{"operation":"document","citation":"CPF 120165005M","title":"PORTLAND PIPE LINE CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-07-11","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120165005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120165005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120165005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120165005M","body":"Notice of Amendment involving PORTLAND PIPE LINE CORPORATION. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2016-07-11 and is reported as closed as of 2016-08-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120165005M_Closure Letter_08252016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165005M/120165005M_Closure%20Letter_08252016.pdf\n\n120165005M_Closure Letter_08252016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165005M/120165005M_Closure%20Letter_08252016_text.pdf\n\n120165005M_Notice of Amendment_07112016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165005M/120165005M_Notice%20of%20Amendment_07112016.pdf\n\n120165005M_Notice of Amendment_07112016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165005M/120165005M_Notice%20of%20Amendment_07112016_text.pdf\n\n120165005M_Operator Response to Notice and Request for Hearing_08112016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165005M/120165005M_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing_08112016.pdf\n\n120165005M_Notice of Amendment_07112016_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJuly 11, 2016\nThomas Hardison, Vice President\nPortland Pipe Line Corporation\n30 Hill Street\nSouth Portland, ME 04106\nCPF 1-2016-5005M\nDear Mr. Hardison:\nFrom July 14 through July 16, 2015, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nPortland Pipe Line Corporation’s (Portland) pipeline facility in South Portland, Maine.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPortland’s plans or procedures, as described below:\n1. § 195.402(c)(3)\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nPortland’s procedures for operating, maintaining and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of this part are inadequate for\noverpressure safety devices. Specifically, the procedures fail to provide sufficient guidance on\nhow to conduct and document relief valve inspections as per §195.428(a).\nDuring the inspection, the PHMSA inspector reviewed pressure control inspection and testing\nprocedures – Portland O&M Section 6 - Maintenance; revised 06/15, and the pressure control\ninspection and testing records for 2014.\nPortland’s procedure, Section 6 - Maintenance, did not provide sufficient guidance on conducting\nand documenting a relief valve inspection.\n\n\n\n1-2016-5005M\nIn order to ensure that a relief valve will relieve at the specified set pressure when needed, data is\nneeded on the condition of the valve prior to the inspection (“as found”), as well as on the condition\nof the valve after the inspection is completed (“as left”). Information typically documented\nincludes:\n1. The relief pressure of the valve in the “as found” condition\n2. The relief pressure of the valve in the “as left” condition\n3. The “set point”\nPortland’s procedure did not include any requirements for capturing either the “as found” or “as\nleft” pressure of a relief device. In addition, the procedure lacked details such as:\n1. The criteria for determining acceptable “as-found” / “as left” relief pressures\n2. The actions that must be taken if the relief valve “as-found” pressure does not meet the\ncriteria\n3. 4. The definition of the term “set point”\nThe documentation required and where it must be recorded, for example:\na. The information that must be captured in the Protective Device Testing record\nb. Where the “as-found” and “as-left” pressures are recorded\n5. How to ensure that the MOP will not be exceeded during testing of the relief device\n2. § 195.402(c)(3)\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nPortland’s procedures for operating, maintaining and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of this part are inadequate for\ndetermining MOP. Specifically, Portland’s procedure lacks details on how the maximum\noperating pressure (MOP) is determined in accordance with §195.406(a).\nDuring the inspection, the PHMSA inspector reviewed Portland Pipeline’s O&M, Section 4.2.7.1\n“Maximum Pipe Joint MAOP” dated 2-2015. The procedure lacks details such as:\n1. The criteria used to establish the MOP\n2. 3. 4. How the internal design pressure of the pipe is determined, in accordance with §195.106\nHow the surge pressure requirements are met, per §195.406\nThe documentation and retention requirements for MOP records\nPortland Pipe Line was unable to provide any relevant procedures in their O&M which\ndemonstrated how the Operator established its MOP.\n120165005M_NOA_07112016 Page 2 of 4\n\n\n\n1-2016-5005M\n3. § 195.402(c)(3)\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nPortland’s procedures for operating, maintaining, and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of this part are inadequate in that they\ndo not properly address the maintenance of mainline valves as per §195.420. Specifically,\nPortland’s procedures do not contain a process for ensuring deficiencies found during mainline\nvalve inspections are remediated.\nDuring the inspection, the PHMSA inspector reviewed Portland O&M Section 6 – Maintenance,\n6.7.3 “Block Valves.” The procedure lacked adequate guidance such as:\n1. The process for ensuring that results of the inspection are documented, e.g. who is\nresponsible for documentation entry / approval\n2. The process for ensuring that deficiencies found during inspections are remediated, for\nexample:\na. 3. What is the criteria for determining the timeframe for remediation\nb. Who is responsible for approving the proposed remediation work and the\ntimeframe\nHow the work is documented, e.g. forms / work orders\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 Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 60 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in\nyour amended procedures, this enforcement action will be closed.\n120165005M_NOA_07112016 Page 3 of 4\n\n\n\n1-2016-5005M\nIt is requested (not mandated) that Portland maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear\nTavern Road, Suite 103, W. Trenton, NJ 08628, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 1-2016-5005M\nand, for each document you submit, please provide a (signed) copy in electronic format whenever\npossible. Smaller files may be emailed to Byron.Coy@dot.gov. Larger files should be sent on a\nCD accompanied by the original (signed) paper copy to the Eastern Region Office.\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120165005M_NOA_07112016 Page 4 of 4\n\n120165005M_Closure Letter_08252016_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nAugust 25, 2016\nThomas Hardison, Vice President\nPortland Pipe Line Corporation\n30 Hill Street\nSouth Portland, ME 04106\nCPF 1-2016-5005M\nDear Mr. Hardison:\nFrom July 14 through July 16, 2015, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted\nan on-site pipeline safety inspection of Portland Pipe Line Corporation’s (Portland) pipeline\nfacility in South Portland, Maine. As a result of the inspection, Portland was issued a Notice of\nAmendment on July 11, 2016, which proposed amendment of its procedures.\nPortland submitted its amended procedures on August 11, 2016. 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\nyou for your cooperation.\nSincerely,\nByron Coy, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":10595}