Interview of Donald Payne - 4/5/01

Transcription

1 Interview of Donald Payne - //01

2 -- BEFORE THE NTIONL TRNSPORTTION SFETY BORD FIELD INTERVIEWS 1 EL PS0 NTURL GS COMPNY ) NO. DC00-MP00 1 Kayser Center I 1 st Floor Conference Room 0 N. Stanton El Paso, Texas Thursday, pril,001 The Interview began at :Ol a.m. Interview of: DONLD R. PYNE

3 1 --. i u BEFORE THE NTIONL TRNSPORTTION SFETY BORD 1 FIELD INTERVIEWS EL PS0 NTURL GS COMPNY t) ) NO. DC00-MP00 Kayser Center I 1st Floor Conference Room 0 N. Stanton El Paso, Texas Thursday, pril, 001 The interview began at :Ol a.m. Interview of: DONLD R. PYNE PPERNCES: On behalf of the Witness: SNFORD M. SUNDERS, JR., ES. kin, Gump, Strauss, Hauer & Feld, L.L.P. 1 New Hampshire venue, N.W., Suite 00 Washington, D.C. 00 (0) - BENNIE BRNES Manager, West Pipeline Corrosion Services El Paso Corp. E. th Street, Suite 0 Tucson, rizona (0) - Executive Court Reporters, InC.

4 PPERNCES: (COnt. On behalf of the NTSB: (I RVIND M. CHHTRE CLIFF ZIMMERMN ccident Investigators National Transportation Safety Board Office of Pipeline and Hazardous Materials Safety 0 L'Enfant Plaza East, S.W.- Washington, D.C. 0 (0) 1- On behalf of the U.S. DOT: RICHRD J. LOPEZ, Sr. Engineer GUSTIN LOPEZ, Engineer U.S. Department of Transportation. Office of Pipeline Safety Research and Special Programs dministration 0 LaBranch, Suite 0 Houston, Texas 00 (1) -

5 WITNESSES: DONLD R. PYNE EXMINTION - -

6 f' Ll 1 a 1 1 e/ PEcEEP1NGS MR. ZIMMERMN: I am Cliff Zimmerman, the investigator in charge for the NTSB for the accident that occurred on ugust the 1th of 000 on the El Paso Gas pipeline south of Carlsbad. In these interviews we're trying to get some background information that will help to avoid this type of accident occurring in the future. The person we're going to interview at this time is Don Payne. BY MR. ZIMMERMN: EXMINTION Don, would you state your full name, please? Donald Ray Payne. Thank you. nd a business address where you're located now? Railroad Drive, El Paso, Texas. MR. ZIMMERMN: Thank you. Now I'd like to go around the table and have everybody introduced to you so that you know who is in the room today with us. Safety. Safety. MR. CHHTRE: Ravi Chattre, NTSB. MR. R. LOPEZ: Richard Lopez, Office of Pipeline MR.. LOPEZ: gustin Lopez, Office of Pipeline MR. BRNES: Bennie Barnes, El Paso Corporation.

7 (Li: MR. SUNDERS: Sandy Saunders from kin, Gump, Strauss, Hauer & Feld as the personal representative for the interviewee. BY MR. ZIMMERMN: Don, could you tell us the position that you have at this time with the company? of the accident? I'm in the process of retiring. Can you tell us what your position was at the time Manager of Compliance Services. Okay. nd why don't you give us a history of your background in pipelines, and if you have some before El Paso Gas you could start with that? I've worked for El Paso Natural Gas for years, Okay. I'm an engineer. Where did you go to school? I went to the University of Texas at El Paso. I have a Bachelor's in Physics, Bachelor's in Electrical Engineering, a Master's in Physics. nd the Master's is from the University of Texas through studies here in El Paso. Could you give us a little bit of your background and your progression through the company and different assignments that you've had, different positions?

8 Right. The first job I had was with Codes and Standards in the Engineering Department. I was the editor of the Manual of Engineering Standards. I also was responsible for setting and reestablishing MOP for pipelines in the Permian Division and the gathering systems. In I was promoted to Supervisor Pipeline Services for the Permian Division. nd I had the compliance, both DOT and environmental compliance for the OC d division. I also was in charge $#well I'm sorry; what? Well ties. Tying to wells. Oh, okay. ties. Okay? Because, you know, Permian Division at that time was not only in mainline transmission but it was also a gathering system, quite extensive gathering, both low pressure and high pressure. Okay. nd I was also in charge of the hydrostatic testing group, the survey group and facility inspection. Okay. nd you were in that job until? Two years in July -- on July I, I became the Manager of Compliance Engineering. Duties included compliance to DOT pipeline safety regulations and environmental regulations.

9 nd you continued in that job until? Well, it's had different names, okay. nd the organization has changed a little bit. ll this time from ' to, well, we were in Engineering Operations until ' and then I changed to Operations Services. nd other than losing the environmental at one time, getting it back and then losing it again I have kept the pipeline safety compliance. time? nd back in 1 who did you report to at that Syl Nunez. Syl? Nunez, yeah. MR. R. LOPEZ: Can you spell that? THE WITNESS: Yeah, N-U-N-E-Z. MR. R. LOPEZ: Okay. BY MR. ZIMMERMN: nd his title was? Director of -- the first part of the year he was Director of Transmission Operations Engineering and then he was Director of Operations Services. nd that was after the reorganization then when it was Operations Services? That was right in the middle, right, it was right in the middle, ' the reorganization occurred at the end of

10 ,/-* Tdt.e W L 1 March. In the first part were in Engineering and the second part we were just in the Services Group. Okay. Tell me what if you would your -, responsibilities were then at the time of the accident at Carlsbad? I was in charge of ensuring compliance to DOT -- pipeline safety regulations and trucking regulations. lso I had the training function. But it was a minor training function like more administrative than actually doing the training. Was it administrative like -- Right, we had -- No, we had one person that was kind of in charge of helping get the development plans together for the next merger. nd she answered to me. But most of the time what I did was just sign the check for training in the field, so to speak. We didn't sign checks but we just approved the money. Right. pproved it. Okay. Did you have responsibility for environment also in this position? No. No? Not at the time. Okay. I think I'd been removed from that position about

11 f- L 1 a year before. There was another reorganization. Well, it was another merger actually. Okay, so -- The Sonat merger. Then that's when I no longer had the environmental. That merger was what again? Sonat. a Oh, okay. So if the accident was in ugust of 000, approximately a year prior to that is when the environmental? I don't remember the exact date of that merger but 1 I'm thinking it occurred in October of the previous year. 1 Okay. 1 We've had a few mergers, It's kind of hard to keep 1 them straight. 1 Is the Compliance Group responsible for 1 distribution of Operations and Maintenance Manuals and company procedures? 1 Well, not all -- When you say company procedures 0 there are a lot of company procedures. We're responsible 1 for the implementation of procedures that are directly related to the O&M. We assist with some other procedures that aren't directly related to the O&M. Could you give us some examples of ones that are related to your duties then, what are related to them?

12 000 LJ1 Okay. Of course the O&M itself and its L procedures. nd the 0&M directly references the Corrosion Manual in its entirety, the Coating Manual in its entirety, the portions of the Measurement Manual, portions of the Compressor Manual, portions of the Pipeline Procedures wb Nlle whgmc &Ut=, WOE MUhS 0 bd-@ Manuals We distribute the emergency plans. I nd I'm sure there's a couple others in there. But we've got a lot of manuals in some way connected to the -- we take care of the -- Engineering has been doing it but we're going to take it over and stuff. The manual for the MOP of our pipeline system. 1 But that's something you're going to take over and 1 haven' t? 1 Well, portions, we're responsible for it, okay. 1 1 They've been doing it up to this point.- We're taking that over. Except that we take care of the measurement MOPs and 1 make that distribution. Okay. Can you tell me just a little bit more 1 about what is in the pipeline procedures manual? 0 They would have purging, pigging, hot tapping, 1 some of those rules and stuff. Let me see. Now we have pigging protocols, smart pigging protocols are in there. When was that created? Well, in the OtM that was in effect up to May of ~ those protocols appeared in the El Paso Natural Gas 0&M - -

13 I 1 1 L' Manual. When the new 0&M Manual took effect those protocols were removed,,okay. nd basically we just -- we moved them to ours and kept them off to the side. they were still our protocols but they weren't the entire corporation's protocols. Manual? nd that's why they're in the Pipeline Procedures No. No? No, there's more story to it. More story is we had been pushing to get it in. nd it was an agenda item. nd then after the failure on ugust the 1 then that speeded up those and they were approved I think pretty recently. We had, we went outside the company to get support on re-writing the protocols. present them to DOT in the system integrity inspection pilot program. Okay. nd we wanted to nd just because I mentioned this, that falls under my duties, the system integrity pilot program. The people that -- our liaison with DOT works for me. Okay. Now, that's, you know; certainly a lot of manuals that are associated with the O&M Manual. So how do you ensure that the latest information is distributed then to the

14 1 1 /- 1 [W: It's on our website. It's on a website? Right. nd then we roll out each one of them to all the organizations first, the main ones that are responsible for the particular activity. nd then we roll it out generally to those people that have -- that fall under those people that are generally responsible. For example, the Corrosion Manual. The Corrosion Manual is rolled out by the corrosion experts to the corrosion technicians. nd then in turn we roll it out to the rest of the population inside the company. nd to date they've rolled it out to our technicians and they've got schedules or scheduling rolling it out to the rest of the population. Okay. re you talking, right now it sounds like you're referring to a specific procedure that you have in mind that's being rolled out. What procedure are you referring to? out in the past? No, no. That's the whole manual. The whole manual. That's every procedure in the manual. Okay. There's an existing manual that had been Right. nd now there's some revisions or what are we

15 talking? Right. When we -- prior to the incident, the accident, prior to that we changed the O&M, okay, from our individual one to combining it with Tennessee and Sonat. nd this was approximately when before the accident? Well, we were working on it a year, almost a year before that. nd we'd got John Kiefner to take all the manuals from Sonat, El Paso and Tennessee and combine them. Okay. So you had this process going on where you were putting everything together -- Right. -- and then finally you were ready to roll it out; is that it? That's correct. nd this was approximately when? That we were going to roll it out? Yeah, that you -- Well, we have to go through stages. ll right. Stage number one there's the first you've got to have some document to work with. nd so we got Kiefner to get us going. nd then we set up teams to work on different parts of it. - IMP Corrosion had their team, for example, Measurement had their team, Pipeline had..-

16 c 1 1 their team. nd Compliance had people on each one of these teams and sometimes leading the charge so to speak and getting them done. nd I don't remember the exact date that we finished up with all this work and got it approved by a took it to DOT and said these are new O&M Manuals. review them. nd they had no problem. w# went through them, approved them.& was was us Okay. a lot of changes this time. Okay. Please The prior approval which Because these are very good procedures. Okay. Because we were taking the best of three pipelines, combining them. nd there was a lot of experience in different areas and stuff that made it. For sure the Corrosion Manual is probably one of the best manuals that covers more procedures, a lot more than we have, a lot more than say Sonat and even a lot more than what Tennessee had. So we were taking the best of all of them and trying to come up with some very good, decent procedures for covering all w L & - -.'

17 L: 1 LJ areas of corrosion. Let me take a specific one right now and we'll follow this one and how you -- Okay. -- you know, things go into effect. Okay. Well take the, if we could, the one that I'd like to talk about is number 00, Internal Corrosion Control. Okay. Which is dated //000. ' Okay. 1 Would this be part of the -- 1 Yes the Corrosion Control Manual? 1 Right. Right. 1 Okay. So I would like you to characterize what / of 000 means and tell me, you know, obviously you some document that's ready to prepare? Well, it's internal, right, it's the internal corrosion section of the' Corrosion Manual. a,>- Okay. nd it starts off by doing; you know, trying to define what a corrosive gas is. nd then when you find a corrosive gas it sets down what you do and who's responsible for each particular item. nd it talks about the mitigation '* had 1 I - -

18 if you find internal corrosion and any reporting that you have to make to different people. Okay. Now, let's talk about the mechanics of how you roll this out. So on / of 000 it appears that this was, you know, a procedure of the company. Right. nd it was part of the Corrosion Manual. How did you roll this out so that people would know about it? Let me tell you. I tend to give an example that I -Y like to give about how things roll out and becomes.i effective. NTSB has been trying to get a op. qual. rule, actually a training rule for many years. nd DOT came up with a op. qual. rule that became effective pril of last year. nd it's taken about three years for them to roll it out into pieces to get it out and make it totally effective. similar thing happens when you go into industry. You could say this day this is our new one, and then it takes a little bit of time to get it rolled out to all the places and get the manual at the time. nd so even though- - WH&U r'c: w we got the acceptance on a certain date whw- I, y@l -w& became the rule, then we were going to take at least half a year to get it rolled out to everybody. 0 RaLbrr)b memfimuc, So while this is in process*0+gdflg the failure occurs. nd I think what the technicians were -- I don't know exactly what date in ugust they had a meeting, but

19 1 F. \b 1 a 1 l ia they were getting, again, the first batch. They're the ones that were important. They're in the school, they're rolling out this. Okay. DFT- Now, as far as implementing it =Inrlztl.fiF, before,>~f&y$*eg~~!l;~ -&&yz';ygg!r the failure the things that were set up in there were not pp&gg$h totally implemented before the failure., %e-, ~~~~~~q om v ~ & &W(0 rntd' filcchnt CI Okay. nd, okay, so we're up into ugust and then the failure occurred? Right. What has been done then since ugust up to now as far as amending it then? Well, about amending it? This particular one. Right. What date do you have? / of 000. January of 001 they amended it again. nd I'm sure they had two or three meetings in between where they've discussed it. Okay. every other month. That group that's in charge of that meets maybe nd you'd probably have to ask Bob. He's their representative. In fact, Bob, Bruce and Ray are all representatives on it. I'm sure that they were talking quite extensively following the failure about what they should add to make it -- to improve it. - -

20 I 1 r-'. 1 L That's Bob Babnick, Bruce? Bruce Norred. Norred. nd? Ray Vega. Ray Vega, okay. They're the corrosion coordinators for our company. t the time of the failure. Now, we also have compliance that are members of that committee. Generally I was their compliance person. I met with them. to see if it complies with the rules. currently John Chen is taking over that. from &R Pipeline, and he's there, the compliance member on that committee. months or something like that. First they sent stuff through me to look at nd right now we have nd John Chen is He's been on that committee for maybe three From what you've said here I believe that this procedure was -- Was this procedure part of other revisions in the Corrosion Manual, the whole Corrosion Manual -- Right. -- was rolled out at that time? t that particular time into the technicians. nd then, right, and this is July obviously, /.. Right. nd then there was a meeting in ugust? Right, yeah. training session...- '.

21 1 I f ---\: -L 1 F-. Training session. Training session. They rolled out that then. With the corrosion techs. Now, at the time that this would be issued, /, is that approximately the date it's going to get on the internet? How do you, you know, -- Yeah, it was pretty close to it. -- I mean if you create it / you can't put it, you know, it's not on, -- t- It was on the Lntdv -- w -- I recognize it might not be on there that day How do they do that. (Witness and counsel confer.) Go ahead, I'm sorry Well, I recognize it might not be on there that 1 day, yeah. Can you tell'me what happens here with something like that? (rjtwwi bcr H&SU& rrjmlur m@ Tom Brockington from Tennessee is in charg of the CIJ&rb WUW oa% sites, okay. nd he would have put it on the site when it was approved. So he may even have some records if we -- you know, when it was available to people? Right. Okay. So then that's on the internet site. Now, it's on the internet site. How do people know that it's on the internet site, how do your managers and your technicians 1..-

22 0 L; L-J and anybody in the company that needs to know, how do they know? We rolled out the 0&M during this time starting from the time we got approval from DOT. nd we have records showing where we went to each one of the locations rolling out the 0&M. t that one, at those roll-outs we told them where they could read all the approved manuals. So those roll-outs you would talk about the changes that were made in the manual? In the 0&M. The 0&M. We had a presentation that was put together by Bruce Campbell and Darren Moore. O&M. They're the editors of the Okay. nd just so I'm clear, when you have this presentation and you roll out the 0&M you also discuss the manuals that are referenced in the O&M at that time? copies of the 0&M, That's right. nd at that time we had with us okay, copies of those manuals that apply, okay, but only copies or the training. We told them, we directed them to the website. Okay. Because these locations we had to go to are far, and to drive everybody's around with us handing them out, but we didn't want them to get the manual without the - -

23 L 1 1 explanation. Okay. so now we've got this rolled out and it's on the website. nd then your group does compliance audits. So we've got new things in the manuals. How do you incorporate those into your audits? nd I'm speaking specifically about this one, not general, but how you did things as a result of these, you know, changes in 000 that we're talking about? The way it's done is when the people go out for their next audit and they're supposed to be cognizant of the new things that are in the different O&M parts and then they 1 go out and start asking the questions, obviously they would 1 ask the question, one, do you have any evidence w 1 of corrosive gas? nd if they did then we would want to see 1 the records that are required by DOT and required by the 1 O&M Have you had any audits in any part of the company since this one was rolled out? I believe El Paso District was done. They're doing Phoenix right now. nd they did Bakersfield. gain, the question there would be asked, do you have any corrosive gas? I'm sorry? That you have corrosive gas. Okay.

24 Do you have evidence of corrosive gas? nd I'm almost sure that they probably say no in those particular, like Bakersfield, for example. We're starting to get samples taken and taking a look at those and taking a look at gas streams, different parts of them. nd I usually send to my people a copy of lab reports. nd I say look at certain things for them to be aware of. For example, Bruce is in charge of the auditing of the lbuquerque Division. nd I would send him copies of lab reports that Bruce Campbell -- that Darrell Campbell sends me. Okay. I think it's for example purposes here, and specifically about this internal corrosion standard too, we'll just keep on this one. But there's standards like for 1 pages so there's a lot of things in here that are Twenty-seven pages.' Okay. It's been expanded then in the recent? Right. Okay. ll right. So let's stick with this one though for right now rather than going to the one in 001 and what you're doing. We can, yeah, January 1, 001 it was revised and now it's -- So you want to stick with that one then? Yeah, just for right now. We'll talk about both of them

25 Okay. But I want to stick with this one in July so that I can understand what happened then and maybe what's happening now. nd the company is changing and, you now, reorganizing and I'd like to, you know, be up to date on how you handled things in the past at least at that point in time and how you might be handling them now. So I want to try to be clear about that. s a result then of the, you know, this being part of your standards in / of 000, we've got new things that need to be done that weren't part of your procedures before. Did you change your auditing procedure for things that were specifically now required that people do, that managers need to do, to be more specific? w Right a& tl at the time that it came out or? Or since then, yeah, right. Okay. Then let's move up to the one on 1/1/001. Have you done anything to change your compliance auditing procedures Checklist, whatever, to incorporate any of those changes? I didn't understand that. What are you saying? Well, not only did you, yeah, I mean this one was issued back in July and then in January you issued a revised Executive Court Reporters, InC...-

26 .n 1 1 r' 1 :b one. nd I'm just wondering if at the point when that one was revised you made any revisions to the way you audit your complexes -- Or they're called districts right now? reas. reas right now. Okay. -- your areas so that, you know, when you audit the area the manager needs to do certain things and that, you know, the new things that are required in these procedures are now part of what you audit. Right. That's what I'm asking. Nothing more than I've already said. The procedures that we have are pretty well set. I know we were revising it for some other things,-. w nd, again, it takes a little while to get those things out. But I don't think we've gone in point by point, okay, written down exactly everything that's been changed, not only in this manual but in the other manuals too. Okay. Okay, because most of ou Or) proo SSbS. rrtv,tews. in the records nd that's the'way we've done our ri w. nd so if there's a record that's supposed to be orp W W ~ 'IfPL+# thj THe UbtrY sslooked at are general rules&. &otvut,, LL"&&% MWUlSL. ww If you looked at the way we do our check,k ;:- M it gives the opportunity for a broad range in the corrosion of what you're looking for. But in it includes n - -

27 b 1 R&W&PS te F* V we Mbwtes MOO things like coupons, to look and make sure- a& & do *s.- a pretty good examination on W. blw+* Now, what we're trying to do now is set up to, oae I@@CtFlt 1 1 L but we haven't written it in our procedures yet everything that's in that. But it would be. So do you intend to go through these -- bsolutely. -- and then add them -- bsolutely. right now. Ravi? MR. ZIMMERMN: Okay. That's all I've got for BY MR. CHHTRE: Hello. Hello. Who was the compliance lead for the Corrosion Manual, do you recall? You said the compliance persons participate in. Me. 1 That makes it easy. Okay. I want to go back to Roswell accident circa 1. s a result of that was the auditing process changed any?..-

28 c. 1 c/ No.. nd I'm referring now to the El Paso report that was issued as a result of the line 0 rupture. nd there were several recommendations made for line 0 for the internal corrosion viewpoint. Did the compliance follow those and require the other regions or lines to follow the same recommendations that were made for line 0? In all of it? I'm sorry. You're sure we did more than one; eight? More than one. More than one recommendation. bsolutely. I'm not sure exactly what we did. (Witness and counsel confer.) THE WITNESS: There's only, basically there's only one recommendation in the report, it's under "recommendations. " (Witness and counsel confer.) THE WITNESS: I know. But the approved recommendations are in the section called "recommendations." Up to then they're recommendations-for recommendations. Okay? BY MR. CHHTRE: Okay. Executive Court Reporters, InC. - -

29 ... i 1 a mst L &?I- (Witness reviews document.) &DMX#rp ov ma cetbipui. * rde espoct WS ~u"vm0 'td D I M * Now, your question? ~ ~ ~ ~ centttuvo * ~ S. lu sur FIUCLM+Nr *Y &U 0 BY MR. CHHTRE: &llipulb&u RaVaSao PWOUC m& at" m DD ~twttaa P~UI The question is any of these recommendations were extended to the other areas, regions and other pipelines? nd, again, I'm referring to transmission lines only from the internal corrosion viewpoint. It's my understanding, okay, that other areas were ultrasonic tested, okay, when pipe was uncovered. I've seen bell hole reports. Okay. Some of the other stuff that's mentioned here was -- became moot later on because we did a smart pigging of the area, okay, lookin for any other type of internal corrosion. So,,we didn't carry through with some of the R~to&Ytwuw#e OF rwa swllcr 1 R things in this particular-.& Of course, we continued to sample gas, ok y. This was ', okay. That tutwmto "0 d year we,,, abnormal condition report and an abnormal condition procedure. upsets due to H,S. IPU U0rTWIL.t &r nd in that procedure we asked for any nd that was considered abnormal condition and that went through the channels. We had already on some of our lines that carried -. S, H -PW nd we do that, it was once a month for those particular pipelines and compliance checked ParrrLI - -

30 f- -.i 'u 1., -. L; them. c I don't believe we hydrostatically tested the area. But there were pipe that was replaced that was hydrostatically tested. nd some of -- this particular pipeline was already in a program to hydrostatically test, theh&-. GUnM PcVCttdC. n&e - But other areas,$ w you in the Waha area we took samples and we took them I can tell before, we took them after, we take them today. Okay. We sa! pcss take--. We have taken samples of the constituents of CO,, H,S and water throughout the system anyway, okay. so it was a matter of people looking at those things. nd So it wasn't something that compliance had to go out and tell the rest of them to do because in my view they were doing it. But as a compliance auditing process would the compliance auditors look at the information to make sure that upset conditions were reported? Was that a part of the auditing process? conducted that. Right. Right, that was a part of the audit. I Because the way that it was coming through on the abnormal condition report, it would come through me and go to the person that was responsible for the abnormal condition. nd the abnormal condition in this case, like for example it was interkttent H,S. right because I understand you guys have a problem with the I have to say that

31 word "slug." But that's what we call it. nd it's an air, it's air -- I mean not air but gas, a slug of gas, ll right, maybe that's what happened. Goes through the system, okay. That's considered abnormal. nd that's relayed to the party that's in charge, you know, like for example if it went through Carlsbad rea then Johnny Cole was called. Okay. If it went through the Jal rea -- and it's not called, it's all computerized. They would get it, I would get it, okay. nd my responsibility at that point during the auditing process, one, did they respond to it? Okay. What did they do? Okay. Is there any way that we can keep it from happening again? But it was only for the constituent of H,S. But we are taking, we were taking samples of CO, at a bunch of sites and water samples. But during the auditing process would the auditor ask the area manager or superintendent, whatever the title may be at that time, about the excursions or slugs or? Yes. I would do it when the -- I wouldn't wait for the auditing process where we go out and sit down and run through the checklist, we'd ask them right then. nd if you have a chronic, well, if you have some pipes with a chronic problem of -- Right. -- passing the undesirable constituents or above

32 Ll 1 your recommended numbers would the auditing department then ask them, ask the area managers or require them to install some corrosion monitoring? Yes. In any of the transmission lines, 0 -- I'm sorry, 1, and 10 had that kind of history in the past that you recall? No, they were intermittent is all that we saw. When I say intermittent, long periods of time in between it. the corrosion monitoring? Was there some kind of a 1 nd at what level you would require them to have guideline number given that three times a year if they have r- 1 upset conditions you would do it? b 1 No, we don't have that. 1 So do you recall if any of the -- 1 We have it now. But I mean at that, you know, up 1 to that point. Right. This is pre-accident. 1 Right. Pre-accident, no. We were looking for 0 something more sustained, okay, like it was actually 1 carrying the gas without being treated at all, okay. s a result of line 0 Roswell rupture was any of the superintendents required to monitor and they reported upset conditions were required to install the corrosion monitoring? m I clear or not? 0 - -

33 '..b Yeah, I'm not clear of what you mean. ll right. s a result of Roswell accident where internal corrosion was found. Right. nd there's a report. Right. s a result of that accident did you have any guidelines that you would require the operators to install the corrosion monitoring as a result of that accident because of the frequent excursions? Right. There were no frequent excursions at Roswell. Okay. So if we're saying that the cause of that accident was a frequent excursion at Roswell, as far as our investigation,proved it was not. That other than a isolated excursion area, I guess, from one particular well. nd that's what we said it was, all right. Our first response to that is maybe it is, so - w let's see what we've got on the rest of that pipeline. So ~ppato00ts tu-1 CO&~W~@& we ran the smart pigs. nd didn't find the,-. So we don't have any more there, it's isolated. Do we need to do a lot more at the other areas and stuff other than what we originally had on our list? Okay. I don't think that came up. I think in the risk management program this became a topic of how to address it. t that time? - -

34 a 1 p '. t that time. nd does the compliance participate in the risk management process? Compliance ran it, okay. We had more members on it than any other group. nd the man in charge of it was Larry Meyer. nd he works for me or did at that time. MR. CHHTRE: Thank you much. MR. ZIMMERMN: Richard? BY MR. R. LOPEZ: Since your department or you were responsible for El Paso Natural for the O&M and all the parts that go with the 0&M, when I speak to the O&M I also include the Corrosion Manual -- Right. -- since it's part of the O&M. The old one had Corrosion Manual included. Okay. nd I'm particularly interested in the changes that are made to the 0&M and how they're implemented to the field. nd you gave us an analogy with the NTSB rule and now we implement this. I'm sorry about that. That's okay. nd you well know in our regulations we say the implementation date is effective and it will give you a date. Give me the -- Now I wish we'd a done that too...-

35 . i f --. L' 1 with El Paso? Can you give me an equivalent date how it works Usually it's done by the individual groups that are in charge of the roll-out, they have a schedule to meet. e Okay. nd this schedule is generally, it's a written 1s Dbwrtrrlr~~a by c schedule. nd this written schedule,,- Pat - in 0.% mf Carey who is in charge of compliance, DOT compliance 1s the fr a one that dictates the schedules. nd my understanding he's getting that from the team. The merger team wanted the implementation thing. nd they set up the schedule for each one of the things to roll out. 1 Okay. 1 Okay? 1 Now, but as far as past changes, not future 1 changes, past changes how does El Paso know when the meter 1 starts? I made changes to the O&M how do people within El 1 Paso know when the meter starts? Right. We try to do it, okay, when we have our, 1 you know, the meeting where we roll it out. That's 0 1 generally the time. Because up to that point there's a possibility that a technician doesn't get to see this. Right. So we set up a time for our compliance, for say, all right, we've got a new one here, here it is. We samplings on it, for our compliance guys to go out there and try to do it as close to that date as we can, okay. Executive Court Reporters, InC. - -

36 i/ 1.- L; O&M? Is that the same date that's on the bottom of the That date usually occurs first before we roll out. nd the reason for that is we have to get certain approvals. nd we have to put the date down of, you know, after the approvals. For example, we have one pipeline that is under the jurisdiction of the Railroad Commission. nd for us to get approval of a new O&M we have to send the whole thing in to them and they have to look it over. nd they send us a PhRava letter back saying, well, we don't it and our inspector next time he's out has to do it. But their rule says we have to have it in 0 days before it goes into effect. So we don't very well go out before and bring our people up to date on that O&M, we have to give it a date and then go out and get it to go. Okay. That's generally we could probably do that, say, all right, this is the date it's effective and this is the date it really takes place. Kind of like you guys do. Okay. We normally don't do it. We try to do it, you know, kind of systematic with the nwr!/jut# ow We want the person trained on it and then it's in w. effect. Does that make sense? Not really, But I'm going to continue with it. - -

37 /-- L; 1 _ ii Maybe I didn't understand it. 0&M, Not really. Well, when the O&M was inspected -- I shouldn't have asked you that. -- by DOT at the desk what effective date is this how would you respond to that? The effective date of it? Well, at the time they came in we had a date on it and they approved or they wanted us to wait, we waited till they got the approval. we'll put a date on it. you, is our management. nd they're the ones who's already approved it. approves it. they approve it. So I said once it gets approved then nd that approval process, mind nd we bring it to DOT and DOT looks at it and nd then we send it to the Railroad Commission and So that you may have some changes in 0&M if the 0&M inspection by DOT usually come at five year intervals? Except for us. Except for you, SII. Right. But forget about the SI1 program for now. Okay. Let's just say before. If we had five year intervals you mean to say that the 0&M would not be

38 f L/ effective until OPS approves it? No. It would be effective when then? In that particular case if it's in between the five years, okay, it's when we put the date at the top. Or at the bottom? Didn't you have dates on the bottom; is that correct? We do? I thought it was at the top. I don't know. Okay. But there is a date stamped on the procedure? f-- Exactly.

39

40 ...- i/' that's your point of view on that, you know, about how it matches up. I mean the way you -- that's not the way I would characterize it necessarily. Well, characterize -- I've already characterized it. Okay. So this is the one I didn't understand. The way I see it is that we go through the approval processes and then there's a date on it, okay. that date, I still have to do the training. wait till it's approved by everybody before I do the training. nd I have to nd there could be a little gap in between there of I'm still working on the old one until I get the other one rolled out. nd I know that's now -- well, that's the 1 Okay. 1 nd, by the way, that's the way we've always done 1 it. Now, I think we've touched on that. So that if 1 the date on the O&M or the procedure then you would also 0 start changing your audits? I think that's what we -- 1 Right. -- talked about the same time. nd the audits I mean your internal DOT audits. Right. Okay. Now, the regulations also require that nd

41 fl L 1 L: personnel review the procedures that impact them. example, if I'm a corrosion tech I would review the procedures that I would require to conform to; is that correct? Yes. For Okay. When do your, for example in the corrosion, 00 internal, when do they have to sign that they reviewed the procedure and understand it? How much? When did they do that? is once a year. they reviewed it. Generally they -- the way the procedure is written nd so they would sign it annually that nd they would -- the training, there would be a, there's what we gave at the training and then there's a sheet that they signed in at the training. nd the training is done for the internal corrosion and the Corrosion Manual? Right. When is that done? The training? Say it again? On the corrosion techs. Right. The training on the Corrosion Manual which includes external, internal procedures. Right, I believe that was done in ugust. No, I don't want a specific date. Those are done,

42 ! I 1 /oq I u 1 that specific date, those are done when you've gathered all of the technicians or do they -- No, they -- (Witness and counsel confer.) THE WITNESS: Say that again. I apologize. BY MR. R. LOPEZ: The corrosion techs meet once a year or once -- No, several times a year. Several times a year. Right. nd one of them they get together and have big 1 meetings and training are performed as I understand by the corrosion coordinators? That's correct. Is this when the training or when they sign off that they reviewed the procedures and understand them is done? separated. Okay. The word "understand" and "signing off" should be But they sign off, yes. Sign off. nd what do they sign off to? That they attended the meeting. nd then, of course, the content of the meeting is there, okay. Now, how do they satisfy the requirement in the Executive Court Reporters, InC.

43 0 LJ L j regulations that they had to review the procedures and understand then and know what they're supposed to do? What procedure are you talking about? The corrosion one. No, what procedure are you talking about where it says "understand"? Oh, what part of the regulations you mean? Yeah. Just tell me where it says. You know, they're supposed to review the procedures. says, review the procedures. Okay. Okay, I'll get to that in a little bit. That's what it We have other ways of doing it, okay. Okay, well explain to me then. Well, if a procedure that's changed from DOT is -- I mean from our stuff is substantial it would cause a change in the task that they have to sign off on. Okay. nd those they would have to resign. Okay. nd I believe we're in the process of doing that because m. mw potvs cal. Tna TScdaurerlG W,naP.lMW been waiting for#mue, we've been kind of held up because of the merger on getting all those tasks out. Now, that's an additional way. ut also they attend the school, the training school where all of them are rolled out. nd they go through them and they sign that they attended the school. Executive Court Reporters, InC. -

44 'its/ nd that's the way they do it. Okay. Okay, those are the technicians. Okay. Yes, the technicians. Now, there are other people involved. nd after they get through with the technicians they do it again. They take it out to the areas. nd those are also part of the roll-out. Okay. Those are technicians. Okay. Okay. I think we're on the same page now. Okay. What about the guys who are ultimately responsible for that, that is to say your area managers or complex managers, when are they trained? Yeah. They're trained when it goes out to the area. nd, you know, when we say they're -- under the new rule, okay, under the new rule it says they're responsible for the people, you know, to see that the people do the job. Because they themselves are not trained by experience, not all of them anyway are trained by experience or have experience or training in corrosion to run a corrosion program. But they have people that work for them or people that are In the loop. nd that's the way that particular -- they're in charge of making sure the work gets done. That's (01.) -00 1

45 L.: 1 their charge. Okay. They're not in charge of corrosion. They don't have to understand all of the corrosion but they have to understand what some of the tasks they have to perform? Right. nd especially some of the new ones. Exactly. nd that's when it's rolled out at that time. Okay. Okay? gain, we rolled it out -- what we would 1 expect our managers to do is when we roll out the 0&M and we 1 b said, Gosh, we've got more things in this than you've been used to, and give it to them, okay, then we expect them to get onboard themselves with it. For example, did you say that the changes in the internal corrosion went from to B and now -- Right, substantially. -- B requires some things that they had to participate in, the tasks that had to be performed, how do they know this, this is part -- are they given a list, these are additional jobs and things? We told them that, you know, when we went out that there were substantial changes in the corrosion when we rolled out the 0&M and we left them a copy of it. Executive Court Reporters, InC.

46 c. r. i,? 1 This has been done? Right. When we did the O&M. w When was this done? mrr, kle M&* t.0 Between,,-wbu we got final approval from DOT our guys started rolling out the OtM. So they should know now, today? They should know. Okay. They should know. ll right. But they got to know lots of stuff. No, I understand that. Lots of stuff. They have to rely on support. nd 1 their support comes from compliance and from those corrosion 1 guys and from the technicians themselves. I 1 I understand that Now they've got to be the ones saying, going to the manager and say, Hey, I've got a new rule here that says we're supposed to do, B, C, YOU know. nd he says, YOU do? Show it to me. That's usually the way it happens. nd they show 0 it to him. Right. nd then he does it. If there's any 1 problem with it then he might threaten saying he's going to call me up or something, you know. nd that's what happens. I understand that. I don't have any problems with that. ll right.

47 I'm going to change and go back to some stuff that was discussed earlier and that's the Roswell incident. Right. nd this is the distribution memo. I think you -- Right. -- might have a copy of it. Right. What I'd like to do, Don, is if you can review a copy of that with me, I asked about some of these guys that were on there and their job functions. But I didn't have a copy of it then. nd I'd like to review it again and go over this. Okay. McCubbin was the vice president of what? Of operations. Operations. nd O'Nan? He's Director of lbuquerque Division. He was director then at the time of the accident? That's correct. He's also a lead. He's the one in charge of this investigation. Okay. nd of course that's you, G.R. Payne? That's right. nd you were head of compliance then? You bet. nd Blaine Metzger who had the lines entity and

48 - 1 metallurgical and that sort of thing? Right. He was in charge of corrosion at the time too. His job was he was the Manager of Pipeline Services. Okay. But at the time of the accident you had already reorganized. The Corrosion Group he had was -- Three guys. -- the three? Yeah. Before that he had all the technicians. Okay. Before like May, May of ' he had all of the technicians and the -- Yeah, I don't want to imply here that he had all 1 i 1 the corrosion and one guy was head of It. had the Corrosion Group -- It was just he 1 1 He had the three guys. -- the gang of three? 1 Right. 1 three specialists.. ia rmen ta? 1 rmenta, he was the Manager of San Juan Division. 0 Baca? 1 He was the Director of Tucson Division. nd D.W. Campbell, Manager Engineering? No. He was in charge of the Gallup, well, rea I guess, it was complex then. rmenta, I'm sorry. -rmenta was San Juan rea,. Executive Court Reporters, 'Inc..

49 -. 1 okay. San Juan rea. Okay. Okay? nd Campbell is Gallup rea. Okay. nd W.D. Hall? He was my counterpart at that time for field services. Oh, okay. Compliance, field services. nd G.D. Hill? L; He was the Manager of Flagstaff rea,. W. Johnson? He was the Chief Engineer. nd T.P. Morgan? nd Mr. Wilcox? He was the Director of Midland Division. He was the Manager of Gas Control. a Okay. Now, by the distribution here we have areas that are not even involved with the 0 line -- That's correct directly. So, as an OPS inspector I infer that 0 this, although this accident reported attributed the failure 1 was unique to this particular spot, but you should be -- could I infer correctly then you might be aware that this could happen also in your pipeline? Yes. Very serious situation here. So that you ought to

50 look at these recommendations and perhaps consider if you have these to do what the recommendations say? everybody. Yes. That's the reason they were sent to That's what I inferred from this distribution. I - thought I was correct but I wanted to make sure. tp,rvd+ HI/ECOeMS M We- -t, &aez : b& thnpn tyrnnr -.i dietv+hit+-..- of my people had this report. Okay, nd I would make sure that the risk management team also had this report. nd when you say your people, yours were the auditors, the compliance guys, -- Right. -- the guys who ensure that or try to prevent accidents like this from happening again? Correct. compliance with was part of the up to according to -- Towards that end would they also be looking for the gas quality that's part of your, that corrosion standards then or procedures? 1 we would be looking at the gas quality Yeah. -- those constituents. In ' we went to the abnormal condition and we looked mostly at upsets with H,S.

51 /-- L 1 Yeah. nd this is important because it also went to gas control who gets, who also receives many of the alarms if the piping is so instrumented; right? Right. So the idea was keep the gas in the line and let it comply with the gas quality standard? (Witness and counsel confer.) a - Wait a second. Say that again. Okay. The intent here is, and always has been for El Paso as well as other operators, is the gas that's being a L; transported should comply with what's in the gas quality 1 standard? 1 Which is you're talking about a tariff or? 1 Yes, a tariff. 1 Okay. That particular part of the tariff 1 complying to that was through Measurement. Okay. 1 Measurement was in charge of tariff. nd their task would be, and in this particular case it's one person who is in 1 charge of the gas quality. Okay. nd he would see that 0 each one of the managers, if there was a gas quality problem 1 he would notify them. ;Jj He's getting data from a couple of places, okay. His data is coming from Darrell Campbell in the lab and it's coming from the alarms from gas control. Exactly. But it also says if you do not meet

52 1 a tariff, for example, it could be dangerous or unsafe to operate the pipeline if you exceed some certain criteria, critical points, if you have too much HS, if you have too much water vapor, pound standard? That' s not, that's not why he was -- they were worried about the tariff. I don't think anywhere in that particular discussion would there be a discussion as to what would be hazardous to the pipeline. When it goes to, when the information goes to the manager the manager would notify people involved and they would determine, you know, -- Yes. -- along with the Babnicks and those guys whether it posed a hazard. That, you know, that's different from -- you know, they're enforcing the tariff for one reason. For commercial purposes? Right. Then the other data is -- But that's how you also determine if gas is being transported, isn't it? How do you determine -- Well, let me ask you this: in the old procedures -- Old procedures. -- the gas, corrosive gas is being transported how did you determine this? Up to that point the -- we had, we had at this time, okay, one pipeline that they considered to be carrying corrosive gas. Okay. It may have run over to two pipelines

53 ,r*. 1 1 I 1 -L of which we had monitoring. Okay. That was continuous gas, okay. In the case where you have intermittent, not frequent excursions above tariff or whatever, we'd alarm and tell our people that. out, for example, they were getting some water vapors in the gas above, they would get an alarm, they'd notify people but they would ask the question am I -- is the gas stream I got right now in the main line dry enough to take care of that gas coming in? that time. Okay. But if they felt they were blending nd that's the way they looked at the situation at Did El Paso have a standard that they compared to? Was this the way you described the way it was done? I don't think there was a particular standard that they looked at. It was a judgment call on the part of gas control and operations on, one, could they blend it and meet tariff? Okay. nd consequently get it down to a point where they don't, you know, it wouldn't be a corrosion, corrosive gas. If they couldn't then they blew the gas. Okay. nd we're talking H,S or CO, they blew the gas. If they could not blend it they would blow the gas. nd there are places where we did it. Okay. 0