{"operation":"document","citation":"CPF 120085004M","title":"PORTLAND PIPE LINE CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-16","effective_on":null,"summary":"CLOSED notice of amendment citing 195.403, 195.567(b)(1), 195.573(c), 195.573(e), 195.575(c), 195.579(a), 195.579(c), 195.581(a), 195.583(a), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120085004M","body":"Notice of Amendment involving PORTLAND PIPE LINE CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.403,  195.567(b)(1),  195.573(c),  195.573(e),  195.575(c),  195.579(a),  195.579(c),  195.581(a),  195.583(a),  195.589(c). The case was opened on 2008-09-16 and is reported as closed as of 2009-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120085004M_Closure Letter_12142009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085004M/120085004M_Closure%20Letter_12142009.pdf\n\n120085004M_Closure Letter_12142009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085004M/120085004M_Closure%20Letter_12142009_text.pdf\n\n120085004M_Notice of Amendment_09162008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085004M/120085004M_Notice%20of%20Amendment_09162008.pdf\n\n120085004M_Operator Response and Request for Time Extension_09262008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085004M/120085004M_Operator%20Response%20and%20Request%20for%20Time%20Extension_09262008.pdf\n\n120085004M_Operator Response to Notice Letter_10152009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085004M/120085004M_Operator%20Response%20to%20Notice%20Letter_10152009.pdf\n\n120085004M_Notice of Amendment_09162008.pdf\n\nU.S. Department\nof Transportation\n409 3° St. S.W. Suite 300\nPipeline and\nWashington, D.C. 20024\nHazardous Materials\nSafety Administration\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 16, 2008\nMs. Marjorie Dawson\nPresident\nPortland Pipeline Terminal\n30 Hill Street\nS. Portland, ME 04106\nCPF 1-2008-5004M\nDear Ms. Dawson:\nDuring the week of November 5, 2007, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour crude oil pipeline between Portland, Maine and Jay, Vermont.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPortland Pipeline Corporation's (PMPL) plans or procedures, as described below:\n\n\n\n1.\n§195.403 Emergency Response Training.\n(a) Each operator shall establish and conduct a continuing training program to\ninstruct emergency response personnel to:\n(1) Carry out the emergency procedures established under 195.402 that relate to\ntheir assignments;\n(2) Know the characteristics and hazards of the hazardous liquids or carbon\ndioxide transported, including, in case of flammable HVL, flammability of mixtures\nwith air, odorless vapors, and water reactions;\n(3) Recognize conditions that are likely to cause emergencies, predict the\nconsequences of facility malfunctions or failures and hazardous liquids or carbon\ndioxide spills, and take appropriate corrective action;\n(4) Take steps necessary to control any accidental release of hazardous liquid or\ncarbon dioxide and to minimize the potential for fire, explosion, toxicity, or\nenvironmental damage; and\n(5) Learn the potential causes, types, sizes, and consequences of fire and the\nappropriate use of portable fire extinguishers and other on-site fire control\nequipment, involving, where feasible, a simulated pipeline emergency condition.\nSection 11 of PMPL's Operations and Maintenance Procedures Manual (O&M) details PMPL's\nregarding the training materials. Operator states that the entire O&M is the training guide. The\nEmergency Response Training Procedures (ERTP). The procedures are lacking sufficient detail\nERTP was lacking specificity with respect to training materials, training curriculum and schedule\nof the ERT classes.\n2.\n§195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(b) Installation. You must install test leads as follows:\n(1) Locate the leads at intervals frequent enough to obtain electrical measurements\nindicating the adequacy of cathodic protection.\n(c) Maintenance. You must maintain the test lead wires in a condition that enables\nyou to obtain electrical measurements to determine whether cathodic protection\ncomplies with Sec. 195.571.\nPMPL's O&M section 6.5.2.2 states that test stations are located at most road crossings along the\nOW. This does not necessarily assure that the operator can properly monitor the adequacy of\nhe cathodic protection alone the entire pipeline. The procedures fail to establish a maintenanc\nprogram for the test lead wires to assure their suitability for testing the cathodic protection\nsystem on the pipeline.\n§195.573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper\nperformance each device in the first column at the frequency stated in the second\ncolumn.\n2\n\n\n\nDevice\nCheck frequency\nRectifier\nAt least six times each calendar year, but\nReverse current switch\nwith intervals not exceeding 2 ½ months\nDiode\nInterference bond whose failure would\njeopardize structural protection\nOther interference bond\nAt least once each calendar year, but\nWith intervals not exceeding 15 months.\nPMPL's O&M section 6.5.2.2.f states:\nResistance bonds - These are electric ties between our own lines and foreign\npipelines that cross us. Data is gathered that reflects the electric current flow in\namperes to or from these lines.\nThe O&M provides no guidance on the testing of the interference bond nor does it provide the\nresults of the monitoring that would prompt corrective action.\n§195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion\ncontrol as required by Sec. 195.401(b). However, if the deficiency involves a\npipeline in an integrity management program under Sec. 195.452, you must\ncorrect the deficiency as required by Sec. 195.452(h).\nPMPL's O&M do not specify that deficiencies identified in corrosion control must be corrected\nto satisfy §195.401(b) which requires that corrections be done within a reasonable time, or if the\ncondition presents an immediate hazard .... the operator may not operate the pipeline until it has\ncorrected the unsafe condition\n5.\n§195.575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n(c) You must inspect and electrically test each electrical isolation to assure the\nisolation is adequate.\nPMPL's O&M section 6.5.5.4.b state that the insulated flanges and casings will be tested, but\nthey do not specify a definite test interval. There is no prescribed follow-up action when\noperator discovers a shorted casing.\n§195.579 What must I do to mitigate internal corrosion?\n(a) General. If you transport any hazardous liquid or carbon dioxide that would\ncorrode the pipeline, you must investigate the corrosive effect of the hazardous\nliquid or carbon dioxide on the pipeline and take adequate steps to mitigate internal\ncorrosion.\nPMPL states that the tariff limits crude to <1% BS& W (sand, grit, dirt, wax and water).\nOperator runs a cleaning pig through the pipeline quarterly. Vessels provide assay analysis with\n3\n\n\n\nhydrogen sulfide (HS) concentrations, but the procedures do not provide threshold levels of\nHaS, or other corrosive materials, to alert operating staff of problem batches and what protections\noperator could take to protect the pipeline from internal corrosion.\n7.\n195.579 What must I do to mitigate internal corrosion?\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect\nthe internal surface of the pipe for evidence of corrosion. If you find internal\ncorrosion requiring corrective action under Sec. 195.585, you must investigate\ncircumferentially and longitudinally beyond the removed pipe (by visual\nexamination, indirect method, or both) to determine whether additional corrosion\nrequiring remedial action exists in the vicinity of the removed pipe.\nPMPL's O&M fails to provide procedures to maintenance staff on the inspection of removed\npipe for internal corrosion.\n8.\n$195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\na) You must clean and coat each pipeline or portion of pipeline that is exposed to\nthe atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\nPMPL O&M fails to specify the process involved in the application of coating to ensure that it\nadheres to the pipeline. The O&M also fails to specify acceptable coatings to protect the\npipeline from atmospheric corrosion.\n9.\n§195.583 What must I do to monitor atmospheric corrosion control?\na) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located onshore, then the frequency of inspection is at least once\nevery 3 calendar years, but with intervals not exceeding 39 months...\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports...\nand in spans over water.\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by Sec. 195.581.\nPMPL's O&M in Section 6 refers to the annual paint inspection. There is only reference to\n\"paint and coating failures.\" Procedures fail to specify different levels of coating failure, levels\nof pipe degradation or urgency of remediation. Procedures provide only for remediation during\nwarmer weather.\n10.\n§195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\n4\n\n\n\nretain these records for at least 5 years, except that records related to Sees. 195.569,\n195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the\npipeline remains in service.\nPMPL's O&M in Section 6 requires only that \"if abnormalities are discovered [during the annual\npaint/coating inspection], an immediate report is made to maintenance Supervisor South\nPortland.\" PMPL's procedures do not specify criteria to measure the adequacy of corrosion\nCOME peasedises do not designard herablon record retenin requiring control measures.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material 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 believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies 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 waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, 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. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 1-2008-5004M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5\n\n120085004M_Closure Letter_12142009_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 306\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nDecember 14, 2009\nEXPRESS OVERNIGHT DELIVERY\nMs. Marjorie Dawson\nPresident\nPortland Pipeline Terminal\n30 Hill Street\nPortland, Maine 04106\nCPF 1-2008-5004M\nDear Ms. Dawson:\nDuring the week of November 7, 2007, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Portland Pipeline Corporation’s (PMPL)\nprocedures in South Portland, Maine. As a result of the inspection, PMPL was issued a Notice of\nAmendment on September 16, 2008, which proposed amendment of your procedures.\nPMPL submitted its amended procedures on October 15, 2009. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":13743}