{"operation":"document","citation":"PHMSA-2022-0038","title":"Colorado Interstate Gas Company, LLC — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2023-07-24","effective_on":"2023-07-24","summary":"PHMSA-2022-0038, issued 2023-07-24 for Colorado Interstate Gas Company, LLC's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2022-0038.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2022-0038.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2022-0038","source_url":"https://www.regulations.gov/docket/PHMSA-2022-0038","body":"PHMSA pipeline special permit PHMSA-2022-0038. Operator: Colorado Interstate Gas Company, LLC. System: Gas Transmission. Issue date: 2023-07-24.\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-2022-0038\nRequested By: Colorado Interstate Gas Company, LLC\nOperator ID#: 2564\nOriginal Date Requested: March 1, 2022\nOriginal Issuance Date: July 24, 2023, to July 24, 2033\nCode Section(s): 49 CFR 192.611(a) and (d) and 192.619(a)\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS),\n1 provides this information to describe the facts of the subject special permit application\nsubmitted by Colorado Interstate Gas Company, LLC (CIG)2 to discuss any relevant public comments\nreceived with respect to the application, to present the engineering and safety analysis of the special\npermit application, and to make findings regarding whether the requested special permit should be\ngranted and, if so, under what conditions. CIG requested that PHMSA waive compliance from the 49\nCode of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for a natural gas transmission\npipeline segment, where the class location has changed from Class 1 to a Class 3 location.\nPipeline System Affected:\nThis special permit application by CIG requests a waiver from the class location change requirements\nin 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 1.40 miles of the 24-inch diameter\n1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s\nPipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.\n2 CIG is a wholly owned subsidiary of Kinder Morgan, Inc.\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 1 of 10\n\n<<<PAGE 2>>>\n\nDenver-Rock Springs Loop Pipeline located in Adams County, Colorado.\nPipe specifications including outside diameter, year installed, seam type, coating type, pipe grade, wall\nthickness, maximum allowable operating pressure (MAOP), minimum pressure test pressure, and\npressure test factor based on the minimum test pressure are detailed in Table 1 – Pipe Specifications\nby Line Name.\nTable 1 – Pipe Specifications by Line Name\nMinimum\nOutside\nLine Name\nDiameter\nYear\nInstalled Seam Type Coating Type Grade Wall Thickness\n(inches)\nMAOP\nTest\nPressure\n(psig)\nPressure\nTest Factor\n(inches)\nDenver-Rock\nSprings Loop 24 1978 ERW-HF Tape X60 0.25 850 (psig)\n1,112 1.31\nWithout this special permit, 49 CFR 192.611(a) would require CIG to replace the special permit\nsegment with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location change.\nSpecial Permit Request:\nOn March 1, 2022, CIG applied to PHMSA for a special permit seeking relief from 49 CFR 192.611(a)\nand (d) and 192.619(a) for the below-listed special permit segment, where a class location change\noccurred from the original Class 1 to a Class 3 on the 24-inch diameter Denver-Rock Springs Loop\nPipeline located in Adams County, Colorado.\nCIG’s special permit applies to the special permit segment and special permit inspection area\ndescribed and defined as follows, using the CIG survey station references:\nSpecial Permit Segment:\nThis special permit applies to the special permit segment in Table 2 – Special Permit Segment and\nare identified using the CIG mile post (MP) and survey station (SS) references.\nTable 2 – Special Permit Segment\nSpecial\nOutside\nPermit\nDiameter\nLine Name Length\n(feet)\nStart Survey\nStation\nEnd Survey\nStation\nCounty,\nState\nNo.\nYear\nSeam\nMAOP\nSegment\nNumber\nDwellings\nInstalled\nType\n(psig)\n(inches)\n(MP - SS)\n(MP -SS)\n650 24 Denver-Rock\nSprings Loop 7,387 004 - 3085 005 - 5192 Adams, CO 9 1978 ERW-\nHF 850\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 2 of 10\n\n<<<PAGE 3>>>\n\nSpecial Permit Inspection Areas:\nThe special permit inspection area is defined as the area that extends 220 yards on each side of the\ncenterline as listed in Table 3 – Special Permit Inspection Area.\nTable 3 – Special Permit Inspection Area\nSpecial\nSpecial\nOutside\nPermit\nPermit\nDiameter\nLine Name Inspection\nStart Survey Station\n(MP - SS)\nEnd Survey Station\n(MP - SS)\nLength3\n(miles)\nArea Number\nSegment(s)\nIncluded\n(inches)\n1 650 24 Denver-Rock\nSprings Loop 004 - 2161.73 085 - 3469 81\nPublic Notice:\nOn May 27, 2022, PHMSA posted a notice of this special permit request in the Federal Register (87 FR\n32235) with a closing date of June 27, 2022. PHMSA received no public comments concerning this\nspecial permit request through June 27, 2022.\nThe CIG special permit application letter, Federal Register notice, FEA, Finding of No Significant\nImpact, and all other pertinent documents are available for review in Docket No. PHMSA-2022-0034\nin the Federal Docket Management System (FDMS) located at www.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the criteria\nit uses for the consideration of applications for class location change waivers, now being granted or\ndenied through a special permit. First, certain threshold requirements should be met on a pipeline\nspecial permit segment for a class location change special permit to be granted. Second, the age and\nmanufacturing process of the pipe; system design, and construction; environmental, operating and\nmaintenance histories; and integrity management program elements are evaluated as significant criteria.\nThese significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket No.\nPHMSA–RSPA-2004-17401. Third, special permits will only be granted when pipe conditions and\nactive integrity management provide a level of safety greater than or equal to a pipe replacement or\n3 If the special permit inspection area footage does not extent from launcher to receiver, then the special permit\ninspection area would need to be extended.\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 3 of 10\n\n<<<PAGE 4>>>\n\npressure reduction. The operator’s Federal pipeline safety regulation compliance history is also\nevaluated as part of the criteria matrix for acceptability prior to issuance of a special permit.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the June 29,\n2004, Federal Register notice is discussed below regarding the CIG special permit request.\n• No pipeline segment in a class location changing to Class 4 location will be considered.\n• This special permit request is for one (1) special permit segment where a change has occurred\nfrom a Class 1 location to a Class 3 location.\n• CIG meets this requirement.\n• No bare pipe will be considered.\n• The special permit segment is externally coated with polyethylene tape.\n• CIG meets this requirement.\n• No pipe containing wrinkle bends will be considered.\n• There are no reported wrinkle bends in the special permit segment.\n• CIG meets this requirement.\n• No pipe segment operating above 72% of the specified minimum yield strength (SMYS) will be\nconsidered for a Class 3 special permit.\n• The special permit segment operates at or below 72% SMYS.\n• CIG meets this requirement.\n• Records must be produced that show a hydrostatic test to at least 1.25 time the MAOP. The records\nshould include test pressure, year of the test, test duration, and pressure test percent of MAOP for\neach pipeline:\n• CIG has communicated that the special permits segment has been tested to at least 1.25 times\nthe MAOP.\n• CIG meets this requirement.\n• In-line inspection (ILI) must have been performed with no significant anomalies identified that\nindicate systemic problems such as stress corrosion cracking (SCC).\n• CIG ran a high-resolution magnetic flux leakage (HR-MFL) ILI for corrosion and\ndeformation ILI for denting.\n• CIG meets this requirement.\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 4 of 10\n\n<<<PAGE 5>>>\n\n• Criteria for consideration of a class location change waiver, being considered through the special\npermit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver inspection\narea (special permit inspection area) as up to 25 miles of pipe on either side of the waiver segment\n(special permit segment).\n• CIG has identified longer segment surrounding each special permit segment as the special\npermit inspection area. This segment has been extended to the entire segment length between\nthe upstream launcher and downstream receiver for the ILI segment that contains the special\npermit segment.\nCriteria Matrix: The data submitted by CIG for the special permit segment have been compared to the\nclass location change special permit criteria matrix.\n• The following special permit segment fall in the probable acceptance column of the criteria\nmatrix for:\no Design stress, depth of pipe cover, test pressure, test failures, local geology, type of\nservice, pressure fluctuations, safety related conditions, direct assessment, ILI type, and\ndamage prevention program.\n• The following special permit segment fall in the possible acceptance column of the criteria\nmatrix for:\no Pipe manufactured in 1978, class location change, coating type (polyethylene tape\ncoating may shield CP when disbanded and lead to SCC4)\nOperational Integrity Compliance:\nTo inform PHMSA’s decision about whether a special permit could provide a level of safety greater\nthan or equal to a pipe replacement or pressure reduction and is consistent with pipeline safety,\nPHMSA reviewed this special permit request to understand the known type of integrity threats that are\nin the special permit segment and special permit inspection area. This integrity information was used\nto consider special permit conditions to provide a systematic program to review and remediate the\npipeline for safety concerns. Additional operational integrity review and remediation requirements are\nrequired by this special permit to ensure that the operator has an ongoing program to locate and\n4 Two (2) types of SCC are found on pipelines: high pH (9 to 11) SCC and near-neutral pH (6 to 8) SCC. Polyethylene tape\ncoatings that are disbonded are more prone to have SCC.\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 5 of 10\n\n<<<PAGE 6>>>\n\nremediate safety threats. These threats to integrity and safety include any issues with the pipe coating\nquality, cathodic protection effectiveness, operations damage prevention program, pipe depth of soil\ncover, weld seam and girth weld integrity, anomalies in the pipe steel and welds, and material and\nstructures either along or near the pipeline that could cause the cathodic protection system to be\nineffective. PHMSA has carefully designed a comprehensive set of conditions that CIG must\nimplement to comply with this special permit.\nPast Enforcement History – January 1, 2012, through January 22, 2023:\nDuring January 1, 2012, through January 22, 2023, CIG was cited in five (5) enforcement actions with a total\nof $154,800 in assessed civil penalties. PHMSA issued one (1) Notice of Amendment, one (1) Notice of\nProbable Violation, and three (3) Warning Letters to CIG. Tables 4 and 5 below shows PHMSA’s\nenforcement actions and civil penalties for CIG:\nTable 4 - CIG Enforcement Matters from\nJanuary 1, 2012, through January 22, 2023\nNotice of\nStatus Corrective\nAction Order\nNotice of\nProbable\nAmendment\nSafety\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 0 1 1 0 3 5\nOPEN 0 0 0 0 0 0\nTotal 0 1 1 0 3 5\nTable 5 - CIG Enforcement Civil Penalty Status\nJanuary 1, 2012, through January 22, 2023\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$198,000 $154,800 $43,200 $154,800\nSummary of Enforcement Findings for CIG includes:\n• Corrosion Control: Records; Integrity Management: High Consequence Area – Integrity Actions\nand Preventative and Mitigative Measures; OME Procedural Manual: General and Maintenance\nand Normal Operations; Operations and Maintenance: Overpressure safety devices and overfill\nprotection systems, Valve Maintenance, and General; Reporting: Immediate Reporting Incident;\nTransportation of Gas: Conversion to Service.\n• 49 CFR 191.5, 191.14, 192.461, 192.475, 192.491, 192.603, 192.605, 192.745, and 192.935.\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 6 of 10\n\n<<<PAGE 7>>>\n\nTable 6 below shows PHMSA’s enforcement actions and civil penalties for CIG and the specific 49 CFR\nParts 191 and 192 violations:\nTable 6 - Summary of Enforcement Findings from CIG\nJanuary 1, 2012, through January 22, 2023\nNotice of Amendment\nOME Procedural Manual 1 Reporting 1 Transportation of Gas 1\nNotice of Amendment Total: 3\nNotice of Probable Violation\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: 12\nSummary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG, EPNG,\nNGPL, SNG, Tejas, and CIG:\nFrom January 1, 2012, through January 22, 2023, Kinder Morgan, the operator of CIG, was cited in 64\nenforcement actions with a total of $979,900 in assessed civil penalties on its Colorado Interstate Gas\nCompany (CIG), El Paso Natural Gas Company (EPNG), Natural Gas Pipeline of America (NGPL),\nSouthern Natural Gas Company (SNG), Tejas Pipeline (Tejas), and Tennessee Gas Pipeline Company (CIG)\npipeline systems. PHMSA issued seven (7) Corrective Action Orders, 15 Notice of Amendments, 20 Notices\nof Probable Violations, and 22 Warning Letters to Kinder Morgan.\nTables 7 and 8 below show PHMSA’s enforcement actions and civil penalties for Kinder Morgan on\nthese pipeline systems – CIG, EPNG, NGPL, SNG, Tejas, and CIG - with operator identification\nnumbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160.\nTable 7 - Kinder Morgan Enforcement Matters from\nJanuary 1, 2012, through January 22, 2023\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 3 15 20 0 22 60\nOPEN 4 0 0 0 0 4\nTotal 7 15 20 0 22 64\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 7 of 10\n\n<<<PAGE 8>>>\n\nTable 8 - Kinder Morgan Enforcement Civil Penalty Status\nJanuary 1, 2012, through January 22, 2023\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$1,363,600 $0 $979,900 $383,700 $979,900\nThe type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline\nsystems from January 1, 2012, through January 22, 2023, were as follows:\nSummary of Enforcement Findings for CIG, EPNG, NGPL, SNG, Tejas, and CIG includes:\n• Atmospheric Corrosion Control: General and Monitoring; Construction: Compliance with\nStandards; Control Room Management: Alarm Management and Fatigue Mitigation; Design:\nSupports and Anchors; External Corrosion Control: Cathodic Protection, Examination of Buried\nPipe, Monitoring, and Test Stations; Gas Transportation: Conversion of Service and Underground\nNatural Gas Storage; Internal Corrosion Control: Inspection Internal Surface; Integrity\nManagement: Addressing Integrity Issues, Continual IM Baseline Assessment, Continual Process\nof Evaluation and Assessment, High Consequence Area (HCA) Identification, HCAs – Integrity\nActions, Preventative and Mitigative Measures, and Threat Identification; Maintenance:\nCompressor Stations-Gas Detection, Compressor Stations-Inspection and Testing of Relief Devices,\nCompressor Stations-Storage of Combustible Materials, Line Markers, Leak Surveys, Pressure\nLimiting and Regulating Stations Inspection and Testing, Relief Devices, Patrolling, Record\nKeeping, and Valve Maintenance; OME Procedural Manual: General and Maintenance and\nNormal Operations; Operations and Maintenance: Overpressure safety devices and overfill\nprotection systems and Valve Maintenance; Operations: Change in Class Location, Continual\nSurveillance, Emergency Plans, General, MAOP, and Odorization of Gas; Operator Qualification:\nQualification Program and Recordkeeping; Public Awareness: Develop and Implement Public\nAwareness, Documentation available for Review, Follow API RP 1162, Justification for not\nfollowing API RP 1162, Language Used, and Specifics addressing the Public; Reporting: Filing\nSRCR, Incident Reports, Immediate Reporting Incident, National Registry of Pipeline and LNG\nOperators, Offshore Pipeline Condition Report; Welding: Limitations on Welders and Procedures.\n• 49 CFR 191.3, 191.5, 191.15, 191.22, 191.23, 191.25, 191.27, 192.3, 192.12, 192.14, 192.161,\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 8 of 10\n\n<<<PAGE 9>>>\n\n192.201, 192.225, 192.227, 192.229, 192.303, 192.459, 192.461, 192.463, 192.465, 192.469,\n192.475, 192.479, 192.481, 192.603, 192.605, 192.611, 192.613, 192.615, 192.616, 192.619,\n192.625, 192.631, 192.705, 192.706, 192.707, 192.709, 192.713, 192.731, 192.735, 192.736,\n192.739, 192.743, 192.745, 192.805, 192.807, 192.905, 192.917, 192.921, 192.933, 192.935,\nand 192.937.\nTable 6 below gives a complete summary of the findings and the specific 49 CFR Parts 191 and 192\nviolations:\nTable 9 - Summary of Enforcement Findings for\nCIG, EPNG, NGPL, SNG, Tejas, and CIG\nJanuary 1, 2012, through January 22, 2023\nNotice of Amendment\nConstruction 1 Control Room Management 4 Integrity Management 2\nOME Procedural Manual 6 Operation and/or Maintenance 2 Operator Qualification 3\nPublic Awareness 8 Reporting 3 Transportation of Gas 5\nWelding of Steel in Pipelines 1\nNotice of Amendment Total: 35\nNotice of Probable Violation\nCorrosion Control 6 Integrity Management 9 OME Procedural Manual 11\nOperation and/or Maintenance 14 Operator Qualification 8 Public Awareness 2\nReporting 4 Welding of Steel in Pipelines 2\nNotice of Probable Violation Total: 56\nWarning Letter\nCorrosion Control 13 Design 1 Integrity Management 1\nOME Procedural Manual 13 Operation and/or Maintenance Public Awareness 4 Reporting 43 Warning Letter Total: Operator Qualification 4\n4 Transportation of Gas 1\n84\nGrand Total: 167\nFindings:\nBased on the information submitted by CIG and PHMSA’s analysis of the technical, operational, and\nsafety issues, PHMSA finds that granting this special permit with conditions that requires CIG to\noperate the special permit segment on 24-inch diameter Denver-Rock Springs Loop Pipeline located in\nAdams County, Colorado at its current MAOP for a Class 1 to Class 3 location change would not be\ninconsistent with pipeline safety.\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 9 of 10\n\n<<<PAGE 10>>>\n\nPHMSA has designed the special permit conditions to effectively assess and remediate threats to the\nspecial permit segment and special permit inspection area, including pressure testing, obtaining pipe\nmaterial records, and conducting assessments to evaluate pipe girth welds that have not been non-\ndestructively tested, any pipe with missing material records, and SCC. To ensure CIG properly\nimplements the special permit conditions, CIG will be required to give PHMSA an annual review of\ntheir compliance with the special permit.\nPHMSA finds the issuance and full implementation of this special permit that waives the requirements\nof 49 CFR 192.611(a) and (d) and 192.619(a) 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 permit\nconditions that include safety requirements on the operations, maintenance, and integrity management\nof the special permit segment and the special permit inspection area. CIG will be required to\nimplement the special permit conditions along the special permit segment and special permit\ninspection area in pipeline segments that are not high consequence areas and would not normally be\nrequired by 49 CFR Part 192 to be assessed on a periodic interval for threats.\nCompleted in Washington DC on: July 24, 2023\nPrepared by: PHMSA - Engineering and Research Division\nPHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Special Permit Analysis and Findings – Colorado\nPage 10 of 10\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJuly 24, 2023\nKenneth W. Grubb\nChief Operating Officer\nKinder Morgan Natural Gas Division\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: Docket No. PHMSA-2022-0038\nSpecial Permit from July 24, 2023, to July 24, 2033\nDear Mr. Grubb:\nOn March 1, 2022, 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 special permit to waive compliance\nwith 49 CFR §§ 192.611(a) and (d), and 192.619(a) for Class 1 to Class 3 location changes on one\n(1) pipeline segment for approximately 1.40 miles of 24-inch diameter gas transmission pipeline\n(Pipeline) located in Adams County, Colorado. A gas transmission pipeline operator is required by\n49 CFR § 192.611 to confirm or revise the maximum allowable operating pressure of a pipeline\nsegment where the class location has changed as defined in 49 CFR § 192.5.\nOn May 27, 2022, PHMSA published a Federal Register notice (87 FR 32235) 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-2022-0038 in the Federal Docket Management System located at www.regulations.gov.\n2\nSubject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based on\nthe information provided by CIG and the findings set forth in the SPAF, FEA, and FONSI. This\nspecial permit provides relief from certain provisions of the Federal pipeline safety regulations for\nthe Pipeline and requires CIG to comply with conditions and limitations designed to maintain\npipeline safety as defined in the special permit. Note that in accordance with 49 CFR § 190.341(j),\n1 Colorado Interstate Gas Company, LLC is owned by Kinder Morgan, Inc.\n2 https://www.regulations.gov/docket?D=PHMSA-2022-0038.\n\n<<<PAGE 2>>>\n\nPHMSA reserves the right to revoke, suspend, or modify this special permit if circumstances occur\nin which its continuance would be inconsistent with pipeline safety. If CIG elects not to implement\nthe special permit conditions, CIG must notify PHMSA within 60 days and comply with 49 CFR\n§ 192.611 within 18 months of the date of this letter.\nMy staff is available to discuss this special permit or any other regulatory matter with you. Mary\nMcDaniel, Acting Director of PHMSA Engineering and Research Division, may be contacted at\n713-272-2847, 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-2022-0038\nSpecial Permit: PHMSA-2022-0038 – Colorado Interstate Gas Company, LLC Letter of Decision – Class 1 to 3 Location – Colorado\nPage 2 of 2","truncated":false,"body_characters":23734}