pressure\nincrease is safe, considering all known defects, anomalies, and operating parameters of\nthe pipeline. The Director's determination will be based on the information provided by\nthe ongoing failure investigation, including the metallurgical testing results mandated in\nitem 3 below.\nMechanical, Metallurgical and other Testing. Within 60 days of receipt of this Safety\nOrder, Respondent must complete mechanical, coating, and metallurgical testing of the\nfailed pipe segment by a third party independent testing laboratory. Additionally, the\nRespondent must complete in-situ soil testing. The results must be summarized in a\nwritten analysis. Testing and analysis requirements are as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the Failure Site;\nb. Utilize the testing protocol provided by PHMSA;\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director\nwith the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing; and\nd. Ensure that the testing laboratory distributes all reports, whether draft or final, in\ntheir entirety to the Director at the same time they are made available to\nRespondent.\nUse of Appropriate ILI Tool. Conduct a survey with an ILI tool that best characterizes\nthe failed anomaly as determined by the metallurgical testing (See Corrective Measure -\nItem 3). The ILI must be conducted within 90 days of receipt of this Safety Order and\npreliminary results received from the ILI vendor analysts within 3","truncated":true,"body_characters":49857}