{"operation":"document","citation":"PHMSA-2016-0008","title":"Colorado Interstate Gas Company, L.L.C. — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2016-09-01","effective_on":"2016-09-01","summary":"PHMSA-2016-0008, issued 2016-09-01 for Colorado Interstate Gas Company, L.L.C.'s gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2016-0008.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2016-0008.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2016-0008","source_url":"https://www.regulations.gov/docket/PHMSA-2016-0008","body":"PHMSA pipeline special permit PHMSA-2016-0008. Operator: Colorado Interstate Gas Company, L.L.C.. System: Gas Transmission. Issue date: 2016-09-01. Renewal: Mar 17, 2023.\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMarch 17, 2023\nMr. Kenneth W. Grubb\nChief Operating Officer\nKinder Morgan Natural Gas Division\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: Docket No. PHMSA-2016-0008\nSpecial Permit Renewal from March 17, 2023 to March 17, 2028\nDear Mr. Grubb:\nOn March 4, 2021, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Colorado\nInterstate Gas Company, LLC (CIG)1 applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) for a special permit. CIG requested a renewal of a previously granted\nspecial permit to waive compliance with 49 CFR §§ 192.611(a) and (d), 192.619(a), and 192.5 for\nClass 1 to Class 3 location changes on eight (8) pipeline segment for approximately 1.208 miles\nof 20-inch diameter and 22-inch diameter gas transmission pipelines (Pipelines). The Pipelines\nare located in Adams and Morgan Counties, Colorado, and Sweetwater County, Wyoming. A gas\ntransmission pipeline operator is required by 49 CFR § 192.611 to confirm or revise the\nmaximum allowable operating pressure of a pipeline segment where the class location has\nchanged as defined in 49 CFR § 192.5.\nOn May 27, 2022, PHMSA published a Federal Register notice (87 FR 32236) announcing the\nSpecial Permit Request. The Special Permit Request letter, Final Environmental Assessment\n(FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings\n(SPAF), and all other pertinent documents for this special permit are available in Docket No.\nPHMSA-2016-0008 in the Federal Docket Management System located at\nwww.regulations.gov.\n2\nSubject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based\non the information provided by CIG and the findings set forth in the SPAF, FEA, and FONSI.\n1 Colorado Interstate Gas Company, LLC is owned by Kinder Morgan, Inc.\n2 https://www.regulations.gov/docket?D=PHMSA-2016-0008.\n\n<<<PAGE 2>>>\n\nThis special permit provides relief from certain provisions of the Federal pipeline safety\nregulations for the Pipelines and requires CIG to comply with conditions and limitations\ndesigned to maintain pipeline safety as defined in the special permit. Note that in accordance\nwith 49 CFR § 190.341(j), PHMSA reserves the right to revoke, suspend, or modify this special\npermit if circumstances occur in which its continuance would be inconsistent with pipeline\nsafety. If CIG elects not to implement the special permit conditions, CIG must notify PHMSA\nwithin 60 days and comply with 49 CFR § 192.611 within 18 months of the date of this letter.\nMy staff would be pleased to discuss this special permit or any other regulatory matter with you.\nSentho White, Director of PHMSA Engineering and Research Division, may be contacted at\n(202) 366-2415, on technical matters; and James Urisko, Director, Office of Pipeline Safety,\nSouthern Region, may be contacted at (404) 832-1150, for operational matters specific to this\nspecial permit.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2016-0008\nSpecial Permit: PHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Letter of Decision – Class 1 to 3 Location – Colorado and Wyoming\nPage 2 of 2\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings\nClass 1 to 3 Location\nSpecial Permit Information:\nDocket Number: PHMSA-2016-0008\nRequested By: Colorado Interstate Gas Company, LLC\nOperator ID#: 2564\nOriginal Date Requested: January 11, 2016\n1st Renewal Issuance Date: March 17, 2023\nCode Section(s): 49 CFR 192.611(a) and (d), 192.619(a), and 192.5\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) provides this\ninformation to describe the facts of the subject special permit application submitted by Colorado\nInterstate Gas Company, LLC1 (CIG), to discuss any relevant public comments received with\nrespect to the application, to present the engineering/safety analysis of the special permit\napplication, and to make findings regarding whether the requested special permit should be\ngranted and if so under what conditions. CIG requests that PHMSA waive compliance from 49\nCode of Federal Regulations (CFR) 192.611(a) and (d), 192.619(a), and 192.5 for eight (8)\nspecial permit segments of approximately 1.208 miles of natural gas transmission pipeline\nsegments.\nPipeline System Affected:\nThis special permit request applies to eight (8) special permit segments of natural gas\ntransmission pipeline operated by CIG and located in the states of Colorado and Wyoming where\na change has occurred from an original Class 1 location to a Class 3 location. This special\npermit allows CIG to continue to operate the eight (8) pipeline segments and approximately\n1 Colorado Interstate Gas Company, LLC is owned by Kinder Morgan, Inc.\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 1 of 12\n\n<<<PAGE 2>>>\n\n1.208 miles (6,379.96 feet) at their current maximum allowable operating pressure (MAOP)\nshown in pounds per square inch gauge (psig).\nSpecial Permit Request:\nCIG applied to PHMSA on March 4, 2021, for a renewal of a previously granted special permit\nseeking relief from the Federal pipeline safety regulations in 49 CFR 192.611(a) and (d),\n192.619(a), and 192.5 for eight (8) special permit segments and 1.208 miles of natural gas\ntransmission pipelines. The special permit segments are in the states of Colorado and Wyoming,\nthat are identified using CIG station references of mile post (MP) and survey station (SS).\nSpecial permit segments are divided into two (2) categories: Type A special permit segments\nand Type B special permit segments.\n• Type A special permit segments include those special permit segments as described in Table\n1 – Type A Special Permit Segments, where there is a cluster, as described in 49 CFR\n192.5(c), of more than 10 buildings intended for human occupancy in a “class location unit”\nand for which the MAOP has not been confirmed in accordance with 49 CFR 192.611(a) or\nwhere the pipe installed has been identified to have a seam type or manufacturer type that is\nproblematic for maintaining pipeline integrity. Type A special permit segments total\napproximately 0.827 miles (4,365.03 feet) of pipe in this proposed special permit renewal.\nType A special permit segments must meet Condition 1(d) and Conditions 8(b)(i) and (c) of\nthe Special Permit Conditions.\nTable 1 – Type A Special Permit Segments\nSpecial\nOutside\nSegment\nStart Survey\nEnd Survey\nPermit\nLine\nCounty,\nDiameter\nLength\nStation\nStation\nSegment\nName\nState\nNo.\nDwellings Year Installed Seam\nType\nExternal\nCoating\nNumber2\n(inches)\n(feet)3\n(MP - SS)\n(MP - SS)\n1 (KM 33) 20 0002-A 782.61 0222 – 5203 0223 – 53 Adams, CO 1 1947 LF-ERW CTE 2 (KM 34) 20 0002-A 1,370.52 0223 – 529 0223 – 1900 Adams, CO 1 1947 LF-ERW CTE 3 (KM 36) 20 0002-B 845.14 0222 – 5219 0223 – 177 Adams, CO 1 1950 LF-ERW CTE 4 (KM 37) 20 0002-B 1,366.76 0223 – 618 0223 – 1984 Adams, CO 1 1950 LF-ERW CTE 2 The initial special permit required the replacement of special permit segments 10 (KM 43) and 11 (KM 44). In\naddition to the required replacements, CIG has not elected to request a renewal for special permit segments 5\n(KM 38), 6 (KM 39), 7 (KM 40), 8 (KM 41), 9 (KM 42), and 15 (KM 332). These segments must now meet the\nrequirements of 49 CFR 192.611(a).\n3 Differences between the actual length and what is calculated from the begin and end station is due to station\nequations.\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 2 of 12\nMAOP\n(psig)\n920\n920\n920\n920\n\n<<<PAGE 3>>>\n\nNote: LF-ERW is a low frequency electric resistance welded pipe longitudinal seam.\nCTE is coal tar enamel pipe coating type.\n• Type B special permit segments include those special permit segments as described in\nTable 2 – Type B Special Permit Segments where there is a cluster, as described in 49\nCFR 192.5(c), of 10 or fewer buildings intended for human occupancy in a “class\nlocation unit” and for which the MAOP has not been confirmed in accordance with 49\nCFR 192.611. Type B special permit segments total approximately 0.382 miles\n(2,014.93 feet) of pipe.\nTable 2 – Type B Special Permit Segments\nSpecial\nPermit\nOutside\nLine\nDiameter\nLengt\nh\nStart Survey\nStation\nEnd Survey\nStation\nCounty, State Name\nNo.\nDwellings\nYear\nSeam\nExternal\nSegment\nNumber\nInstalled\nType\nCoating\n(inches)\n(feet)\n(MP - SS)\n(MP - SS)\n12 (KM 45) 20 0059-A 543.6 0005 – 2956 0005 – 3500 Morgan, CO 1 1995 HF-ERW Tape 13 (KM 46) 20 0059-A 779.6 0005 – 3579 0005 – 4359 Morgan, CO 1 1995 HF-ERW Tape 14 (KM 47) 20 0059-A 82 0005 – 4775 0005 – 4857 Morgan, CO 0 1995 HF-ERW Tape 16 (KM 333) 22 0005-A 609.7\n3 0348 – 1253 0348 – 1863 Sweetwater, WY 4 1957 DSAW CTE Note: HF-ERW is a high frequency electric resistance welded pipe longitudinal seam.\nDSAW is double submerged arc welded pipe longitudinal seam.\n• Special permit inspection area – is defined as a one (1) mile continuous segment on both\nsides of the special permit segment (Type A and Type B) plus the footage in the special\npermit segment. Appendix A lists the boundaries for the special permit inspection area\nassociated with each special permit segment. The special permit inspection areas total\n8.83 miles of pipe as detailed in Table 3 – Type A Special Permit Inspection Areas and\nTable 4 – Type B Special Permit Inspection Areas.\nTable 3 – Type A Special Permit Inspection Area\nSpecial Permit\nOutside\nInspection Area\nNumber\nDiameter\nLine Name Inspection Area Start\n(MP – SS)\nInspection Area End\n(MP – SS)\nInspection Area Length\n(Miles)\n1 (KM 33) (inches)\n20 0002-A 0221 – 5177 0224 – 14.81 2.15\n2 (KM 34) 20 0002-A 0222 – 1182 0224 – 1718 2.26\n3 (KM 36) 20 0002-B 0221 – 5305 0224 – 146 2.16\n4 (KM 37) 20 0002-B 0222 – 1225 0224 – 1947 2.26\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 3 of 12\nMAOP\n(psig)\n1,050\n1,050\n1,050\n845\n\n<<<PAGE 4>>>\n\nTable 4 – Type B Special Permit Inspection Area\nOutside\nSpecial Permit\nSegment Number\nLine\nDiameter\nName\nInspection Area Start\n(MP – SS)\nInspection Area End\n(MP – SS)\nInspection Area Length\n(Miles)\n(inches)\n12 (KM 45) 20 0059-A 0004 – 2956 0006 – 3500 2.10\n13 (KM 46) 20 0059-A 0004 – 3579 0006 – 4359 2.15\n14 (KM 47) 20 0059-A 0004 – 4775 0006 – 4857 2.02\n16 (KM 333) 22 0005-A 0347 – 1253 0349 – 1863 2.23\nSubsequent to the issuance of this special permit, those special permit segments that have been\npressure tested or replaced, such that the MAOP has been made commensurate with the present\nclass location as defined in 49 CFR 192.611, would no longer be included in this special permit.\nThis special permit allows CIG to continue to operate the pipeline segments at their current\nmaximum allowable operating pressure (MAOP) until either replaced, hydrostatically tested, or\noperated in accordance with the special permit conditions. The Federal pipeline safety\nregulations in 49 CFR 192.611(a) require natural gas pipeline operators to confirm or revise the\nMAOP of a pipeline segment after a change in class location. A special permit allows CIG to\ncontinue to operate each of the eight (8) special permit segments at their existing MAOP’s\ndespite a change in class location for the special permit specified time interval.\nPublic Notice:\nOn May 27, 2022, PHMSA posted a notice of this special permit request in the Federal Register\n(87 FR 32236) with a closing date of June 27, 2022. PHMSA received a public comment\nconcerning this special permit request that has been addressed in the Final Environmental\nAssessment and Finding of No Significant Impact (FEA and FONSI).\nThe CIG special permit application letter, Federal Register notice, Final Environmental\nAssessment, Finding of No Significant Impact, and all other pertinent documents are available\nfor review in Docket No. PHMSA-2016-0008 in the Federal Docket Management System\n(FDMS) located at www.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the\ncriteria it uses for the consideration of class location change waivers, now being granted through\nspecial permits. First, certain threshold requirements must be met for a pipeline section to be\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 4 of 12\n\n<<<PAGE 5>>>\n\nfurther evaluated for a class location change special permit. Second, the age and manufacturing\nprocess of the pipe; system design and construction; environmental, operating and maintenance\nhistories; and integrity management (IM) program elements are evaluated as significant criteria.\nThese significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket\nNumber PHMSA–RSPA-2004-17401. Third, such special permits will only then be granted\nwhen pipe conditions and the operator’s IM program provides a level of safety equal to a pipe\nreplacement or pressure reduction.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the\nJune 29, 2004, Federal Register notice is discussed below regarding the CIG special permit\npetition.\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\nThis special permit request is for eight (8) special permit segments on the CIG pipeline\nsystem where a class location change has occurred from Class 1 to Class 3 locations as\ndefined in 49 CFR 192.5(c) for cluster locations and segments outside the cluster (and inside\nthe sliding mile for the class location) where an additional dwelling(s) have been identified.\nCIG has met this requirement.\n2) No bare pipe will be considered. These CIG special permit segments are coated with an\nexternal protective coating. CIG has met this requirement.\n3) No pipe containing wrinkle bends will be considered. There are no wrinkle bends in the\nspecial permit segments. CIG has met this requirement.\n4) No pipe segments operating above 72% of the specified minimum yield strength (SMYS)\nwill be considered for a Class 3 special permit. The special permit segments operate at or\nbelow 72% SMYS. CIG has met this requirement.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x maximum allowable\noperating pressure (MAOP). CIG will pressure test any special permit segments that do not\nmeet this requirement through the special permit conditions.\n6) In-line inspection (ILI) must have been performed with no significant anomalies identified\nthat indicate systemic problems. CIG will meet this requirement through the special permit\nconditions.\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 5 of 12\n\n<<<PAGE 6>>>\n\n7) Criteria for consideration of class location change waiver, now being granted through special\npermits, published by PHMSA in the Federal Register (69 FR 38948), define a waiver\ninspection area (special permit inspection area) as up to 25 miles of pipe either side of the\nwaiver segment (special permit segment). The special permit inspection area must be\ninspected according to CIG’s IM program and periodically inspected with an in-line\ninspection technique. The special permit inspection area extends one-mile out from either\nside of the special permit segments and the Class location 3 sliding mile. This additional\nlength was used since the Type B areas that are not being replaced are locations with 10 or\nfewer buildings intended for human occupancy in a “class location unit” and are outside the\noriginal “cluster area.\n” This special permit is contingent upon CIG’s incorporation of each of\nthe special permit segments in its written IM program as a “covered segment” in a “high\nconsequence area” (HCA) per 49 CFR 192.903.\nCriteria Matrix: The original and supplemental data submitted by CIG for the special permit\nsegment have been compared to the class location change special permit criteria matrix. The\nspecial permit segments fall in the probable acceptance column of the criteria matrix for all\ncriteria except for:\n• Possible acceptance – pipe coating and several leaks within 20-miles of the special\npermit segment.\n• Requires substantial justification - pipe manufacture and pipe material\nThe data findings below fall within the “possible acceptance and requires substantial\njustification” columns of the criteria matrix:\n1) Pipe design and construction, including pipe manufacture, material and design stress:\n• CIG pipeline special permit segments have:\no Pipe manufactured with the following pipe seams: low frequency electric resistance\nwelded, high frequency electric resistance welded, and double submerged arc welded.\no Pipe coatings included: coal tar enamel and tape-polyethylene.\no Pipe design stress was 72% specified minimum yield strength or lower.\n• To further address pipe manufacturing, material, construction, pipe coating, stress\ncorrosion cracking direct assessment (SCCDA), and possible pipe leak issues, this special\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 6 of 12\n\n<<<PAGE 7>>>\n\npermit will include conditions requiring CIG to treat all special permit segments as\n“covered segments” in an HCA per 49 CFR 192.903.\n• CIG will also be required to perform ILI assessments, anomaly repairs, close interval\nsurveys, identify any pipeline segment that may be susceptible to pipe seam issues\nbecause of the vintage of the pipe, the manufacturing process of the pipe, or other issues\nand SCCDA along the entire length of the special permit inspection areas and special\npermit segments according to the requirements of 49 CFR 192.929 after the grant of this\nspecial permit.\n• This special permit will include a condition that CIG must continue to operate each\nspecial permit segment at or below its existing MAOP.\nPHMSA has determined that imposing the special permit conditions will address these concerns\nand provide equivalent safety for these areas.\nOperational Integrity Compliance:\nTo inform PHMSA’s decision about whether a special permit could provide a level of safety\ngreater than or equal to a pipe replacement or pressure reduction and is consistent with pipeline\nsafety, PHMSA reviewed this special permit request to understand the known type of integrity\nthreats that are in the special permit segment and special permit inspection area. This integrity\ninformation was used to consider special permit conditions to provide a systematic program to\nreview and remediate the pipeline for safety concerns. Additional operational integrity review\nand remediation requirements are required by this special permit to ensure that the operator has\nan ongoing program to locate and remediate safety threats. These threats to integrity and safety\ninclude any issues with the pipe coating quality, cathodic protection effectiveness, operations\ndamage prevention program, pipe depth of soil cover, weld seam and girth weld integrity,\nanomalies in the pipe steel and welds, and material and structures either along or near the\npipeline that could cause the cathodic protection system to be ineffective. PHMSA has carefully\ndesigned a comprehensive set of conditions that CIG must implement to comply with this special\npermit.\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 7 of 12\n\n<<<PAGE 8>>>\n\nPast Enforcement History – January 1, 2011 through July 31, 2022:\nDuring January 1, 2011, through July 31, 2022, CIG was cited in six (6) enforcement actions with a\ntotal of $154,800 in assessed civil penalties. PHMSA issued two (2) Notices of Amendment, one (1)\nNotice of Probable Violation, and three (3) Warning Letters to CIG. Tables 5 and 6 below shows\nPHMSA’s enforcement actions and civil penalties for CIG:\nTable 5: CIG Enforcement Matters from\nJanuary 1, 2011, through July 31, 2022\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 0 2 1 0 3 6\nOPEN 0 0 0 0 0 0\nTotal 0 2 1 0 3 6\nTable 6: CIG Enforcement Civil Penalty Status\nJanuary 1, 2011, through July 31, 2022\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$198,000 $0 $43,200 $154,800\n$154,800 Summary of Enforcement Findings for CIG includes: definitions, supports and anchors,\ndesign of pressure relief or limiting devices, external corrosion control monitoring, internal\ncorrosion control, procedures for O&M, patrolling transmission lines, record keeping for\ntransmission lines, compressor stations, valve maintenance, and IM.\n• 49 CFR 192.5, 192.14, 192.42, 192.225, 192.227, 192.475, 192.491, 192.603, 192.605,\n192.933, and 192.935.\nTable 7 below shows PHMSA’s enforcement actions and civil penalties for CIG and the specific 49\nCFR Part 191 and 192 violations:\nTable 7: Summary of Enforcement Findings from CIG\nJanuary 1, 2011, to July 31, 2022\nNotice of Amendment\nIntegrity Management 1 OME Procedural Manual 2 Reporting 1\nWelding of Steel in Pipelines 2 Transportation of Gas 1\nNotice of Amendment Total: 7\nNotice of Probable Violation\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 8 of 12\n\n<<<PAGE 9>>>\n\nTable 7: Summary of Enforcement Findings from CIG\nJanuary 1, 2011, to July 31, 2022\nIntegrity Management 3 Operation and/or Maintenance 2\nNotice of Probable Violation Total: 5\nWarning Letter\nCorrosion Control 1 Integrity Management 1 OME Procedural Manual 1\nOperation and/or Maintenance 1\nWarning Letter Total: 4\nGrand Total: 16\nSummary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG,\nEPNG, Tejas, NGPL, TGP, and TGP:\nFrom January 1, 2011, through July 31, 2022, Kinder Morgan, the operator of TGP, was cited in 71\nenforcement actions with a total of $1,077,800 in assessed civil penalties on its Colorado Interstate\nGas Company (CIG), El Paso Natural Gas Company (EPNG), Tejas Pipeline (Tejas), Natural Gas\nPipeline of America (NGPL), Southern Natural Gas Company (SNG), and Tennessee Gas Pipeline\nCompany (TGP) pipeline systems. PHMSA issued seventeen (17) Notice of Amendments, twenty-two\n(22) Notices of Probable Violations, twenty-two (22) Warning Letters, one (1) Safety Order, and nine\n(9) Corrective Action Orders to Kinder Morgan.\nTables 8 and 9 below show PHMSA’s enforcement actions and civil penalties for Kinder\nMorgan on these pipeline systems – CIG, EPNG, NGPL, SNG, Tejas, and TGP with operator\nidentification numbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160.\nTable 8: Kinder Morgan Enforcement Matters from\nJanuary 1, 2011, through July 31, 2022\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 5 17 22 1 22 67\nOPEN 4 0 0 0 0 4\nTotal 9 17 22 1 22 71\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 9 of 12\n\n<<<PAGE 10>>>\n\nTable 9: Kinder Morgan Enforcement Civil Penalty Status\nJanuary 1, 2011, through July 31, 2022\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$1,461,500 $0 $1,077,800 $383,700 $1,077,800\nThe type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6)\npipeline systems from January 1, 2011 through July 31, 2022 were as follows:\nSummary of Enforcement Endings for CIG, EPNG, Tejas, NGPL, SNG, and TGP includes:\nReporting, design, welding, compliance with specifications or procedures, corrosion control,\noperations and maintenance procedures, continuing surveillance, public awareness, emergency\nplans, maximum allowable operating pressure, control room management, relief devices,\nmaintenance of valves, qualification of operating personnel, and integrity management:\n• 49 CFR 191.3, 191.5, 191.15, 191.22, 191.23, 191.25, 191.27, 192.3, 192.12, 192.14,\n192.161, 192.163, 192.199, 192.201, 192.225, 192.227, 192.229, 192.303, 192.459, 192.461,\n192.463, 192.465, 192.469, 192.475, 192.479, 192.481, 192.491, 192.603, 192.605, 192.611,\n192.613, 192.615, 192.616, 192.619, 192.625, 192.631, 192.705, 192.706, 192.707, 192.709,\n192.713, 192.731, 192.735, 192.736, 192.739, 192.743, 192.745, 192.805, 192.807, 192.905,\n192.911, 192.917, 192.921, 192.933, 192.935, 192.937, 195.42, 195.44, 195.428, and\n195.452.\nTable 10 below gives a complete summary of the findings and the specific 49 CFR Part 191 and 192\nviolation:\nTable 10: Summary of Enforcement Findings for\nCIG, EPNG, Tejas, NGPL, SNG, and TGP\nJanuary 1, 2011 through July 31, 2022\nNotice of Amendment\nConstruction 1 Control Room Management 4 Integrity Management 10\nOME Procedural Manual 11 Operation and/or Maintenance 2 Operator Qualification 3\nPublic Awareness 8 Reporting 3 Transportation of Gas 5\nWelding of Steel in Pipelines 3\nNotice of Amendment Total: 50\nNotice of Probable Violation\nControl Room Management 1 Corrosion Control 13 Design 2\nIntegrity Management 10 OME Procedural Manual 14 Operation and/or Maintenance 26\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 10 of 12\n\n<<<PAGE 11>>>\n\nTable 10: Summary of Enforcement Findings for\nCIG, EPNG, Tejas, NGPL, SNG, and TGP\nJanuary 1, 2011 through July 31, 2022\nOperator Qualification 7 Public Awareness 2 Reporting 5\nWelding of Steel in Pipelines 1\nNotice of Probable Violation Total: 81\nWarning Letter\nCorrosion Control 11 Design 1 Integrity Management 1\nOME Procedural Manual 10 Operation and/or Maintenance 31 Operator Qualification 2\nPublic Awareness 4 Reporting 1 Transportation of Gas 1\nWarning Letter Total: 62\nGrand Total: 193\nFindings:\nBased on the information submitted by CIG and PHMSA’s analysis of the technical, operational,\nand safety issues, PHMSA finds that granting this special permit with conditions that requires\nCIG to operate the eight (8) special permit segments on 20-inch diameter and 22-inch diameter\nnatural gas transmission pipelines located in Adams and Morgan Counties, Colorado, and\nSweetwater County, Wyoming at their current MAOP for a Class 1 to Class 3 location change\nwould not be inconsistent with pipeline safety.\nPHMSA has designed the special permit conditions to effectively assess and remediate threats to\nthe special permit segments and special permit inspection areas, including pressure testing,\nobtaining pipe material records, and conducting assessments to evaluate pipe girth welds that\nhave not been non-destructively tested, any pipe with missing material records, and stress\ncorrosion cracking (SCC). To ensure CIG properly implements the special permit conditions,\nCIG will be required to give PHMSA an annual review of their compliance with the special\npermit.\nPHMSA finds the issuance and full implementation of this special permit that waives the\nrequirements of 49 CFR 192.611 for a class location change to a Class 3 location is not\ninconsistent with pipeline safety. This special permit requires CIG to implement the special\npermit conditions that include safety requirements on the operations, maintenance, and integrity\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 11 of 12\n\n<<<PAGE 12>>>\n\nmanagement of the special permit segments and the special permit inspection areas. CIG will\nbe required to implement the special permit conditions along the special permit segments and\nspecial permit inspection areas in pipeline segments that are not high consequence areas and\nwould not normally be required by 49 CFR Part 192 to be assessed on a periodic interval for\nthreats.\nCompleted in Washington, DC, on: March 17, 2023.\nPrepared By: PHMSA – Engineering and Research Division\nPHMSA-2016-0008 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado and Wyoming\nPage 12 of 12","truncated":false,"body_characters":28285}