GORDON TERMINAL SERVICES — Notice of Amendment

120076004m_notice of amendment_11052007_text.pdf, page 1Official PDFO U S Department af Transpanatian Pipeline and Hazardous Matetfals Safety Administration 409 3rd Street, SW Suite 300 Washington, Da 20024 NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT RE UESTED November 5, 2007 Mr Tim Gordon Vice President Gordon Terminals P 0 Box 313 McKees Rocks, PA 15136 CPF 1-2007-6004M Dear Mr Gordon On September 11-12, 2007, representatives of the Pipehne and Hazardous Matenals Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code inspected Gordon Termmal's procedures in McKees Rocks, Pennsylvania for integnty management of Gordon's Tioga Pipeline On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Gordon's plans or procedures, as descnbed below IM Plan Development in Framework Stage s195. 4 52(b) What program and practices must operators use to manage pipeline integrity? (5) Implement and follow the program; tt195. 452(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,#

120076004m_notice of amendment_11052007_text.pdf, page 2conclusions 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. A number of issues involved with the Integrity Plan are addressed in Gordon's OPA 90 and O&M Plans The issues mcluded in those plans should be referenced in the IM Plan where ever appropriate Gordon conducts their patrol activities in accordance with 195 requirements and their O&M procedures outhne the field process This process needs to be expanded to expliun what happens with field documents once they are received in the office for disposition Risk Factors $195. 452(i) An operator must include, at minimum, each of the following elements in its written integrity management program: (3) An analysis that integrates all available information about the integrity of the entire pipeline and the consequences of a fadure Gordon has provided well-summanzed tables within their IM Plan One of those tables shows risk factors where third party excavation damage needs to be included Gordon provides in their IM Plan a "vulnerabdity analysis" for each pipehne section and the farm tanks For clanficatton, these analyses should explicitly state in some fashion that they address the "nsk analysis" requirements of the IM Rule Within the P&M measures portion of the IM Plan, Gordon needs to state how these measures have impacted their nsk factors For the leak detection portion of their P&M measures, the "N/A" shown for the risk assessment results of the tank farm should be changed to reference the appropriate secuon m the IM Plan where the results are documented Classification of Anomalies II195. 452(h) What actions must an operator take to address integrity issues? Gordon has assessed their pipehnc using a successful pressure test where no anomahcs were found In the event future assessments result in needed repairs, more detail is needed withm their plan outhning how these repairs would be prioritizcd#

120076004m_notice of amendment_11052007_text.pdf, page 3Res onse to this Notice This Notice is provided pursuant to 49 U S C $ 60108(a) and 49 C F R $ 190237 Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings Please refer to ttus document and note the response options Be advised that all matenal you submit in response to tins enforcement action is subJect to being made publicly available If you believe that any portion of your responsive matenal 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 beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted mformation quahfies for confidential treatment under 5 U S C 552(b) If you do not respond within 30 days of receipt of this Notice, this constitutes a wiuver of your nght to contest the allegations in this Notice and authonzes the Associate Administrator for Pipehne Safety to find facts as alleged in this Notice without further notice to you and to issue a Fmal Order If, after opportunity for a heanng, 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 g 190 237) If you are not contesting this Notice, we propose that you submit your amended procedures to my office wtthm one hundred twenty (120) days of receipt of this Notice This penod may be extended by wntten request for good cause Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed t In correspondence concerning this matter, please refer to CPF 1-2007-6004M and, for each document you submit, please provide a copy in electronic format whenever possible Sincerely, Byron E Coy, PE Director, Eastern Region Pipehne and Hazardous Matenals Safety Administration Enclosure Response Options for Pipeline Operators in Compliance Proceedings#