{"operation":"document","citation":"CPF 120173001M","title":"DISTRIGAS OF MASSACHUSETTS LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-11","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2605(b)(1), 193.2605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120173001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120173001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120173001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120173001M","body":"Notice of Amendment involving DISTRIGAS OF MASSACHUSETTS LLC. PHMSA's enforcement data identifies the cited regulations as 193.2605(b)(1),  193.2605(b)(2). The case was opened on 2017-05-11 and is reported as closed as of 2018-01-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120173001M_Closure Letter_01262018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120173001M/120173001M_Closure%20Letter_01262018.pdf\n\n120173001M_Closure Letter_01262018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120173001M/120173001M_Closure%20Letter_01262018_text.pdf\n\n120173001M_Notice of Amendment_05112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120173001M/120173001M_Notice%20of%20Amendment_05112017.pdf\n\n120173001M_Notice of Amendment_05112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120173001M/120173001M_Notice%20of%20Amendment_05112017_text.pdf\n\n120173001M_Operator Response to Notice (Submittal Of Amended Procedures)_07072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120173001M/120173001M_Operator%20Response%20to%20Notice%20(Submittal%20Of%20Amended%20Procedures)_07072017.pdf\n\n120173001M_Notice of Amendment_05112017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 11, 2017\nRobert Wilson, Chief Executive Officer\nENGIE Gas & LNG\n1990 Post Oak Boulevard, Suite 1900\nHouston Texas, 77056-4499\nCPF 1-2017-3001M\nDear Mr. Wilson:\nFrom October 18-21, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Distrigas\nof Massachusetts’ (Distrigas) maintenance procedures in Everett, Massachusetts.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nDistrigas’ plans or procedures, as described below:\n1. §193.2605 Maintenance procedures.\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The\nprocedure must include:\n(1) The details of the inspections or tests determined under paragraph (a) of this\nsection and their frequency of performance; and…\nDistrigas’ corrosion control procedures are inadequate in that they do not contain guidance for\nidentifying, testing for, and minimizing the detrimental effects of interference currents as\nprescribed in §193.2633.\n§193.2633 Interference Currents states:\n“(a) Each component that is subject to electrical current interference must be protected by a\ncontinuing program to minimize the detrimental effects of currents.”\n\n\n\nCPF 1-2017-3001M\nDuring the inspection, the PHMSA inspector reviewed Distrigas’ annual cathodic protection\nsurvey records for 2014 and 2015. The records indicated that coupons were installed to the vent\nstack pilings in December 2015 as a corrective measure due to concerns of interference currents.\nThe PHMSA inspector requested procedures addressing the monitoring of these coupons for\ninterference currents. Distrigas provided two plant maintenance procedures, EMT 049-\nM/Corrosion Control Monitoring, Revised 3/2/16 and EMT 107-M/Cathodic Protection Systems,\nRevised 3/2/16. In addition, these procedures refer to the adopted plan of its corrosion contractor,\nCorrosion Probe, Inc. (CPI), entitled Comprehensive Plan for Plant-Wide Corrosion\nInspection/Monitoring/Protection Program, Everett Plant, Revised 8/5/03 (CPI Plan). Neither the\nmaintenance plans nor the CPI Plan provided adequate detail on the testing, monitoring or the\nremediation of interference currents.\n2. §193.2605 Maintenance procedures.\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The\nprocedure must include:\n(1) The details of the inspections or tests determined under paragraph (a) of this\nsection and their frequency of performance; and…\nDistrigas’ corrosion control procedures are inadequate in that they do not provide guidance for\nperforming testing on buried steel components under cathodic protection in accordance with\n§193.2635.\n§193.2635 states:\n“Corrosion protection provided as required by this subpart must be periodically monitored to give\nearly recognition of ineffective corrosion protection, including the following, as applicable:\n(a) Each buried or submerged component under cathodic protection must be tested at least once\neach calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic\nprotection meets the requirements of §192.463 of this chapter.”\nDuring the inspection, the PHMSA inspector reviewed Distrigas’ procedures for external corrosion\ncontrol monitoring. Distrigas’ procedures, CPI Comprehensive Plan_Plant Wide Corrosion\nInspection-Monitoring-Protection Program, Revised 8/5/03, Sec. 6 and EMT-049M, Revised\n3/2/16, Sec. 2, specify the interval for testing, and other prescriptive requirements such as the\ncathodic protection criteria utilized.\nIn its annual cathodic protection surveys, Distrigas employs the -850 mV and 100 mV shift criteria.\nThe procedures fail to provide guidance for a corrosion technician to perform the actual testing of\ncomponents to determine compliance with these criteria.\n3. §193.2605 Maintenance procedures.\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The\nprocedure must include: …\n120173001M_Notice of Amendment_05112017_text Page 2 of 4\n\n\n\nCPF 1-2017-3001M\n(2) A description of other actions necessary to maintain the LNG plant according to\nthe requirements of this subpart.\nDistrigas’ corrosion control procedures are inadequate in that they do not provide guidance for\ntaking prompt corrective or remedial action on the cathodic protection (CP) system in accordance\nwith §193.2637.\n§193.2637 Remedial Action states:\n“Prompt corrective or remedial action must be taken whenever an operator learns by inspection or\notherwise that atmospheric, external, or internal corrosion is not controlled as required by this\nsubpart.”\nDuring the inspection, the PHMSA inspector reviewed Distrigas’ procedures for corrosion control\nremedial actions. Distrigas’ CPI Comprehensive Plan for Plant-Wide Corrosion\nInspection/Monitoring/Protection Program, Revised 8/5/03, Section 5, Remediation/Maintenance,\naddresses taking remedial actions on the CP system utilized for external corrosion control. Section\n5.4 Remedial Method Procedures, (C) Cathodic Protection System states in part:\n“…Each of the inspections will include submittal of a written report to Distrigas identifying all\nPotential and Current Measurements, inspection findings, and recommendations for repair or\nmaintenance work. This work will be performed by Corrosion Probe, Inc.”\nThis procedure does not include sufficient guidance to address the requirements of §193.2637\nregarding deficiencies with the CP system, such as:\n1. Specifying required response time for “prompt” remedial action\n2. Prescribing and detailing appropriate corrective or remedial actions\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\n120173001M_Notice of Amendment_05112017_text Page 3 of 4\n\n\n\nCPF 1-2017-3001M\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Distrigas maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-3001M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120173001M_Notice of Amendment_05112017_text Page 4 of 4\n\n120173001M_Closure Letter_01262018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJanuary 26, 2018\nRobert Wilson\nChief Executive Officer\nENGIE Gas & LNG\n1990 Post Oak Boulevard, Suite 1900\nHouston, TX 77056-4499\nCPF 1-2017-3001M\nDear Mr. Wilson:\nFrom October 18-21, 2016; a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Distrigas of Massachusetts’ (Distrigas) maintenance procedures in\nEverett, Massachusetts. As a result of the inspection, Distrigas was issued a Notice of Amendment\non May 11, 2017; which proposed amendment of your procedures.\nDistrigas submitted its amended procedures on December 11, 2017. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":11028}