EL PASO NATURAL GAS CO — Warning Letter

party submissionOfficial PDF520191001W_Operator Response to Notice_04172019.pdf#

520191001W_Warning Letter_01182019_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 18, 2019 Mr. Tom Martin President, Natural Gas Pipelines Kinder Morgan 1001 Louisiana Street, Suite 1000 Houston, TX 77002-5089 CPF 5-2019-1001W Dear Mr. Martin: During the weeks of April 17 through 24, April 24 through 28, and August 14 through 18, 2017, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected your El Paso Natural Gas Pipeline, Waha Complex facilities in New Mexico and Texas. Based on our inspection findings, PHMSA determined that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR), Part 192. The deficiencies noted and the probable violations are: 1. §192.736 Compressor stations: Gas detection. (c) Each gas detection and alarm system required by this section must be maintained to function properly. The maintenance must include performance tests. Kinder Morgan (KM) personnel did not adequately inspect their gas detection and alarm system at two of their compressor stations to ensure that they are being maintained to function properly. Kinder Morgan specified an inspecting and testing interval for these systems in their Operations and Maintenance (O&M) manual as required by 192.605(a). KM maintenance records indicate#

520191001W_Warning Letter_01182019_text.pdf, page 2that they have not followed their procedure in accordance with their O&M Manual, specifically the mandated testing activites for their gas detection system. Kinder Morgan's Procedure 550, Testing of Gas and Fire Detection Systems, requires that interval testing of the gas detection system be conducted at least four (4) times each calendar year, not to exceed 4.5 months. Prior to 2014, the gas detection frequency was established to be conducted annually. A review of the gas detection testing records indicated that Kinder Morgan personnel did not conduct the performance tests at the revised frequency, as established by Procedure 550. Examples of non compliance were found at the following locations: • Puckett Compressor Station - Gas detection testing records provided for calendar year 2014 documented an actual finish date of 2013. No other testing records demonstrating completion in calendar year 2014 were provided. • Wink Compressor Station - Gas detection testing records for calendar year 2014 indicated the second and third quarterly testing occurred on the same date in August. The records provided indicate inspection and testing dates were performed on 5/1/14, 8/19/14, and 12/24/14. Therefore, personnel failed to test the hazardous gas detector at the Wink Compressor Station four times per calendar year, per the procedure. Additionally, KM was not properly maintaining the gas detection alarm systems at the compressor stations. Kinder Morgan's procedure requires that the high-level detectors in compressor buildings be set to alarm at a high-level set point of 30-40% of the Lower Explosive Limit (LEL). Records for the Wink Compressor Station for calendar years 2015, 2016, and through May 2017 indicated that the high-level alarms were set higher than the level established by the procedure. Records reviewed indicated the high-level alarms had been set above 40% of the LEL, sometimes as high as 50% of the LEL. 2. §192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures and conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Kinder Morgan's annual review and update of their procedural manual appears inadequate. The procedural manual is required by 192.605(e) to include procedures that address Continuing Surveillance, as prescribed in 192.613(a). Kinder Morgan records provided during the inspection could not substantiate that all activities in Procedure #218 for Continuing Surveillance were included in the annual review for calendar years 2014, 2015, and 2016. 2#

520191001W_Warning Letter_01182019_text.pdf, page 33. §192.745 Valve maintenance: Transmission lines. (a) Each transmission line valve that might be required during any emergency must be inspected and partially operated at intervals not exceeding 15 months, but at least once each calendar year. Kinder Morgan records reviewed could not demonstrate that the required valve maintenance was completed for each valve on the Waha Complex transmission pipeline facilities. A review of the records indicated the following apparent non-compliances: • Line 3161: Valve inspection records for 2013 indicate different valve equipment descriptions as the valve inspection records for 2014, 2015, and 2016. There was no indication on anv of the records that valves had been replaced or re-numbered. Additionally, the 2016 valve maintenance records did not provide the valve size, manufacturer, or description in order to cross reference to the 2013, 2014, and 2015 records. • Line 3173: Valve inspection records provided for block valves #0 and #1 did not contain inspection dates or the names of the individuals conducting the valve inspection. Based on the inconsistent recordkeeping, and lack of information/traceability contained within the records, compliance with 49 CPR§ 192.745(a) could not be determined. 4. §192.705 Transmission lines: Patrolling. (b) The frequency of patrols is determined by the size of the line, the operating pressures, the class location, terrain, weather, and other relevant factors, but intervals between patrols may not be longer than prescribed in the following table: Maximum interval between patrols Class location ofline At highway and railroad crossings At all other places 1, 2 7½ months; but at least twice each calendar year 15 months; but at least once each calendar year. 3 4½ months; but at least four times each calendar year 7½ months; but at least twice each calendar year. 4 4½ months; but at least four times each calendar year 4½ months; but at least four times each calendar year. 3#

520191001W_Warning Letter_01182019_text.pdf, page 4Kinder Morgan did not patrol all of the line section crossings at the required patrol frequency. The records reviewed during the inspection revealed the following line section exceeded the maximum time interval between patrols: Line 3153: Calendar Year 2014: Kinder Morgan did not perform patrolling on their highway and railroad crossings in their Class 1 locations, twice per calendar year, not to exceed (NTE) 7.5 months. The records revealed that this line segment was only patrolled once in May 2014. No records were provided to demonstrate a second patrol occurred in 2014. Calendar Year 2016: Kinder Morgan did not perform patrolling on all of their highway and railroad crossings in their Class 1 locations, twice per calendar year, NTE 7.5 months. The 2016 patrol records indicate this segment was only patrolled on 12/12/2016. 5. §192.807 Recordkeeping. (b) Records supporting an individual's current qualification shall be maintained while the individual is performing the covered task. Records of prior qualifications and records of individuals no longer performing covered tasks shall be retained for a period of five years. Kinder Morgan did not maintain records for all individuals performing covered tasks at the Wink Compressor Station. We understand that Kinder Morgan used contractor personnel to perform annual inspections on the over pressure protection relief devices, but was unable to provide records to demonstrate that the contracted individuals were qualified to perform the covered task in calendar years 2015 and 2016. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related series of violations. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the items identified in this letter. Failure to do so will result in Kinder Morgan being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 5-2019-1001W. 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 4#

520191001W_Warning Letter_01182019_text.pdf, page 5you 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). Sincerely Chris Hoidal Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 D.Fehling (#155198) 5#