# UTICA EAST OHIO MIDSTREAM LLC — Notice of Amendment

**Citation:** CPF 120176002M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-06-08

CLOSED notice of amendment citing 195.402(a), 195.402(c)(13), 195.402(c)(2), 195.402(c)(3), 195.402(d)(1)(i), 195.402(d)(1)(ii), 195.402(d)(1)(iii), 195.402(d)(1)(v), 195.402(d)(2), 195.402(d)(3), 195.402(d)(4), 195.402(d)(5), 195.452(f)(3), 195.452(f)(5).

## Document text

Notice of Amendment involving UTICA EAST OHIO MIDSTREAM LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(13),  195.402(c)(2),  195.402(c)(3),  195.402(d)(1)(i),  195.402(d)(1)(ii),  195.402(d)(1)(iii),  195.402(d)(1)(v),  195.402(d)(2),  195.402(d)(3),  195.402(d)(4),  195.402(d)(5),  195.452(f)(3),  195.452(f)(5). The case was opened on 2017-06-08 and is reported as closed as of 2018-03-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120176002M_Closure letter_03022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Closure%20letter_03022018.pdf

120176002M_Closure letter_03022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Closure%20letter_03022018_text.pdf

120176002M_Notice of Amendment_06082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Notice%20of%20Amendment_06082017.pdf

120176002M_Notice of Amendment_06082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Notice%20of%20Amendment_06082017_text.pdf

120176002M_Operator Response To Notice_09272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Operator%20Response%20To%20Notice_09272017.pdf

120176002M_Closure letter_03022018_text.pdf

OVERNIGHT EXPRESS DELIVERY
March 2, 2018
James Roberts
Vice President of Environmental, Health, and Safety
Utica East Ohio Midstream LLC
600 Travis, Suite 5600
Houston, TX 77002
CPF 1-2017-6002M
Dear Mr. Roberts:
From August 10 – 14, 2015, a representative from the Pipeline and Hazardous Materials Safety
Administration, Office of Pipeline Safety pursuant to Chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Utica East Ohio Midstream LLC’s (UEO)
procedures in Salineville, Ohio. As a result of the inspection, UEO was issued a Notice of
Amendment (NOA) on June 8, 2017, which proposed amendments of its procedures.
UEO submitted its amended procedures on September 27, 2017. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in the NOA have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120176002M_Notice of Amendment_06082017_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
June 8, 2017
James Roberts
Vice President of Environmental, Health, and Safety
Utica East Ohio Midstream LLC
600 Travis, Suite 5600
Houston, TX 77002
CPF 1-2017-6002M
Dear Mr. Roberts:
From August 10 to 14, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United
States Code inspected certain procedures in Utica East Ohio Midstream LLC’s (UEO) Momentum
Gas & Liquid Pipeline Integrity Management Program, Last Revision Date July 2015 (IMP) and
Operation, Maintenance and Emergency Manual, Revised July 2015 (OM&E Manual) in
Salineville, Ohio.1
Based on the inspection, PHMSA has identified the apparent inadequacies found within UEO’s
plans or procedures, as described below:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted.
1 UEO is a joint venture between Access Midstream Partners L.P. (Access) (Williams Partners L.P. merged with
Access), M3 Midstream LLC (Momentum) and EV Energy Partners, L.P. See, William’s website, available at
http://investor.williams.com/press-release/access-midstream-partners-projects/utica-east-ohio-announces-major-
expansion (last accessed May 10, 2017).



CPF 1-2017-6002M
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for reviewing the manual at intervals not exceeding
15 months, but at least once each calendar year in accordance with §195.402(a) as prescribed in
§195.402(c)(3). Specifically, the OM&E Manual, Section 2 – Plan Review did not include a clear,
detailed process for reviewing the manual and documenting recommendations within the required
interval.
Subsection 2.1 Manual Review 195.402(a) on page 1 of 3 states: “This plan will be evaluated for
effectiveness every year (not to exceed 15 months) by the Vice President of Operations or his
designee. The review designee should utilize the latest DOT Pipeline Standard Inspection
Checklist… The DOT Pipeline Standard Inspection Checklist site is:
https://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/PHMSA Form 1 200
9.pdf.”
1. The “Inspection Checklist” referenced in the procedure is PHMSA standard inspection report
of a gas transmission pipeline form rev. 03/23/09. This form is out-of-date and UEO had a
liquid pipeline system. Therefore, the procedure did not include an applicable checklist or
questionnaire to assist with determining needed changes or improvements in the manual.
Moreover, the procedure did not include further instructions for reviewing the manual and
determining whether changes or improvements are necessary.
2. The procedure did not provide details on documenting recommendations and justifications for
changes or improvements in the manual.
3. Section 2 – Plan Review referenced Form 20.2 to document the reviews and revisions.
However, the form only had one column for a date – so it is unclear when a review or a revision
occurred. In addition, the form did not require the review date to be month/day/year format to
demonstrate manual review completed within the required interval.
Thus, the procedures were inadequate for reviewing the manual at intervals not exceeding
15 months, but at least once each calendar year in accordance with §195.402(a).
2. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
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(1) …
(2) Gathering of data needed for reporting accidents under subpart B of this part in a
timely and effective manner.
UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a
timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,
Subsection 19.14 Telephonic Notification did not identify who is responsible for making a notice
in accordance with §195.52(a).2
According to §195.52(a), at the earliest practicable moment following discovery, of a release of
the hazardous liquid or carbon dioxide transported resulting in an event described in §195.50, but
no later than one hour after confirmed discovery, the operator of the system must give notice, in
accordance with §195.52(b) of any failure that meets the criteria therein. Section 195.52(b)
requires the notice to include the information listed under that paragraph to the National Response
Center (NRC).
Subsection 19.4 Telephonic Notification did not state the person who is responsible for making the
notice and giving the required information to the NRC. Therefore, the procedures were inadequate
for reporting accidents under subpart B of Part 195 in a timely and effective manner in accordance
with§195.52(a).
3. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(2) Gathering of data needed for reporting accidents under subpart B of this part in a
timely and effective manner.
UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a
timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,
Subsection 19.14 Telephonic Notification did not require the minimum information in the notice
in accordance with §195.52(b)(6).
According to §195.52(b)(6), the initial estimate of amount of product released must be included in
the notice made to the National Response Center.
2 Section 195.52(a) was in effect at the time of the PHMSA’s inspection but subsequently amended, effective
March 24, 2017. 82 Fed. Reg. 7999 (Jan. 23, 2017).
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Subsection 19.14 Telephonic Notification required the following information:
1. 2. 3. 4. 5. 6. Name and address of the operator.
Name and telephone number of the reporter.
The location of the failure.
The time of the failure.
The fatalities and personal injuries (if any).
All other significant facts known by the operator that are relevant to the cause of the
failure or extent of the damages.
The procedure did not include the requirement for including the initial estimate of amount of
product released in the notice.
Thus, the procedures were inadequate for reporting accidents under subpart B of Part 195 in a
timely and effective manner in accordance with §195.52(b)(6).
4. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(2) Gathering of data needed for reporting accidents under subpart B of this part in a
timely and effective manner.
UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a
timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,
Subsection 19.14 Telephonic Notification did not include a written procedure for calculating a
reasonable initial release estimate in accordance with §195.52(c).
5. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual
of written procedures for conducting normal operations and maintenance activities
and handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
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CPF 1-2017-6002M
(2) Gathering of data needed for reporting accidents under subpart B of this part in a
timely and effective manner.
UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a
timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,
Subsection 19.14 Telephonic Notification did not include a process for revising or confirming its
initial notice in accordance with §195.52(d).3
6. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(2) Gathering of data needed for reporting accidents under subpart B of this part in a
timely and effective manner.
UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a
timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,
Subsection 19.15 Incident Written Notification did not require accidents reports to be electronically
filed as soon as practicable but not later than 30 days after discovery in accordance with
§195.54(a).
According to the PHMSA F 7000-1 (Instructions for Form), accident reports must be submitted
online through the PHMSA Portal unless an alternate method is approved.4
Subsection 19.15 Incident Written Notification on page 12 of 16 states in part: “Submit the
Department of Transportation / Office of Pipeline Safety / Transmission Incident Report (RSPA
7100.2) within 30 days after discovery of the incident to the following to the written report
addresses listed below: … Liquid Report PHMSA 7000-1.1.” The procedures did not require
electronic reporting.
In addition, for an accident that meets the criteria in §195.50, Form PHMSA F 7000-1 must be
filed as soon as practicable but not more than 30 days after discovery of the accident as described
in §195.54(a). The procedure did not require reports be filed “as soon as practicable.”
Therefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in
3 Section 195.52(d) was in effect at the time of the PHMSA’s inspection but subsequently amended, effective
March 24, 2017. 82 Fed. Reg. 7999 (Jan. 23, 2017).
4 See, http://phmsa.dot.gov/pipeline/library/forms.
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CPF 1-2017-6002M
a timely and effective manner in accordance with §195.54(a).
7. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(2) Gathering of data needed for reporting accidents under subpart B of this part in a
timely and effective manner.
UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a
timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,
Subsection 19.15 Incident Written Notification did not require the supplemental report be filed
within 30 days of receiving changes or additions to the originally reported information in
accordance with §195.54(b).
Subsection 19.15 Incident Written Notification on page 13 of 16, states in part: “Where additional
related information is obtained after a report is submitted as listed… must make a supplement
report (as soon as practicable) with clear reference by date and subject to the original report
(emphasis added).” The procedure did not give specific instructions to “submit” or “file” the
supplemental report online through the PHMSA Portal within the 30-day timeframe.
Therefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in
a timely and effective manner in accordance with §195.54(b).
8. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had procedures that did not adequately require maintaining current maps and
records of all crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines in
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CPF 1-2017-6002M
accordance with §195.404(a)(2) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,
Subsection 5.4 Record Retention 195.404 did not include provisions to comply with
§195.404(a)(2). In addition, Section 5- Recordkeeping did not describe the manner in which
personnel must maintain records, for example hard copies, electronic files, intranet, etc.
9. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had procedures that did not adequately require maintaining current maps and
records of the diameter, grade, type, and nominal wall thickness of all pipe in accordance with
§195.404(a)(4) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 5.4
Record Retention 195.404 did not include provisions to comply with §195.404(a)(4). In addition,
Section 5- Recordkeeping did not describe the manner in which personnel must maintain records,
for example hard copies, electronic files, intranet, etc.
10. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for conducting inspections of rights-of-way (ROW) in
accordance with §195.412(a), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,
Subsection 7.1 Pipeline Patrol 195.412 did not include guidance for ensuring mitigation measure
will be taken when conditions are found along the ROW.
Subsection 7.1 Pipeline Patrol 195.412 referenced Form 20.3 for documenting the ROW
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CPF 1-2017-6002M
inspection. Neither document gave instructions for documenting the actions taken to ensure safe
operation of the pipeline when a condition is found along the ROW. In addition, Subsection 7.1
Pipeline Patrol 195.412 did not specify who must receive notification of a condition found along
the ROW such as a leak or soil erosion to inform them to take the appropriate action(s).
Thus, the procedures were inadequate for conducting inspections of rights-of-way (ROW) in
accordance with §195.412(a).
11. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. . .
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for inspecting each mainline valve to determine that it
is functioning properly in accordance with §195.420(b) as prescribed in §195.402(c)(3).
Specifically, the OM&E Manual, Subsection 11.1 Valve Inspection 195.420 did not contain a
detailed process for inspecting and maintaining mainline valves on its pipeline system.
Subsection 11.1 Valve Inspection 195.420 of the OM&E Manual did not include:
1. Guidelines on inspecting the general appearance of valves on its pipeline system,
particularly, the paint and coating finish.
a. The procedure states to prepare Form 20.8 if there is evidence of corrosion but there
was no guidance – no coating criteria or rating to determine next appropriate action(s)
i.e. to prepare Form 20.8.
b. The procedures refer to Form 20.9 for documentation of valve inspection but the
form did not have a place for recording the paint and coating condition. There is no
connection between the Form 20.8 and Form 20.9.
2. A specified timeframe to correct deficiencies identified during valve inspection and
documenting remedial actions.
3. Guidance for maintaining valves on the pipeline system that have solar panels.
4. A process for the winterization of valves and making sure valves with an indicator, clearly
show the valve position.
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5. Instructions to safely inspect and maintain valves; for example, checking for vapors and
gas level, removing hazards from valves before attempting an inspection or repair, and
lockout/tagout practices.
The procedures did not reference other sections of the manual or documents (manufacturer's
specifications) for additional guidance. Thus, the procedures were inadequate for inspecting each
mainline valve to determine that it is functioning properly in accordance with §195.420(b).
12. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for inspecting and testing each highly volatile liquids
(HVLs) pressure limiting device, relief valve, pressure regulator, or other item of pressure control
equipment in accordance with §195.428(a) as prescribed in §195.402(c)(3). Specifically, the
OM&E Manual, Subsection 9.8 Pressure Limiting Devices Inspection 195.428 and Forms 20.4(A)
and (B) did not include details such as:
1. Recording the “as found” and “as left” settings when inspecting overpressure safety
devices except Form 20.4 (B), this had a field for recording “as left” pressure.
2. Documenting calculations of capacities include the piping size and length associated with
the relief device.
3. Establishing a schedule for repairing or replacing devices if capacity is not satisfactory.
4. Determining what is acceptable “as found” setting.
Thus, the procedures were inadequate for inspecting and testing each HVL pressure limiting
device, relief valve, pressure regulator, or other item of pressure control equipment in accordance
with §195.428(a).
13. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
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and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s had procedures that did not adequately require documents that support decisions and
analyses, any modifications, justifications, deviations and determination made, variances, and
actions taken to implement and evaluate each element of the integrity management program listed
in §195.524(f) to be maintained for the useful life of the pipeline in accordance with
§195.452(l)(1)(ii) as prescribed in §195.402(c)(3).
During this inspection, UEO presented Section 1 Identification of Could Affect HCAs, Table 1.1 –
Record Retention of its IMP as the recordkeeping procedure for the integrity management program.
Neither Table 1.1 nor the OM&E Manual included specific instructions for maintaining the records
listed in §195.452(l)(1)(ii).
14. 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for requiring and verifying that supervisors maintain a
thorough knowledge of that portion of the corrosion control procedures established under
§195.402(c)(3) for which they are responsible for insuring compliance in accordance with
§195.555 as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Section 10 Corrosion
Control did not explicitly address requirements for a supervisor to maintain knowledge and insure
compliance with the corrosion control procedures.
Section 10 on page 1 of 12 states: “Corrosion control procedures required by this section (including
those for the design, installation, operation and maintenance of cathodic protection systems), must
be carried out by, or under the direction of, a person qualified in pipeline corrosion control
methods. Qualification may include person certified by the National Association of Corrosion
Engineers or other qualified persons identified in the Momentum Operator Qualification Program
(emphasis added).”
First, the procedure did not address a supervisor. The procedure addressed “qualified personnel”
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which is general. Second, the procedure said, “carried out by, or under the direction of” – this
statement does not seem like it is meant for a supervisor. The supervisor is responsible for insuring
compliance of the corrosion control procedures. Finally, the procedure did not state the
qualification requirements for a supervisor to maintain knowledge of the corrosion control
procedures. The procedure said, “qualification may include persons certified by [NACE] or other
qualified persons identified in the Momentum Operator Qualification Program (emphasis added).”
The procedure did not ensure the supervisor would be knowledgeable and educated and/or
experienced in corrosion control.
Thus, the procedures were inadequate for requiring and verifying that supervisors maintain a
thorough knowledge of that portion of the corrosion control procedures established under
§195.402(c)(3) for which they are responsible for insuring compliance in accordance with
§195.555.
15. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for the protection of pipe at soil-to-air interfaces in
accordance with §195.581(a), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,
Subsection 10.7 Atmospheric Corrosion 195.569 did not require cleaning and coating the pipe at
soil-to-air interfaces that are exposed to the atmosphere.
Pursuant to §195.581(a), an operator must clean and coat each pipeline or portion of pipeline that
is exposed to the atmosphere, except pipelines under §195.581(c). Section 195.581(c) provides
exceptions to clean and coat each pipeline or portion of pipeline exposed to the atmosphere, which
does not include pipe at soil-to-air interfaces. Accordingly, an operator must clean and coat the
pipe at soil-to-air interfaces when exposed to the atmosphere.
Subsection 10.7 Atmospheric Corrosion 195.569, on page 1 of 12, states: “An operator need not
comply with this paragraph if the operator can demonstrate by test, investigation, or experience in
the area of application, that a corrosive atmosphere does not exist.” The procedures did not require
cleaning and coating pipe at soil-to-air interfaces when exposed to the atmosphere.
Thus, the procedures were inadequate for protecting the pipe at soil-to-air interfaces in accordance
with §195.581(a).
16. §195.402 Procedural manual for operations, maintenance, and emergencies.
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(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for monitoring atmospheric corrosion control in
accordance with §195.583(b), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,
Subsection 10.7 Atmospheric Corrosion 195.569 did not include instructions for performing
inspections of aboveground facilities at the specific areas described in §195.583(b).
Pursuant to §195.583(b), an operator must give particular attention to pipe at soil-to-air interfaces,
under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck
penetrations, and in spans during inspections.
Subsection 10.7 Atmospheric Corrosion 195.569, on page 8 of 12, states, “at interval not exceeding
3 years, reevaluate each pipeline that is exposed to the atmosphere and take remedial action
whenever necessary to maintain protection against atmospheric corrosion.” Subsection 10.7
Atmospheric Corrosion 195.569 also states to “[v]isually inspect the condition of the coating [and
that if] coating is disbonded, remove disbonded coating and inspected using the steps for uncoated
pipe below.” The procedures did not describe how to give particular attention to pipe at soil-to-air
interfaces and pipe at pipe supports.
Therefore, the procedures were inadequate for monitoring atmospheric corrosion control in
accordance with §195.583(b).
17. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
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UEO’s manual had inadequate procedures for providing enough looping or slack so backfilling
will not unduly stress or break the lead and the lead will otherwise remain mechanically secure
and electrically conductive in accordance with §195.567(b)(2), as prescribed in §195.402(c)(3).
Specifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.573, .567(b) did not include
sufficient details to ensure the test leads will remain mechanically secure and electrically
conductive following backfilling.
Subsection 10.5 Test Leads, 195.573, .567(b), on page 7 of 12, restates the requirement in code
section 195.567(b)(2). The procedure did not include details about measuring and documenting
the pipe-to-soil reading to ensure conductivity between the wire and pipe following backfilling. In
addition, the procedure did not include a process for backfilling to ensure that there are no
disturbances to the test station and wire. The procedures did not reference other sections of the
manual or documents for additional guidance.
Therefore, the procedures were inadequate for providing enough looping or slack so backfilling
will not unduly stress or break the lead and the lead will otherwise remain mechanically secure
and electrically conductive in accordance with §195.567(b)(2).
18. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for preventing lead attachments from causing stress
concentration on pipe in accordance with §195.567(b)(3), as prescribed in §195.402(c)(3).
Specifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.573, .567(b) did not include
sufficient guidance for installing test leads.
Subsection 10.5 Test Leads, 195.573, .567(b) on page 7 of 12, restates the requirement in code
section 195.567(b)(3). The procedure did not provide details about the method used to attach the
test leads such as thermite welding, solder connection, and/or mechanical connection. The
procedure did not reference another section of the manual or documents for additional guidance.
Thus, the procedures were inadequate for preventing lead attachments from causing stress
concentration on pipe in accordance with §195.567(b)(3).
19. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
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written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for maintaining test lead in a condition that enables
electrical measurements to determine whether cathodic protection complies with §195.571 in
accordance with §195.567(c) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,
Subsection 10.5 Test Leads, 195.567(b) did not include a process or a timeframe to repair a
damaged or defective test lead.
Subsection 10.5 Test Leads, 195.567(b) on page 7of 12 states: “Existing test leads will be
maintained so that adequate electrical measurements can be made to monitor each facility’s
cathodic protection…”
The procedure did not provide details such as:
1. Repairing the test leads.
2. Timeframe to repair the damaged or defective test leads.
3. Documentation of test lead repair.
Thus, the procedures were inadequate for maintaining test lead in a condition that enables electrical
measurements to determine whether cathodic protection complies with §195.571 in accordance
with §195.567(c).
20. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for the inspection of all external pipe coating required
by §195.557 just prior to lowering the pipe into the ditch or submerging the pipe in accordance
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with §195.561(a) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection
10.2 External Corrosion 195.573 did not include a detailed process for inspecting the external pipe
coating.
Subsection 10.2 External Corrosion 195.573, on page 3 of 12, states that “[i]f coated pipe is
installed by boring, driving, or other similar method, precautions must be taken to minimize
damage to the coating during installation and inspected prior to lowering the pipe in the ditch or
submerging the pipe.”
The procedure did not provide details such as:
1. Method for coating inspection such as visual and electrical testing (holiday
detector/jeeping).
2. Inspection and calibration of equipment used for coating inspection, if any.
The procedures did not reference other sections of the manual or documents (manufacturer's
specifications) for additional guidance. Thus, the procedures were inadequate for inspecting all
external pipe coating required by §195.557 just prior to lowering the pipe into the ditch or
submerging the pipe in accordance with §195.561(a).
21. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for examining exposed portions of pipe for evidence of
external corrosion if the pipe is bare, or if the coating is deteriorated in accordance with §195.569
as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.2 External
Corrosion 195.573 did not include detailed instructions to clean the pipe for examination and
determination of whether there is external corrosion.
Subsection 10.2 External Corrosion 195.573, on page 3 of 12, states in part:
Whenever Momentum has knowledge that any portion of a buried pipeline
is exposed, the exposed portion must be examined for evidence of external
corrosion if the pipe is bare, or if the coating is deteriorated. . . If external
corrosion requiring remedial action is found… Momentum shall investigate
circumferentially and longitudinally… (by visual examination, indirect
method, or both).
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The procedure did not provide details such as:
1. 2. 3. Instructions for cleaning the pipe before a close visual examination or indirect method.
A definition of external corrosion.
Criteria for determining when further investigation circumferentially and longitudinally
beyond the exposed portion must be conducted.
Thus, the procedures were inadequate for examining exposed portions of pipe for evidence of
external corrosion if the pipe is bare, or if the coating is deteriorated in accordance with §195.569.
22. 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedures for retaining required corrosion control records or maps
in accordance with §195.589(c) as prescribed in 195.402(c)(3). Specifically, the OM&E Manual,
Subsection 5.7 Corrosion Control Records 195.589 did not specifically require maintaining a
record of each analysis, check, demonstration, examination, inspection, investigation, review,
survey, and test required by subpart H in sufficient detail; and retaining records for §§195.569 and
195.573(a) and (b).
Pursuant to §195.589(c), an operator must retain these records for at least 5 years, except that
records related to §§195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for
as long as the pipeline remains in service.
Section 195.569 requires exposed pipeline to be examined for evidence of external corrosion.
Section 195.573 (a) and (b) requires protected pipeline and unprotected pipe to be monitored for
external corrosion control, respectively.
Subsection 5.7 Corrosion Control Records 195.589 states: “Momentum shall maintain a record of
each test, survey, or inspection required… in sufficient detail to demonstrate the adequacy of
corrosion control measures… Internal corrosion control records must be retained for a long as the
pipeline remains in service.” The procedure did not include examination of exposed pipe or
external corrosion records related with §§195.569 and 195.573(a) and (b), respectively.
Subsequently, Section 10 – Corrosion Control states, “Momentum will maintain records or
maps… Each test, survey or inspection will be retained as required by 195.589. However, the
procedure did not specifically require records of examination and other requirements in subpart H.
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Thus, the procedures were inadequate for retaining required corrosion control records or maps in
accordance with §195.589(c).
23. 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
UEO’s manual had inadequate procedure for investigating the corrosive effect of the hazardous
liquid or carbon dioxide on the pipeline and mitigating internal corrosion from the corrosive effect
of the hazardous liquid or carbon dioxide on the pipeline in accordance with 195.579(a) as
prescribed in 195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.1 Internal Corrosion
195.579 did not include a detailed process to determine if the hazardous liquid transported is
corrosive.
Subsection 10.1 Internal Corrosion 195.579, on page 1 of 12, states, in part: “Momentum’s
corrosion control measures will be evaluated by an inspection and monitoring program. Coupons
and/or spools will be utilized to monitor internal corrosion and will be removed and evaluated at
periodic intervals.”
The procedure did not include a process for determining:
1. 2. Whether the hazardous liquid transported is corrosive and
Areas of pipe that may require particular attentions e.g. low points, bends, etc.
Thus, the procedures were inadequate for investigating the corrosive effect of the hazardous liquid
or carbon dioxide on the pipeline and mitigating internal corrosion from the corrosive effect of the
hazardous liquid or carbon dioxide on the pipeline in accordance with 195.579(a).
24. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies…
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
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(1) …
(13) Periodically reviewing the work done by operator personnel to determine the
effectiveness of the procedures used in normal operation and maintenance and taking
corrective action where deficiencies are found.
UEO’s manual had inadequate procedures for periodically reviewing the work done by operator
to determine the effectiveness of the procedures used in normal operation and maintenance and
taking corrective action where deficiencies are found as prescribed in §195.402(c)(13).
Specifically, the OM&E Manual, Subsection 1.11 Operating Personnel 195.402(c)(13) did not
provide sufficient guidance on how to determine the effectiveness of the procedures and correct
deficiencies.
Subsection 1.11 states “[a]nnually (during operator qualification reviews), Momentum will review
the work done by operator personnel to determine the effectiveness of the procedures used in
normal operator and maintenance tasks” and that “[d]uring this evaluation Momentum will take
corrective action if deficiencies are discovered.”
The procedure did not provide details such as:
1. Documenting discussion during operator qualification reviews to validate which
documents were reviewed.
2. 3. 4. Identifying the person responsible for review of work completed by operator personnel.
Defining “work done by operator personnel”.
Requiring documentation of corrective actions.
During the inspection, UEO provided a copy of Form 20.20 Review Work Performed by Operators
in response to showing a document for recording the review. However, the OM&E Manual did not
reference this form.
Thus, the procedure were inadequate for periodically reviewing the work done by operator to
determine the effectiveness of the procedures used in normal operation and maintenance and taking
corrective action where deficiencies are found as prescribed in §195.402(c)(13).
25. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded;
(1) Responding to, investigating, and correcting the cause of:
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(i) Unintended closure of valves or shutdowns;
UEO’s manual had inadequate procedures for responding to, investigating, and correcting the
cause of an unintended closure of valves or shutdowns as prescribed in §195.402(d)(1)(i) were
inadequate. Specifically, the OM&E Manual, Section 13 – Abnormal Operations, Subsection 13.3
and Subsection 13.4 contained general statements and provided insufficient guidance.
The procedure did not include details such as:
1. How and when controllers in the control room and field personnel communicate and
coordinate with each other once an unintended valve closure or shutdown occurred.
2. Requirements for responding to the type (whether automatic or manual valves) and
locations of the valve as well as the valve locking devices.
3. Guidance for monitoring an unintended valve closure or follow-up actions related to an
unintended valve closure.
4. Specific titles or locations of the procedure
5. Requirements for investigating / correcting the cause of an unintended valve closure or
shutdown.
6. Pipeline start-up procedures.
Thus, the procedures were inadequate for responding to, investigating, and correcting the cause of
an unintended closure of valves or shutdown as prescribed in §195.402(d)(1)(i).
26. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
(1) Responding to, investigating, and correcting the cause of:
(i) …
(ii) Increase or decrease in pressure or flow rate outside normal operating limits;
UEO’s manual had abnormal operation procedures that were inadequate for responding to,
investigating, and correcting the cause of an increase or decrease in pressure or flow rate outside
normal operating limits as prescribed in §195.402(d)(1)(ii). Specifically, the OM&E Manual,
Section 13 – Abnormal Operations, did not provide sufficient guidance for responding to,
investigating, and correcting the cause of an increase or decrease in pressure or flow rate outside
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normal operating limits.
Sections 13.4 and 13.5 did not provide details such as:
1. 2. 3. Instructions for communicating between control room and field personnel when an increase
or decrease in pressure or flow rate outside normal operating limits occurred.
Roles and responsibilities of the field personnel and controllers in the control room.
Reference to other sections of the manual or documents for additional guidance.
In addition, the OM&E Manual, Section 13 – Abnormal Operations, Subsection 13.1 Abnormal
Operations, states: “An abnormal operating condition is any condition occurring on a pipeline
system which exceeds normal operating limits (emphasis added).” Thereafter, the procedure
references the words “abnormal operating condition.” However, abnormal operating condition is
under the Operator Qualification Rule in subpart G of Part 195.
Pursuant to §195.402(d)(1)(ii) an operator must respond to, investigate, and correct the cause of
an increase or decrease in pressure or flow rate outside normal operating limits (emphasis added).
Therefore, a pipeline system does not have to exceed normal operating limits to be an abnormal
operation.
An abnormal operation is defined under §195.402(d) which is any unintended closure of valves or
shutdowns; increase or decrease in pressure or flow rate outside normal operating limits; loss of
communications; operation of any safety device; any other malfunction of a component, deviation
from normal operation, or personnel error which could cause a hazard to persons or property. The
definition in the procedure was not accurate.
Thus, the procedures were inadequate for responding to, investigating, and correcting the cause of
an increase or decrease in pressure or flow rate outside normal operating limits as prescribed in
§195.402(d)(1)(ii).
27. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
(1) Responding to, investigating, and correcting the cause of: …
(i) …
(iii) Loss of communications;
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UEO’s manual had abnormal operation procedures that were inadequate for responding to,
investigating, and correcting the cause of cause of loss of communication as prescribed in
§195.402(d)(1)(iii). Specifically, the OM&E Manual, Section 13 – Abnormal Operations,
Subsection 13.6 had insufficient guidance on how to communicate with someone if there is a loss
of communications at the pipeline facilities, for example; communicate person-to-person, two-way
radio, Supervisory Control and Data Acquisition, phone service, intranet/internet, or others. In
addition, the procedure did not provide guidance on how to ensure that the communication
methods are effective.
Thus, the procedures were inadequate for responding to, investigating, and correcting the cause of
cause of loss of communication as prescribed in §195.402(d)(1)(iii).
28. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
(1) Responding to, investigating, and correcting the cause of: …
(i) …
(v) Any other malfunction of a component, deviation from normal operation, or
personnel error which could cause a hazard to persons or property.
UEO’s manual had abnormal operation procedures that were inadequate for responding to,
investigating, and correcting the cause of any other malfunction of a component, deviation from
normal operation, or personnel error which could cause a hazard to persons or property as
prescribed in §195.402(d)(1)(v). Specifically, the OM&E Manual, Section 13 – Abnormal
Operations, Subsection 13.8 did not give guidance on responding, investigating, and correcting
this event.
The procedure did not provide details such as:
1. 2. 3. Guidance for dealing with vandalism – e.g. contact the appropriate authorities, conduct an
investigation, and correct the event.
Methodology for determining the cause of an event
The procedures were too general to ensure compliance with requirements.
In addition, the OM&E Section 13, Subsection 13.1 on page 1 of 7, included the list of abnormal
operations under §195.402(d) except 13.8 which mentions “[a]ny other foreseeable malfunction
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of a component (emphasis added)…” This statement did not adequately describe the requirement
in §195.402 (d)(1)(v) because not all malfunctioned components are foreseeable. The word
“foreseeable” is unnecessary.
Thus, the procedures were inadequate for responding to, investigating, and correcting the cause of
any other malfunction of a component, deviation from normal operation, or personnel error which
could cause a hazard to persons or property as prescribed in §195.402(d)(1)(v).
29. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
(1) …
(2) Checking variations from normal operation after abnormal operation has ended at
sufficient critical locations in the system to determine continued integrity and safe
operation.
UEO’s manual had abnormal operation procedures that were inadequate for checking variations
from normal operation after abnormal operation has ended at sufficient critical locations in the
system to determine continued integrity and safe operation as prescribed in §195.402(d)(2).
The OM&E Manual, Section 13 – Abnormal Operations, Subsection 13.1 Abnormal Operations,
on page 1 of 7, states: “After an abnormal operating condition has been corrected, check variations
from normal operation (at critical locations in the system) to determine continued integrity and
safe operation.”
The procedure did not provide details such as:
1. Methodology for following up and monitoring to ensure the event did not recur.
2. Location of critical locations. The Control Room Manual rev. July 17, 2015 had a list
of all critical locations. However, the abnormal operation procedures and control room
manual did not cross-reference each other.
Thus, the procedures were inadequate to determine continued integrity and safe abnormal
operation has ended as prescribed in §195.402(d)(2).
30. §195.402 Procedural manual for operations, maintenance, and emergencies.
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(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
(1) …
(3) Correcting variations from normal operation of pressure and flow equipment and
controls.
UEO’s manual had abnormal operation procedures that were inadequate for correcting variations
from normal operation of pressure and flow equipment and controls as prescribed in
§195.402(d)(3).
The OM&E Section 13 – Abnormal Operations, Subsection 13.1 Abnormal Operations states:
“After an abnormal operating condition has been corrected, check variations from normal
operation (at critical locations in the system) to determine continued integrity and safe operation.”
The procedure did not provide details such as:
1. 2. Criteria for correcting the variation from normal operation of pressure and flow equipment
and controls.
Guidance to determine the cause of the equipment variations and schedule a response to
prevent recurrence of the event.
Thus, the procedures were inadequate for correcting variations from normal operation of pressure
and flow equipment and controls as prescribed in §195.402(d)(3).
31. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
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(4) Notifying responsible operator personnel when notice of an abnormal operation is
(1) …
received.
UEO’s manual had abnormal operation procedures that were inadequate for notifying responsible
operator personnel when notice of an abnormal operation is received as prescribed in
§195.402(d)(4).
The OM&E Section 13 – Abnormal Operations, Subsection 13.1 Abnormal Operations 195.402(d)
on page 1 of 7 states: “Should any of the above events occur; the Operator on duty will normally
be the first person to become aware of the problem. The Operator should be then contact the
Operations/District Manager. At this point, the Operations/District Manager will assume
responsibility for investigating the incident, for determining what actions are required to correct
the situation, and…”
Section 13 – Abnormal Operations did not address who should the controller in the control room
notify when an abnormal operation is received.
In addition, Subsection 1.7 Momentum Pipeline Organization Chart of the OM&E Manual
contains an outdated organizational chart that did not match the distribution list in Subsection 2.4.
Thus, the procedures were inadequate for notifying responsible operator personnel when notice of
an abnormal operation is received as prescribed in §195.402(d)(4).
32. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities are conducted…
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits have
been exceeded:
(1) …
(5) Periodically reviewing the response of operator personnel to determine the
effectiveness of the procedures controlling abnormal operation and taking corrective
action where deficiencies are found.
UEO’s manual had abnormal operation procedures that were inadequate for periodically reviewing
the response of operator personnel to determine the effectiveness of the procedures controlling
abnormal operation and taking corrective action where deficiencies are found as prescribed in
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§195.402(d)(5).
The OM&E Manual, Section 13 – Abnormal Operations, Subsection 13.9 Reviewing Abnormal
Operation Response, on page 7 of 7, states: “supervisor must periodically review the response of
operator personnel to determine the effectiveness of the procedures controlling abnormal operation
and taking corrective action where deficiencies are discovered.”
The procedure did not provide details such as:
1. The definition of “periodically”.
2. A detailed process for reviewing the response of operator personnel to determine the
effectiveness of the procedures controlling abnormal operation and taking corrective action.
3. Record review requirements to confirm actions were timely and appropriate for the given
abnormal operation. For instance, the procedure did not require logging the response activities
and time (besides the notification time) for post review.
4. A process for recommendations or updates to procedures based on the review and actions
taken.
Thus, the procedures were inadequate for periodically reviewing the response of operator
personnel to determine the effectiveness of the procedures controlling abnormal operation and
taking corrective action where deficiencies are found as prescribed in §195.402(d)(4).
33. §195.452 Pipeline integrity management in high consequence areas.
(a) …
(f) What are the elements of an integrity management program? An integrity management
program begins with the initial framework. An operator must continually change the
program to reflect operating experience, conclusions drawn from results of the integrity
assessments, and other maintenance and surveillance data, and evaluation of
consequences of a failure on the high consequence area. An operator must include, at
minimum, each of the following elements in its written integrity management program:
(1) …
(5) A continual process of assessment and evaluation to maintain a pipeline's integrity
(see paragraph (j) of this section);
UEO’s IMP had inadequate procedures for a continual process of assessment and evaluation to
maintain a pipeline’s integrity (see paragraph (j) of section 195.452), as prescribed in
§195.452(f)(5). Specifically, the IMP, Section 7 Continual Process of Evaluation & Assessment
did not include a clear process to determine the frequency of the evaluation.
Pursuant to §195.452(j)(2), an operator must base the frequency, at which periodic evaluation are
performed, on risk factors associated with the pipeline, including the factors listed in §195.452(e).
Subsection 7.01 Periodic Evaluation & Assessment Intervals of Section 7 on page 7-2 states in
part:
The re-evaluation recommendation will be based on:
 Risk factors identified in the Risk Model,
 Information concerning decisions about remediation following the baseline
120176002M_Notice of Amendment_06082017_text Page 25 of 28



CPF 1-2017-6002M
assessment and future assessments,
 Additional required testing, and
 Any preventive and mitigation actions taken by Momentum as part of this program.
 Root cause analysis of the anomalies and hydrostatic test failures,
The procedures were inconsistent with the requirement in §195.452(j)(2). The procedures included
information about preventive and mitigative measures, which are not risk factors. The procedures
did not specifically instruct how to determine the frequency of the periodic evaluation in
accordance with §195.452(j)(2).
Section 195.452(j)(2) also states an operator’s periodic evaluation, at minimum, must consider the
results of the baseline and periodic integrity assessment, information analysis, decision about
remediation, and preventive and mitigative actions.
Subsection 7.01 Periodic Evaluation & Assessment Intervals of Section 7 on page 7-2 describes
the “process for annual re-evaluation.” However, the procedure did not include all the
considerations required in §195.452(j)(2).
Thus, the procedures for continual process of assessment and evaluation to maintain a pipeline’s
integrity (see paragraph (j) of section 195.452) as prescribed in §195.452(f)(5) were inadequate.
34. §195.452 Pipeline integrity management in high consequence areas.
(a) …
(f) What are the elements of an integrity management program? An integrity management
program begins with the initial framework. An operator must continually change the
program to reflect operating experience, conclusions drawn from results of the integrity
assessments, and other maintenance and surveillance data, and evaluation of
consequences of a failure on the high consequence area. An operator must include, at
minimum, each of the following elements in its written integrity management program:
…
(1) …
(3) An analysis that integrates all available information about the integrity of the entire
pipeline and the consequences of a failure (see paragraph (g) of this section);
UEO’s IMP had inadequate procedures for an analysis that integrates all available information
about the integrity of the entire pipeline and the consequences of a failure, as prescribed in
§195.452(f)(3). According to §195.452(g), an operator must analyze all available information
about the integrity of the entire pipeline and consequences of a failure. The IMP, Section 5 Risk
Analysis did not describe the technical justification for the analytical tools, models, or algorithms
used to integrate information, and recognition of any limitations of these analytical methods.
Subsection 5.1 Approach, on page 5-1 states in part: “The risk analysis was developed as part of
this IM Plan is an analytical subject matter expert (SME) process, by which Momentum has
evaluated its pipeline, taking into consideration, the above guidance for . . . The process involves
gathering data on design, construction, operation, maintenance, testing, inspection and other
120176002M_Notice of Amendment_06082017_text Page 26 of 28



CPF 1-2017-6002M
information about the pipeline system.” The procedure did not include the basis for the selection
of a SME process. Therefore, it is unclear if the SME process is sufficient to recognize the highest
risk. Consequently, the procedures did not provide information on the limitation of a SME process.
Furthermore, the procedure did not give details on what qualifies an individual as a SME (e.g.
knowledge and experience). It is unclear what type of person reviews and/or provides input in the
risk analysis.
In addition, the IMP Section 5 did not include information on where all risk model input data is
gathered from (e.g. maps, database, hard copies records or spreadsheet). Furthermore, the IMP
Appendix I - Risk Analysis Table - Pipelines with HCAs did not have guidelines for selecting a
weighting factor each risk factor. For example, the risk factor “Diameter” did not have a selection
for a weighting factor. Last of all, the IMP Appendix I did not require justification for selecting a
weighting factor.
Thus, the procedures were inadequate for an analysis that integrates all available information about
the integrity of the entire pipeline and the consequences of a failure (see paragraph (g) of section
195.452) as prescribed in §195.452(f)(3).
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings. Please refer to this document and note the response options. Be advised that all
material you submit in response to this enforcement action is subject to being made publicly
available. If you believe that any portion of your responsive material qualifies for confidential
treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a
second copy of the document with the portions you believe qualify for confidential treatment
redacted and an explanation of why you believe the redacted information qualifies for confidential
treatment under 5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 120 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that UEO maintain documentation of the safety improvement costs
associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)
and submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear
Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-6002M on each
document you submit, and whenever possible provide a signed PDF copy in electronic format.
Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD
accompanied by the original paper copy to the Eastern Region Office.
120176002M_Notice of Amendment_06082017_text Page 27 of 28



CPF 1-2017-6002M
Additionally, if you choose to respond to this (or any other case), please ensure that any response
letter pertains solely to one CPF case number.
Sincerely,
Robert Burrough
Acting Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
120176002M_Notice of Amendment_06082017_text Page 28 of 28

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/120176002M>
- Source ID: `phmsa-enforcement`
- SHA-256: `b7a02a9a9a57c82e38ce67aca0b0d2946179db1f74bd70fdec5674db1921d1ee`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T10:11:18.425Z
- Document slug: `phmsa-enforcement-120176002m`

### Source metadata

```json
{
  "cpf": "120176002M",
  "operator": "UTICA EAST OHIO MIDSTREAM LLC",
  "region": "Eastern",
  "pipelineType": "INTRASTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
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}
```