{"operation":"document","citation":"CPF 120076004M","title":"GORDON TERMINAL SERVICES — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-11-05","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(b), 195.452(f), 195.452(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120076004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120076004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120076004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120076004M","body":"Notice of Amendment involving GORDON TERMINAL SERVICES. PHMSA's enforcement data identifies the cited regulations as 195.452(b),  195.452(f),  195.452(h). The case was opened on 2007-11-05 and is reported as closed as of 2009-12-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120076004M_Notice of Amendment_11052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120076004M/120076004M_Notice%20of%20Amendment_11052007.pdf\n\n120076004m_notice of amendment_11052007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120076004M/120076004m_notice%20of%20amendment_11052007_text.pdf\n\n120076004m_notice of amendment_11052007_text.pdf\n\nO\nU S Department\naf Transpanatian\nPipeline and\nHazardous Matetfals Safety\nAdministration\n409 3rd Street, SW Suite 300\nWashington, Da 20024\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nNovember 5, 2007\nMr Tim Gordon\nVice President\nGordon Terminals\nP 0 Box 313\nMcKees Rocks, PA 15136\nCPF 1-2007-6004M\nDear Mr Gordon\nOn September 11-12, 2007, representatives of the Pipehne and Hazardous Matenals Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code inspected Gordon\nTermmal's procedures in McKees Rocks, Pennsylvania for integnty management of Gordon's\nTioga Pipeline\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nGordon's plans or procedures, as descnbed below\nIM Plan Development in Framework Stage\ns195. 4\n52(b) What program and practices must operators use to manage pipeline\nintegrity? (5) Implement and follow the program;\ntt195. 452(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An operator\nmust continually change the program to reflect operating experience,\n\n\n\nconclusions drawn from results of the integrity assessments, and other\nmaintenance and surveillance data, and evaluation of consequences of a failure\non the high consequence area.\nA number of issues involved with the Integrity Plan are addressed in Gordon's OPA\n90 and O&M Plans The issues mcluded in those plans should be referenced in the\nIM Plan where ever appropriate\nGordon conducts their patrol activities in accordance with 195 requirements and their\nO&M procedures outhne the field process This process needs to be expanded to\nexpliun what happens with field documents once they are received in the office for\ndisposition\nRisk Factors\n$195. 452(i) An operator must include, at minimum, each of the following\nelements in its written integrity management program: (3) An analysis that\nintegrates all available information about the integrity of the entire pipeline and\nthe consequences of a fadure\nGordon has provided well-summanzed tables within their IM Plan One of those\ntables shows risk factors where third party excavation damage needs to be included\nGordon provides in their IM Plan a \"vulnerabdity analysis\" for each pipehne section\nand the farm tanks For clanficatton, these analyses should explicitly state in some\nfashion that they address the \"nsk analysis\" requirements of the IM Rule\nWithin the P&M measures portion of the IM Plan, Gordon needs to state how these\nmeasures have impacted their nsk factors\nFor the leak detection portion of their P&M measures, the \"N/A\" shown for the risk\nassessment results of the tank farm should be changed to reference the appropriate\nsecuon m the IM Plan where the results are documented\nClassification of Anomalies\nII195. 452(h) What actions must an operator take to address integrity issues?\nGordon has assessed their pipehnc using a successful pressure test where no\nanomahcs were found In the event future assessments result in needed repairs, more\ndetail is needed withm their plan outhning how these repairs would be prioritizcd\n\n\n\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U S C $ 60108(a) and 49 C F R $ 190237 Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings Please refer to ttus document and note the response options Be\nadvised that all matenal you submit in response to tins enforcement action is subJect to being\nmade publicly available If you believe that any portion of your responsive matenal qualifies for\nconfidential treatment under 5 U S C 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you beheve quahfy for\nconfidential treatment redacted and an explanation of why you beheve the redacted mformation\nquahfies for confidential treatment under 5 U S C 552(b) If you do not respond within 30 days\nof receipt of this Notice, this constitutes a wiuver of your nght to contest the allegations in this\nNotice and authonzes the Associate Administrator for Pipehne Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Fmal Order\nIf, after opportunity for a heanng, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C F R g 190 237) If you are not contesting this Notice, we propose that you submit your\namended procedures to my office wtthm one hundred twenty (120) days of receipt of this Notice\nThis penod may be extended by wntten request for good cause Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action will\nbe closed\nt In correspondence concerning this matter, please refer to CPF 1-2007-6004M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible\nSincerely,\nByron E Coy, PE\nDirector, Eastern Region\nPipehne and Hazardous Matenals Safety Administration\nEnclosure Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":5872}