400 Seventh Street, S.W 
U.S. 
Department 
Washington, D.C. 20590 
of Transportation 
Pipeline and Hazardous 
Materials Safety Administration 
Robert Hogfoss, Esquire 
Hunton & Williams LLP 
Bank of America Plaza 
Suite 4 100 
600 Peachtree Street, N.E. 
Atlanta, GA 30308-22 16 
RE: Petition for Reconsideration or Clarification 
Kinder Morgan Energv Partners, L.P., CPF No. 1-2004-5004 
Dear Mr. Hogfoss: 
As you know, on June 26,2006 the Pipeline and Hazardous Materials Safety Administration 
(PHMSA) issued a Final Order to Kinder Morgan Energy Partners, L.P. (Re. CPF No. 1-2004- 
5004). 1 am in receipt of your letter for Request for Further Extension to File Petition for 
Reconsideration dated December 14,2006 and your Petition for Reconsideration or Clarification 
dated July 17,2006. Over the last several months we have met with Kinder Morgan to discuss 
and clarify the scope and timing of compliance directed by our Final Order. 
At these meetings we discussed completion dates for assessments and remediation of lowfrequency 
electric resistance welded (ERW) pipe and the propensity for some pipe to be 
susceptible to stress corrosion cracking (SCC). In addition, PHMSA issued a Corrective Action 
Order (CAO) to Kinder Morgan requiring a pressure reduction and a remediation plan. The 
CAO-related remediation plan requires a third-party review of Kinder Morgan's pig logs for 
axial flaws in ERW. 
Kinder Morgan has complied with our CAO by developing a new process to evaluate pig 
logs to better identify cracks. This process is more time consuming than the traditional 
evaluation process. However, it is our opinion that the benefits far outweigh the cost needed for 
testing. In light of the time required for the new process and amount of pipe that needs to be 
evaluated, Kinder Morgan's proposed remediation plan provides for completing pig runs in 
ERW pipe by 2010, with remediation completed by 201 1. We believe that the above times are 
consistent with the terms in CPF No. 1-2004-5004. 
During our Integrity Management Plan (IMP) inspection we verified that SCC and axial flaw 
detection in ERW pipe are included in Kinder Morgan's IMP, Kinder Morgan's proposed 
remediation plan for evaluating pipe for potential seam failures according to Kiefner's protocols 
is consistent with IMP regulations and consistent with the terms of the Final Order. 

Notwithstanding, Kinder Morgan must demonstrate that use of its newly developed 
evaluation techniques for Rosen's Axial Flaw Detection (AFD) tool is appropriate for finding 
and classifying linear cracks in ERW pipe. To confirm the AFD tool's abilities, PHMSA 
technical staff and its contractor met with Kinder Morgan in Houston, Texas on December 5-7, 
2006. PHMSA is in the process of evaluating the reliability of Kinder Morgan's overall process 
and, specifically, Kinder Morgan's plan to use the AFD tool and the GE-Ultra Sound Crack 
Detection tool to evaluate linear flaws in ERW pipe identified in its hazardous liquid pipelines 
IMP Plan. 
We appreciate your cooperation in resolving compliance issues associated with the June 26, 
2006 Final Order. Pending our evaluation of information gathered from the December 5-7th 
meetings, I am extending the deadline for Kinder Morgan to file any petition for reconsideration 
to January 19,2007. 
for Pipeline Safety 
cc: 
William Gute, Director, National Field Coordinator, PHMSA 
Joy Kadnar, Director, Engineering and Emergency Support, PHMSA 
Mark Wendorff, Acting Director, Eastern Region, PHMSA 
Rodrick Seeley, Director, Southwest Region, PHMSA 
Chris Hoidal, Director, Western Region, PHMSA 
Ivan Huntoon, Director, Central Region, PHMSA 
Linda Daugherty, Director, Southern Region, PHMSA