GORDON TERMINAL SERVICES — Notice of Amendment

120026004m_final order_04302003_text.pdf, page 1Official PDFUS, Department of Ttonsportatton Research and Special prattrams ftdmtntslratlan 400 seventh sl s w Washington O C 20590 APR 30 Z03 Timothy H Gordon Vice President, Operations Gordon Termmal Services Company 1000 Ella Street McKees Rocks, Pennsylvaiua 15136 Re CPF No 1-2002-6006 CPF No 1-2002-6004-M Dear Mr Gordon Enclosed is the Fmal Order issued by the Associate Admuustrator for Pipelme Safety m the above-referenced cases It makes findings of violation and a findmg of madequate procedures, and requires certain corrective action and revision of certain operations, mamtenance and emergency procedures When the terms of the Order are completed, as determined by the Director, Eastern Region, ttus enforcement action wfil be closed Your receipt of the Final Order constitutes service of that document under 49 C F R 1't 190 5 Sincerely, Gwendolyn M Hfi Pipeline Comphance Registry Office of Pipehne Safety Enclosure CERTIFIED MAIL - RETURN RECEIPT RE UESTED#

120026004m_final order_04302003_text.pdf, page 2DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, DC 20590 In the Matter of Gordon Ternunal Services Company, ) Respondent ) ) ) ) ) ) CPF No 1-2002-6006 CPF No I-2002-6004-M FINAL ORDER On December 20, 2001 and January 8, 2002, pursuant to 49 U S C ) 60117, a representative of the Office of Pipelme Safety (OPS) conducted an on-site pipelme safety mspection of Respondent's facihties and records m McKees Rocks, Pennsylvama As a result of the inspection, the Director, Eastern Region, OPS, issued to Respondent, by letter dated February 15, 2002, a Notice of Probable Violation, Proposed Comphance Order (Notice I), and by letter dated February 19, 2002, a Notice of Amendment (Notice 2) In accordance with 49 C F R ) 190 207, Notice 1 proposed finding that Respondent had violated 49 C F R $tt 195 505, 199 7 and 199 202 snd proposed that Respondent take certain measures to correct the alleged violations Notice 2 proposed, m accordance with 49 C F R tJ 190 237, that Respondent amend tlat its procedures for Operations, Mamtenance and Emergencies Respondent responded to the Notices by letter dated May 7, 2002 (Response) Respondent did not contest the allegations of violation but provided information concermng the corrective actions it was taking Respondent also requested an extension of time to subrmt its amended procedures The Region, m a letter dated May 21, 2002, granted Respondent additional time Respondent did not request a hearing, consequently, Respondent wiuved its right to one FINDINGS OF VIOLATION Respondent did not contest the alleged violations for 195 505, 199 7, and 199 202 in Notice 1 Accordingly, I find that Respondent violated the following sections of 49 C F R Parts 195 and 199, as more fully descnbed in Notice 1 49 C F R tJ 195 505 — faihng to have a written operator quahfication program, 49 C F R $ 199 7 — fatlmg to maintain and follow a written anti-drug plan that conforms to the requirements of Part 199 and the DOT Procedures in Part 40, and#

120026004m_final order_04302003_text.pdf, page 349 C F R $ 199 202 — faihng to maintam and follow a written alcohol nususe plan that conforms to the requuements of Subpart B, Part 199 and the DOT Procedures m Part 40 These findings of violation will be considered pnor offenses m any subsequent enforcement achon taken agamst Respondent COMPLIANCE RDER Under 49 U S C ) 60118(a), each person who engages m the uansportatton ofhazardous hquids or who owns or operates a pipehne facihty is reqmred to comply with the apphcable safety standards estabhshed under chapter 601 Pursuant to the authority of 49 U S C $ 60118(b) and 49 C F R $ 190 217, Respondent is ordered to take the followmg actions to ensure compliance with the pipelme safety regulations applicable to its operations (1) Develop a wntten Operator Qualification (OQ) plan that sattsfies the requirements set forth in 49 C F R Part 195, Subpart G (2) Develop and follow a written Drug and Alcohol plan that meets the requuements of 49 C FR Parts 40 and 199 (3) Submit a copy of the completed OQ plan and the completed Drug and Alcohol plan to the Eastern Region Director witlun 90 days of receipt of this Fmal Order. The address is Office of Pipelme Safety, 400 Seventh Street, SW, Room 7130, Washmgton, DC 20590 AMENDMENT OF PROCEDURES Notice 2 alleged inadequacies m Respondent's Operations, Mamtensnce and Emergencies Manual and proposed to reqmre amendment of Respondent's procedures to comply with the requirements of 49 C F R ltd 195 402, 403, 404, 406, 408, 410, 414, 416, 420, 422, 426, 428, 430, 434, 438, 440, and 442 Respondent did not contest the proposed Notice of Amendment Accordingly, I find that Respondent's procedures are inadequate to ensure safe operation of its pipelme system Pursuant to 49 U S C $ 60108(a) and 49 C F R tt 190 237, Respondent is ordered to make the following revisions to its procedures Respondent inust- 1 t'I 195 402 (c)(5) - Develop procedures for analyzing pipelme accidents to determine then causes 2 tt 195 402 (c)(7) - Amend its procedures for start-up and shut-down of the system to include mstructions apphcable to Airport Services International (ASI) personnel Procedures should mclude instructions for proper commuiucation between ASI and Gordon Termmal Services personnel before, during, and after transfer/delivery operations, and steps for valve sequencing and tank gaugmg#

120026004m_final order_04302003_text.pdf, page 4$ 195 402 (c)(8) - Develop procedures for facilities not equipped to fiul safe to address the momtonng of pipehne pressure dunng startup and shutdown to assure operauon withm the maximum operating pressure for the system $ 195 402 (c)(9) - Develop procedures for detecting abnormal operating conditions for facihties not equipped to fiul safe in areas that would reqmre tnunedhate response by operating personnel These conditions can be identified by monttormg pressure, temperature, flow or other appropnate operational data and transmittmg tlus data to an attended location II 195 402 (c)(11) - Develop procedures for muumizmg the hkelihood of accidental igmtton of vapors in areas where the potential exists for the presence of flammable hqmds or gases II 195 402 (c)(12) - Develop procedures for estabhslung and mamtainmg liaison with fire, police, and other appropnate pubhc officials to learn the responsibility and resources of each government orgamzahon that may respond to a hazardous hquid pipelme emergency These procedures must also address the means of commumcatton, the mtervals at wluch the luuson meetmgs will be conducted, and a description of the mformation to be exchanged CI 195 402 (c)(13) - Develop procedures to provide for reviewing the work done by operatmg personnel to determme the effectiveness of the procedures used m normal operation and maintenance $ 195 402 (c)(14) - Develop procedures to protect personnel from hazards of unsafe accumulations of vapor or gas m excavated trenches and makmg available emergency rescue equipment, mcludmg a breathing apparatus and a rescue harness and, when needed at the excavation site $ 195 402 (d)(1-5) — Develop abnormal operatmg procedures to provide safety when operating design lumts have been exceeded These procedures must address the reqmrements of IN 195 402 (d)(1-5) ) 195 402 (e)(1) - Amend its emergency procedures to identify the notices of events that reqmre immediate response by the operator, fire, pohce, or other responder II 195 402 (e)(3) - Amend its emergency procedures to be more specific about the types of emergency equipment needed at the scene of an emergency and where the eqmpment hke backhoes, excavators, iur compressors, can be located f 195 402 (e)(6) — Develop emergency procedures to provide mstructions for mminuzing public exposure to tn)ury and reducing the probability of accidental ignition by assisting with the evacuation of residents aud assisting with halting or rerouting the traffic on roads and railroads in the affected area, or takmg other appropriate action#

120026004m_final order_04302003_text.pdf, page 513 Ii 195 402 (e)(9) - Develop emergency procedures to provide mstruchons for conducting a post accident review of employees' activihes to determine if procedures were effective m each emergency, and for taking corrective schon where deficiencies are found 14 Ik 195 402(f) - Develop procedures to mstruct personnel performmg operahon and maintenance activities to recognize conditions that potentially maybe safety-related and sub)ect to the reporhng reqmrements under CI 195 55 15 195403 - Develop emergency response trainmg procedures to address the requirements of Ii 195 403 16 I9 195 404 - Develop procedures to address the requirements for mamtammg maps and records 17 Ii 195 406 - Develop procedures to address the requuements for maximum operahng pressure 18 Ik 195 408 - Amend its commumcahons procedures to include a means for momtortng operahonal data as required by It 195 402 (c)(9) 19 $ 195 410 — Amend its procedures to specify where lme markers have to be located 20 «i 195 414 - Amend its procedures for cathodic protection to address the requirements of $ 195 414 21 $ 195 416 — Amend its external corrosion control procedures to address the requirements of $ 195 416 22 |i 195 420 -Develop procedures to address the reqmrements for valve mamtenance 23 II195 422 - Amend its procedures for pipelme repair to cover rnatenal, welding, and testing that is planned for pipelme and tank facihties repairs m the system 24 ) 195 426 - Develop procedures to address the requirements for scraper and sphere facihhes to instruct personnel operahng these facdities 25 Ii 195 428 - Develop procedures for inspectmg and testing pressure limiting devices, rehef valves, pressure regulators, or other items of pressure control equipment 26 ) 195 430 - Amend its procedures on firefighting equipment to satisfy the requirements of 195 430 and to specify the type of firefightmg equipment, location, methods of inspection, and mspection frequencies#

120026004m_final order_04302003_text.pdf, page 627 $ 195 434 - Develop procedures to provide guidance to personnel regardmg the placement of signs In addition, the procedures must specify the mformatton that is reqmred to be visible on the signs 28 Subnut the amended procedures to the Regional Director, Eastern Region, OPS witlun 30 days followmg receipt of this Order 29 The Regional Director may extend the penod for complying with the required items if the Respondent requests an extension snd adequately Justifies the reasons for the extension The terms and conditions of this Order are effective upon receipt Failure to comply with this Fmal Order may result m the assessment of civil penalties of up to $100, 000 per violation per day, or in the referral of the case for judicial enforcement. Under 49 C F R tt 190 215, Respondent has a nght to petition for reconsideration of tlus Fmal Order The petition must be received witlun 20 days of Respondent's receipt of tlus Final Order and must contain a bnef statement of the issue(s) The fihng of the petition automatically stays the payment of any civil penalty assessed All other terms of the order, includmg any requu ed corrective action, remain m full effect unless the Associate Admimstrator, upon request, grants a stay The terms and conditions of this Fmal Order are effective on receipt APR 30 2003 Date Issued tacey Gerard 4 Associate Adnurustrator for Pipelme Safety#