U.S. Department 
of Transportation 
400 Seventh Street, S.W. 
Washington, D.C. 20590 
Pipeline and 
Hazardous Materials Safety 
Administrotion 
APR I 0 XlOFi 
Dwayne M. Burton 
Vice President, Gas Pipelines Operations 
Natural Gas Pipeline Company of America 
Kinder Morgan, Inc. 
500 Dallas St., Suite 1000 
Houston, TX 77002-47 1 8 
Re: CPF No. 4-2005-1012 
Dear Mr. Burton: 
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety 
in the above-referenced case. It makes a finding of violation, assesses a civil penalty of 
$9,500, and specifies actions to be taken to comply with the pipeline safety regulations. The 
penalty payment terms are set forth in the Final Order. When the civil penalty is paid and the 
terms of the compliance order completed, as determined by the Director, Southwest Region, 
this enforcement action will be closed. Your receipt of the Final Order constitutes service 
under 49 C.F.R. Ħħ 190.5. 
Sincerely, 
James Reynolds 
Pipeline Compliance Registry 
Office of Pipeline Safety 
Enclosure 
CERTIFIED MAIL -RETURN RECEIPT REQUESTED 

DEPARTMENT OF TRANSPORTATION 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 
OFFICE OF PIPELINE SAFETY 
WASHINGTON, DC 20590 
In the Matter of 
Natural Gas Pipeline Company of America, CPF No. 4-2005-1012 
a subsidiary of Kinder Morgan, Inc., 
Respondent 
FINAL ORDER 
On June 14-18, 2004, pursuant to 49 U.S.C. $ 601 17, a representative of the Pipeline and 
Hazardous Materials Safety Administration's Office of Pipeline Safety (PHMSA) conducted an 
on-site pipeline safety inspection of Respondent's facilities and records in Texas and Oklahoma. 
As a result of the inspection, the Director, Southwest Region, PHMSA, issued to Respondent, by 
letter dated June 15,2005, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed 
Compliance Order (Notice). In accordance with 49 C.F.R. tj 190.207, the Notice proposed 
finding that Respondent had violated 49 C.F.R. tj 192.745 and proposed assessing a civil penalty 
of $9,500 for the alleged violation. The Notice also proposed ordering Respondent to take 
certain measures to correct the alleged violation. 
Respondent responded to the Notice by letter dated July 20, 2005 (Response). Respondent 
contested the allegation of violation, offered information to explain the allegation, and requested 
that the proposed civil penalty be eliminated. Respondent did not request a hearing, and 
therefore has waived its right to one. 
FINDING OF VIOLATION 
The Notice alleged Respondent violated 49 C.F.R. tj 192.745(a) by failing to partially operate 
several transmission line valves and document their operation. Section 192.745(a) requires 
Respondent to inspect and partially operate each transmission line valve that might be required 
during an emergency at intervals not exceeding 15 months, but at least once each calendar year. 
In its Response, Respondent acknowledged that inspection forms used to record several valve 
inspections did not show that the valves had been partially operated, Respondent stated that the 
valves were operated at the time of their inspection, but the employee performing the inspection 
inadvertently did not record their operation on the designated inspection form. Respondent 
submitted copies of the original inspection forms subsequently corrected to show that the valves 

had been operated at the time of their inspection. Respondent also submitted three affidavits, all 
dated July 12, 2005, signed by Respondent's Operations Specialist, Respondent's Operations 
Supervisor and a contractor. The affidavits state that the valves were operated by Respondent's 
Operations Specialist in accordance with Respondent's procedures at the time of the valves' 
inspection. 
The original valve inspection forms witnessed by PHMSA inspectors during their inspection did 
not record that the valves had been operated in accordance with 5 192.745(a). When PHMSA 
inspectors drew attention to the apparent noncompliance, Respondent corrected the forms by 
having the employee responsible for the inspections mark on the forms that the valves had been 
operated. Although Respondent stated in its response that the employee merely "finished 
completing" the forms in front of the inspectors, the original valve inspections were performed 
several months before the PHMSA inspection in June 2004. In a few cases, the valve inspections 
occurred almost two years before the PHMSA inspection. Accordingly, I cannot find that the 
employee was merely completing the forms when he made changes to the forms during the 
PHMSA inspection. Nor do I find the affidavits submitted, which were signed between several 
months and almost two years after the valve inspections occurred, are sufficient to demonstrate 
compliance with 8 192.745(a) and Respondent's procedures, which require Respondent to 
inspect and partially operate the valves at intervals not exceeding 15 months (but at least once 
each calendar year) and to document compliance on the designated inspection form. 
Accordingly, I find Respondent violated 5 192.745(a) by failing to partially operate transmission 
line valves that might be necessary during an emergency and document the operation. 
ASSESSMENT OF PENALTY 
Under 49 U.S.C. fj 60122, Respondent is subject to a civil penalty not to exceed $100,000 per 
violation for each day of the violation up to a maximum of $1,000,000 for any related series of 
violations. The Notice proposed a total civil penalty of $9,500 for the violation of 8 192.745(a). 
49 U.S.C. 8 60122 and 49 C.F.R. 190.225 require that, in determining the amount of the civil 
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, 
degree of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability 
to pay the penalty, good faith by Respondent in attempting to achieve compliance, the effect on 
Respondent's ability to continue in business, and such other matters as justice may require. 
Respondent did not provide information in mitigation of the proposed civil penalty beyond its 
challenge to the violation. A violation of 8 192.745(a) concerns the safety of valves that may be 
needed during an emergency. Emergency valves must be operable at all times in order to 
prevent and minimize danger to the public and environment during an emergency. Respondent's 
failure to ensure the safe and reliable operation of emergency valves threatened public safety and 
the environment. 
Accordingly, having reviewed the record and considered the assessment criteria, I assess 
Respondent a total civil penalty of $9,500 for the violation of 8 192.745(a). Respondent has the 
ability to pay this penalty without adversely affecting its ability to continue in business. 

Payment of the civil penalty must be made within 20 days of service. Payment may be made by 
sending a certified check or money order (containing the CPF Number for this case) payable to 
"U.S. Department of Transportation" to the Federal Aviation Administration, Mike Monroney 
Aeronautical Center, Financial Operations Division (AMZ-300), P.O. Box 25082, Oklahoma 
City, OK 73125. 
Federal regulations (49 C.F.R. 6 89.21(b)(3)) also permit this payment to be made by wire 
transfer, through the Federal Reserve Communications System (Fedwire), to the account of the 
U.S. 
Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire 
transfers should be directed to: Financial Operations Division (AMZ-300), Federal Aviation 
Administration, Mike Monroney Aeronautical Center, P.O. Box 25082, Oklahoma City, OK 
73 125; (405) 954-8893. 
Failure to pay the $9,500 civil penalty will result in accrual of interest at the current annual rate 
in accordance with 31 U.S.C. 6 3717, 31 C.F.R. 6 901.9 and 49 C.F.R. 89.23. Pursuant to 
those same authorities, a late penalty charge of six percent (6%) per annurn will be charged if 
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty 
may result in referral of the matter to the Attorney General for appropriate action in a United 
States District Court. 
COMPLIANCE ORDER 
The Notice proposed a compliance order with respect to the violation of 49 C.F.R. 192.745(a). 
Under 49 U.S.C. 6 601 18(a), each person who engages in the transportation of gas or who owns 
or operates a pipeline facility is required to comply with the applicable safety standards 
established under Chapter 601. Pursuant to the authority of 49 U.S.C. 6 601 18(b) and 49 C.F.R. 
190.217, Respondent is ordered to take the following actions to ensure compliance with the 
pipeline safety regulations applicable to its operations. Respondent must- 
1. 
Achieve compliance with 49 C.F.R. Ħħ 192.745(a) for each transmission line valve in the 
Fritch District that might be required during an emergency. For the purpose of this 
Order, the Fritch District includes Balko, Stinnet and Pampa Districts. Demonstrate 
compliance by submitting sufficient evidence to show that each valve has been inspected 
during the most recent calendar year(s) in accordance with 6 192.745(a) and 
Respondent's Operations and Maintenance (O&M) procedure number 301 and Planning 
Guide procedure 1-0306. 
2. 
Complete Item 1 and submit documentation of compliance within 30 days of receipt of 
this Order to the Director, Southwest Region, Office of Pipeline Safety, 8701 S. Gessner 
Dr., Suite 1 1 10, Houston, TX 77074-2949. 
The Director, Southwest Region, may grant an extension of time to comply with any of the 
required items upon a written request timely sl-lbmitted by the demonstr~ti~g 
good 
cause for an extension. 

Failure to comply with this Final Order may result in the assessment of civil penalties of up to 
$100,000 per violation,per day, or in the referral of the case for judicial enforcement. 
Under 49 C.F.R. Ħħ 190.215, Respondent has a right to submit a Petition for Reconsideration of 
this Final Order. The petition must be received within 20 days of Respondent's receipt of this 
Final Order and must contain a brief statement of the issue(s). The filing of the petition 
automatically stays the payment of any civil penalty assessed. All other terms of the order, 
including any required corrective action, remain in full effect unless the Associate Administrator, 
upon request, grants a stay. The terms and conditions of this Final Order are effective on receipt. 
APR 1 0 20063 
Date Issued 
ss iate Administrator 
r Pipeline Safety