{"operation":"document","citation":"CPF 520191004W","title":"EL PASO NATURAL GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-18","effective_on":null,"summary":"CLOSED warning letter citing 192.479(a), 192.481(a), 192.481(b), 192.605(a), 192.615(c)(1), 192.705(a), 192.705(b), 192.709(c), 192.731(a), 192.736(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520191004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520191004W","body":"Warning Letter involving EL PASO NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.479(a),  192.481(a),  192.481(b),  192.605(a),  192.615(c)(1),  192.705(a),  192.705(b),  192.709(c),  192.731(a),  192.736(c). The case was opened on 2019-01-18 and is reported as closed as of 2019-01-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520191004W_Operator Response to Notice_04172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191004W/520191004W_Operator%20Response%20to%20Notice_04172019.pdf\n\n520191004W_Warning Letter_01182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191004W/520191004W_Warning%20Letter_01182019.pdf\n\n520191004W_Warning Letter_01182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520191004W/520191004W_Warning%20Letter_01182019_text.pdf\n\n520191004W_Warning Letter_01182019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 18, 2019\nMr. Tom Martin\nPresident, Natural Gas Pipelines\nKinder Morgan\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002-5089\nCPF 5-2019-1004W\nDear Mr. Martin:\nDuring the weeks of April 17 through 21, April 24 through 28, July 10 through 14, and July 17\nthrough 21, 2017, representatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected your El Paso\nNatural Gas Pipeline, El Paso-Pecos River Facilities, in New Mexico and Texas.\nBased on our inspection findings, PHMSA determined that you have committed probable\nviolations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR), Part\n192. The deficiencies noted and the probable violations are:\n\n\n\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures and conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nKinder Morgan did not review and update their procedural manual for operations, maintenance,\nand emergencies, in accordance with §192.605(a). Kinder Morgan was unable to provide\ndocumentation or records which demonstrated a review of the emergency manual occurring in\ncalendar years 2014 and 2015, for the El Paso-Pecos River Unit, which is part of the Deming\nOperating Area.\n2. §192.615 Emergency Plans.\n(c) Each operator shall establish and maintain liaison with appropriate fire, police,\nand other public officials to:\n(1) Learn the responsibility and resources of each government organization that\nmay respond to a gas pipeline emergency;\nWhile reviewing records for calendar years 2014 through 2016, it was determined that the\nKinder Morgan did not establish and maintain liaisons with public officials. Only records\ndemonstrating liaisons with emergency responders were provided during the inspection.\n3. §192.731 Compressor stations: Inspection and testing of relief devices.\n(a) Except for rupture discs, each pressure relieving device in a compressor station\nmust be inspected and tested in accordance with §192.739 and §192.743, and must\nbe operated periodically to determine that it opens at the correct set pressure.\nKinder Morgan did not follow its written procedure for pressure relief devices in compressor\nstations. Pursuant to Kinder Morgan's Operations and Maintenance Manual, Section 3.3.2.2,\nProcedure #703 Pressure Limiting and Relief Devices Inspections: \"All unit relief valves and all\npressure-limiting devices shall be set no higher than 107% of mainline MAOP.\" While reviewing\nthe calendar year 2014 inspection records for the Cornudus Compressor Station (Asset #122622,\nPM56863), it was discovered that the relief valve was set to 990 pounds per square inch (psi) in\n2014, well above the maximum allowable operating pressure (MAOP) of 600 psi. This set\npressure was higher than the operator's procedural allowance of 107% of mainline MAOP.\n2\n\n\n\n4. §192.736 Compressor stations: Gas detection.\n(c) Each gas detection and alarm system required by this section must be\nmaintained to function properly. The maintenance must include performance tests.\nKinder Morgan personnel did not adequately inspect their gas detection and alarm system at four\nof their compressor stations to ensure that they are being maintained to function properly. Kinder\nMorgan specified an inspecting and testing interval for these systems in their Operations and\nMaintenance (O&M) manual as required by 192.605(a). Kinder Morgan maintenance records\nindicate that they have not followed their procedure in accordance with their O&M Manual,\nspecifically the mandated testing activities for their gas detection system.\nKinder Morgan's Procedure 550, Testing of Gas and Fire Detection Systems, requires that\ninterval testing of the gas detection system be conducted at least four (4) times each calendar\nyear, not to exceed 4.5 months. Prior to 2014, the gas detection frequency was established to be\nconducted annually.\nA review of the gas detection testing records indicated that Kinder Morgan personnel did not\nconduct the performance tests at the revised frequency, as established by Procedure 550.\nExamples of non-compliance were found at the following locations:\n• Pecos River Compressor Station-Testing of the gas detection system was only\nperformed once in 2014.\n• El Paso Compressor Station-Testing of the gas detection system was only performed 3\ntimes in 2015 (6//10/15, 11/30/15, and 12/1/15).\n• Hueco Compressor Station - Testing of the gas detection system was only performed 3\ntimes in 2015 (7/11/15, 9/21/15, and 11/18/15).\n• Afton Compressor Station-Testing of the gas detection system was only performed 3\ntimes in 2015 (5/20/15, 9/23/15, and 11/9/15).\n5. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts Land\nM of this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\nKinder Morgan was unable to provide records that demonstrated compliance for continuing\nsurveillance in calendar year 2014, in accordance with their procedure O&M Manual, Procedure\n#218 - Continuing Surveillance, and §192.613(a).\n3\n\n\n\n6. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures and conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nKinder Morgan's annual review and update of their procedural manual appears inadequate. The\nprocedural manual is required by 192.605(e) to include procedures that address Continuing\nSurveillance, as prescribed in 192.613(a). Kinder Morgan records provided during the inspection\ncould not substantiate that all activities in Procedure #218 for Continuing Surveillance were\nincluded in the annual review for calendar years 2015 and 2016.\n7. §192.705 Transmission lines: Patrolling.\n(a) Each operator shall have a patrol program to observe surface conditions on and\nadjacent to the transmission right-of-way for indications of leaks, construction\nactivity, and other factors affecting safety and operation.\n(b) The frequency of patrols is determined by the size of the line, the operating\npressures, the class location, terrain, weather, and other relevant factors, but\nintervals between patrols may not be longer than prescribed in the following table:\nMaximum interval between patrols\nClass\nlocation\nof line\nAt highway and railroad\ncrossings At all other places\n1, 2 7½ months; but at least twice\neach calendar year\n15 months; but at least once\neach calendar year.\n3 4½ months; but at least four\ntimes each calendar year\n7½ months; but at least twice\neach calendar year.\n4 4½ months; but at least four\ntimes each calendar year\n4½ months; but at least four\ntimes each calendar year.\nKinder Morgan did not patrol four times each calendar year, at highway and railroad crossings\nfor Class Location 3, during the calendar year 2016 for Line 1600 (Comudus to Florida Station).\nThe operator only patrolled three times (4/26/16, 7/25/16, and 11/29/16) for segment MP\n199+4217 to MP 205+5013.\n4\n\n\n\nPatrolling records on Lines 1100, 1103, and 1110, for calendar year 2014 through June of 2017,\ndid not demonstrate that Kinder Morgan patrolled road crossings at two locations, Highway 285\nand Highway 652. Calendar year 2014 patrolling records for Class Locations 1 and 2, on Lines\n1100 and 1103, did not document dates on either interval. Due to incomplete records,\ncompliance could not be demonstrated.\n8. §192.479 Atmospheric corrosion control: General\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\nKinder Morgan did not clean and coat pipelines or portions of pipelines that were exposed to the\natmosphere at the following locations:\n• Line 3191, Valve#l\n• Washington Ranch Compressor Station: multiple areas of no coating and/or poor coating,\nincluding nuts, bolts, and flanges.\n9. §192.481 Atmospheric corrosion control: Monitoring\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to\nthe atmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is\nlocated: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but with\nintervals not exceeding 39 months\nOffshore At least once each calendar year, but with intervals\nnot exceeding 15 months\nKinder Morgan personnel failed to identify and inspect multiple areas of aboveground pipe,\nexposed to the atmosphere, for evidence of atmospheric corrosion, including the following\nlocations:\n• Pecos River Compressor Station: Multiple below grade pit type structures were observed\nat the station. Kinder Morgan field staff were not aware of these pit locations and stated\nthe locations were not on the atmospheric corrosion inspection list.\n• Old taps for Lines 2034 and 2058 at the 3 Hills Meter Station. These active lines are not\nincluded on the atmospheric corrosion inspection list.\n5\n\n\n\n10. §192.481 Atmospheric corrosion control: Monitoring\n(b) During inspections the operator must give particular attention to pipe at soil-to-\nair interfaces, under thermal insulation, under disbonded coatings, at pipe supports,\nin splash zones, at deck penetrations, and in spans over water.\nKinder Morgan did not give particular attention to pipe at soil to air interfaces during\ninspections, in accordance with §192.481(b). Multiple areas were found to have disbonded wrap\nand/or damaged wrap at the interfaces, including the following locations:\n• Cornudus Station, Line 1103: cracked wrap with bare steel showing.\n• Hueco Station, Line 1100: improper wrap, areas of bare steel.\n• Line 3191 at Valve #1: wrap in disrepair.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a\nrelated series of violations. For violations occurring prior to November 2, 2015, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the items identified in\nthis letter. Failure to do willresult in Kinder Morgan being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2019-1004W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D.Fehling (#155197)\n6","truncated":false,"body_characters":13461}