VALERO NATURAL GAS PIPELINE — Notice of Amendment

party submissionOfficial PDF120081002M_Operator_Response_02082008.pdf#

120081002m_notice of amendement_01112008_text.pdf, page 1Official PDFU. S. Department of Transportation Eastern Region-PHP-100 Office of Pipehne Safety 4093' St S W Suite 300 Washington, D C 20024 Pipeline and Hazardous Materials Safety Administration NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT RE UESTED January 11, 2008 John Pickering Vice President and General Manager Valero Energy Corporation One Valero Way San Antonio, TX 78249-1616 CPF 1-2008-1002M Dear Mr. Pickering: During the week of May 29, 2007, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Valero Natural Gas Pipeline Company's (Valero) procedures for periodically reviewing work of personnel to determine the adequacy of its operating and mamtenance procedures and monitoring odorant levels of transmission line gas at the Paulsboro, New Jersey refinery, On the basis of the inspection, PHMSA has identified apparent inadequacies found within Valero's plans or procedures, as described below: 1. $192. 605 Procedural manual for operations, maintenance and emergencies. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations.#

120081002m_notice of amendement_01112008_text.pdf, page 2(8) Periodically reviewing the work done by operator personnel to determine the effectiveness and adequacy of the procedures used in normal operation and maintenance and modifying the procedure when deficiencies are found. Procedures need to be developed to address $192, 605(b) (8). The procedures should identify the responsible person(s) to review the work done by operating personnel, and to determine the effectiveness of the procedures and what corrective action will be taken when deficiencies are identified. 2. $192. 625 Odorization of gas. (f) To assure the proper concentration of odorant in accordance with this section, each operator must conduct periodic sampling of combustible gases using an instrument capable of determining the percentage of gas in air at which the odor becomes readily detectable Valero procedures state: Periodic samplmg. . . will be conducted using an instrument capable of determining the percentage of gas in air at which the odor becomes readily detectable. The Odorization Procedure (Proc. 240, sec. A. 5) fails to specify the type of instrument Valero employs in this function, and it also fails to specify an interval to guide personnel on the test frequency to verify the adequacy of the odorant level in the gas stream. Res onse to this Notice This Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 190. 237. 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 beheve 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). 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 m this Notice without further notice to you and to issue a Final Order,#

120081002m_notice of amendement_01112008_text.pdf, page 3If, after opportunity for a hearing, 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. 237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within [number of days] 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. In correspondence concerning this matter, please refer to CPF 1-2008-1002M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Syron E. Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings#