{"operation":"document","citation":"CPF 120176002M","title":"UTICA EAST OHIO MIDSTREAM LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(13), 195.402(c)(2), 195.402(c)(3), 195.402(d)(1)(i), 195.402(d)(1)(ii), 195.402(d)(1)(iii), 195.402(d)(1)(v), 195.402(d)(2), 195.402(d)(3), 195.402(d)(4), 195.402(d)(5), 195.452(f)(3), 195.452(f)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120176002M","body":"Notice of Amendment involving UTICA EAST OHIO MIDSTREAM LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(13),  195.402(c)(2),  195.402(c)(3),  195.402(d)(1)(i),  195.402(d)(1)(ii),  195.402(d)(1)(iii),  195.402(d)(1)(v),  195.402(d)(2),  195.402(d)(3),  195.402(d)(4),  195.402(d)(5),  195.452(f)(3),  195.452(f)(5). The case was opened on 2017-06-08 and is reported as closed as of 2018-03-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120176002M_Closure letter_03022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Closure%20letter_03022018.pdf\n\n120176002M_Closure letter_03022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Closure%20letter_03022018_text.pdf\n\n120176002M_Notice of Amendment_06082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Notice%20of%20Amendment_06082017.pdf\n\n120176002M_Notice of Amendment_06082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Notice%20of%20Amendment_06082017_text.pdf\n\n120176002M_Operator Response To Notice_09272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Operator%20Response%20To%20Notice_09272017.pdf\n\n120176002M_Closure letter_03022018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMarch 2, 2018\nJames Roberts\nVice President of Environmental, Health, and Safety\nUtica East Ohio Midstream LLC\n600 Travis, Suite 5600\nHouston, TX 77002\nCPF 1-2017-6002M\nDear Mr. Roberts:\nFrom August 10 – 14, 2015, a representative from the Pipeline and Hazardous Materials Safety\nAdministration, Office of Pipeline Safety pursuant to Chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Utica East Ohio Midstream LLC’s (UEO)\nprocedures in Salineville, Ohio. As a result of the inspection, UEO was issued a Notice of\nAmendment (NOA) on June 8, 2017, which proposed amendments of its procedures.\nUEO submitted its amended procedures on September 27, 2017. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the NOA have 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\n\n120176002M_Notice of Amendment_06082017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 8, 2017\nJames Roberts\nVice President of Environmental, Health, and Safety\nUtica East Ohio Midstream LLC\n600 Travis, Suite 5600\nHouston, TX 77002\nCPF 1-2017-6002M\nDear Mr. Roberts:\nFrom August 10 to 14, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code inspected certain procedures in Utica East Ohio Midstream LLC’s (UEO) Momentum\nGas & Liquid Pipeline Integrity Management Program, Last Revision Date July 2015 (IMP) and\nOperation, Maintenance and Emergency Manual, Revised July 2015 (OM&E Manual) in\nSalineville, Ohio.1\nBased on the inspection, PHMSA has identified the apparent inadequacies found within UEO’s\nplans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at\nintervals not exceeding 15 months, but at least once each calendar year, and appropriate\nchanges made as necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and appropriate parts\nshall be kept at locations where operations and maintenance activities are conducted.\n1 UEO is a joint venture between Access Midstream Partners L.P. (Access) (Williams Partners L.P. merged with\nAccess), M3 Midstream LLC (Momentum) and EV Energy Partners, L.P. See, William’s website, available at\nhttp://investor.williams.com/press-release/access-midstream-partners-projects/utica-east-ohio-announces-major-\nexpansion (last accessed May 10, 2017).\n\n\n\nCPF 1-2017-6002M\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for reviewing the manual at intervals not exceeding\n15 months, but at least once each calendar year in accordance with §195.402(a) as prescribed in\n§195.402(c)(3). Specifically, the OM&E Manual, Section 2 – Plan Review did not include a clear,\ndetailed process for reviewing the manual and documenting recommendations within the required\ninterval.\nSubsection 2.1 Manual Review 195.402(a) on page 1 of 3 states: “This plan will be evaluated for\neffectiveness every year (not to exceed 15 months) by the Vice President of Operations or his\ndesignee. The review designee should utilize the latest DOT Pipeline Standard Inspection\nChecklist… The DOT Pipeline Standard Inspection Checklist site is:\nhttps://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/PHMSA Form 1 200\n9.pdf.”\n1. The “Inspection Checklist” referenced in the procedure is PHMSA standard inspection report\nof a gas transmission pipeline form rev. 03/23/09. This form is out-of-date and UEO had a\nliquid pipeline system. Therefore, the procedure did not include an applicable checklist or\nquestionnaire to assist with determining needed changes or improvements in the manual.\nMoreover, the procedure did not include further instructions for reviewing the manual and\ndetermining whether changes or improvements are necessary.\n2. The procedure did not provide details on documenting recommendations and justifications for\nchanges or improvements in the manual.\n3. Section 2 – Plan Review referenced Form 20.2 to document the reviews and revisions.\nHowever, the form only had one column for a date – so it is unclear when a review or a revision\noccurred. In addition, the form did not require the review date to be month/day/year format to\ndemonstrate manual review completed within the required interval.\nThus, the procedures were inadequate for reviewing the manual at intervals not exceeding\n15 months, but at least once each calendar year in accordance with §195.402(a).\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n120176002M_Notice of Amendment_06082017_text Page 2 of 28\n\n\n\nCPF 1-2017-6002M\n(1) …\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\ntimely and effective manner.\nUEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,\nSubsection 19.14 Telephonic Notification did not identify who is responsible for making a notice\nin accordance with §195.52(a).2\nAccording to §195.52(a), at the earliest practicable moment following discovery, of a release of\nthe hazardous liquid or carbon dioxide transported resulting in an event described in §195.50, but\nno later than one hour after confirmed discovery, the operator of the system must give notice, in\naccordance with §195.52(b) of any failure that meets the criteria therein. Section 195.52(b)\nrequires the notice to include the information listed under that paragraph to the National Response\nCenter (NRC).\nSubsection 19.4 Telephonic Notification did not state the person who is responsible for making the\nnotice and giving the required information to the NRC. Therefore, the procedures were inadequate\nfor reporting accidents under subpart B of Part 195 in a timely and effective manner in accordance\nwith§195.52(a).\n3. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\ntimely and effective manner.\nUEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,\nSubsection 19.14 Telephonic Notification did not require the minimum information in the notice\nin accordance with §195.52(b)(6).\nAccording to §195.52(b)(6), the initial estimate of amount of product released must be included in\nthe notice made to the National Response Center.\n2 Section 195.52(a) was in effect at the time of the PHMSA’s inspection but subsequently amended, effective\nMarch 24, 2017. 82 Fed. Reg. 7999 (Jan. 23, 2017).\n120176002M_Notice of Amendment_06082017_text Page 3 of 28\n\n\n\nCPF 1-2017-6002M\nSubsection 19.14 Telephonic Notification required the following information:\n1. 2. 3. 4. 5. 6. Name and address of the operator.\nName and telephone number of the reporter.\nThe location of the failure.\nThe time of the failure.\nThe fatalities and personal injuries (if any).\nAll other significant facts known by the operator that are relevant to the cause of the\nfailure or extent of the damages.\nThe procedure did not include the requirement for including the initial estimate of amount of\nproduct released in the notice.\nThus, the procedures were inadequate for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner in accordance with §195.52(b)(6).\n4. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\ntimely and effective manner.\nUEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,\nSubsection 19.14 Telephonic Notification did not include a written procedure for calculating a\nreasonable initial release estimate in accordance with §195.52(c).\n5. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n120176002M_Notice of Amendment_06082017_text Page 4 of 28\n\n\n\nCPF 1-2017-6002M\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\ntimely and effective manner.\nUEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,\nSubsection 19.14 Telephonic Notification did not include a process for revising or confirming its\ninitial notice in accordance with §195.52(d).3\n6. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\ntimely and effective manner.\nUEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,\nSubsection 19.15 Incident Written Notification did not require accidents reports to be electronically\nfiled as soon as practicable but not later than 30 days after discovery in accordance with\n§195.54(a).\nAccording to the PHMSA F 7000-1 (Instructions for Form), accident reports must be submitted\nonline through the PHMSA Portal unless an alternate method is approved.4\nSubsection 19.15 Incident Written Notification on page 12 of 16 states in part: “Submit the\nDepartment of Transportation / Office of Pipeline Safety / Transmission Incident Report (RSPA\n7100.2) within 30 days after discovery of the incident to the following to the written report\naddresses listed below: … Liquid Report PHMSA 7000-1.1.” The procedures did not require\nelectronic reporting.\nIn addition, for an accident that meets the criteria in §195.50, Form PHMSA F 7000-1 must be\nfiled as soon as practicable but not more than 30 days after discovery of the accident as described\nin §195.54(a). The procedure did not require reports be filed “as soon as practicable.”\nTherefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in\n3 Section 195.52(d) was in effect at the time of the PHMSA’s inspection but subsequently amended, effective\nMarch 24, 2017. 82 Fed. Reg. 7999 (Jan. 23, 2017).\n4 See, http://phmsa.dot.gov/pipeline/library/forms.\n120176002M_Notice of Amendment_06082017_text Page 5 of 28\n\n\n\nCPF 1-2017-6002M\na timely and effective manner in accordance with §195.54(a).\n7. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\ntimely and effective manner.\nUEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a\ntimely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual,\nSubsection 19.15 Incident Written Notification did not require the supplemental report be filed\nwithin 30 days of receiving changes or additions to the originally reported information in\naccordance with §195.54(b).\nSubsection 19.15 Incident Written Notification on page 13 of 16, states in part: “Where additional\nrelated information is obtained after a report is submitted as listed… must make a supplement\nreport (as soon as practicable) with clear reference by date and subject to the original report\n(emphasis added).” The procedure did not give specific instructions to “submit” or “file” the\nsupplemental report online through the PHMSA Portal within the 30-day timeframe.\nTherefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in\na timely and effective manner in accordance with §195.54(b).\n8. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had procedures that did not adequately require maintaining current maps and\nrecords of all crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines in\n120176002M_Notice of Amendment_06082017_text Page 6 of 28\n\n\n\nCPF 1-2017-6002M\naccordance with §195.404(a)(2) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,\nSubsection 5.4 Record Retention 195.404 did not include provisions to comply with\n§195.404(a)(2). In addition, Section 5- Recordkeeping did not describe the manner in which\npersonnel must maintain records, for example hard copies, electronic files, intranet, etc.\n9. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had procedures that did not adequately require maintaining current maps and\nrecords of the diameter, grade, type, and nominal wall thickness of all pipe in accordance with\n§195.404(a)(4) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 5.4\nRecord Retention 195.404 did not include provisions to comply with §195.404(a)(4). In addition,\nSection 5- Recordkeeping did not describe the manner in which personnel must maintain records,\nfor example hard copies, electronic files, intranet, etc.\n10. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for conducting inspections of rights-of-way (ROW) in\naccordance with §195.412(a), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,\nSubsection 7.1 Pipeline Patrol 195.412 did not include guidance for ensuring mitigation measure\nwill be taken when conditions are found along the ROW.\nSubsection 7.1 Pipeline Patrol 195.412 referenced Form 20.3 for documenting the ROW\n120176002M_Notice of Amendment_06082017_text Page 7 of 28\n\n\n\nCPF 1-2017-6002M\ninspection. Neither document gave instructions for documenting the actions taken to ensure safe\noperation of the pipeline when a condition is found along the ROW. In addition, Subsection 7.1\nPipeline Patrol 195.412 did not specify who must receive notification of a condition found along\nthe ROW such as a leak or soil erosion to inform them to take the appropriate action(s).\nThus, the procedures were inadequate for conducting inspections of rights-of-way (ROW) in\naccordance with §195.412(a).\n11. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for inspecting each mainline valve to determine that it\nis functioning properly in accordance with §195.420(b) as prescribed in §195.402(c)(3).\nSpecifically, the OM&E Manual, Subsection 11.1 Valve Inspection 195.420 did not contain a\ndetailed process for inspecting and maintaining mainline valves on its pipeline system.\nSubsection 11.1 Valve Inspection 195.420 of the OM&E Manual did not include:\n1. Guidelines on inspecting the general appearance of valves on its pipeline system,\nparticularly, the paint and coating finish.\na. The procedure states to prepare Form 20.8 if there is evidence of corrosion but there\nwas no guidance – no coating criteria or rating to determine next appropriate action(s)\ni.e. to prepare Form 20.8.\nb. The procedures refer to Form 20.9 for documentation of valve inspection but the\nform did not have a place for recording the paint and coating condition. There is no\nconnection between the Form 20.8 and Form 20.9.\n2. A specified timeframe to correct deficiencies identified during valve inspection and\ndocumenting remedial actions.\n3. Guidance for maintaining valves on the pipeline system that have solar panels.\n4. A process for the winterization of valves and making sure valves with an indicator, clearly\nshow the valve position.\n120176002M_Notice of Amendment_06082017_text Page 8 of 28\n\n\n\nCPF 1-2017-6002M\n5. Instructions to safely inspect and maintain valves; for example, checking for vapors and\ngas level, removing hazards from valves before attempting an inspection or repair, and\nlockout/tagout practices.\nThe procedures did not reference other sections of the manual or documents (manufacturer's\nspecifications) for additional guidance. Thus, the procedures were inadequate for inspecting each\nmainline valve to determine that it is functioning properly in accordance with §195.420(b).\n12. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for inspecting and testing each highly volatile liquids\n(HVLs) pressure limiting device, relief valve, pressure regulator, or other item of pressure control\nequipment in accordance with §195.428(a) as prescribed in §195.402(c)(3). Specifically, the\nOM&E Manual, Subsection 9.8 Pressure Limiting Devices Inspection 195.428 and Forms 20.4(A)\nand (B) did not include details such as:\n1. Recording the “as found” and “as left” settings when inspecting overpressure safety\ndevices except Form 20.4 (B), this had a field for recording “as left” pressure.\n2. Documenting calculations of capacities include the piping size and length associated with\nthe relief device.\n3. Establishing a schedule for repairing or replacing devices if capacity is not satisfactory.\n4. Determining what is acceptable “as found” setting.\nThus, the procedures were inadequate for inspecting and testing each HVL pressure limiting\ndevice, relief valve, pressure regulator, or other item of pressure control equipment in accordance\nwith §195.428(a).\n13. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\n120176002M_Notice of Amendment_06082017_text Page 9 of 28\n\n\n\nCPF 1-2017-6002M\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s had procedures that did not adequately require documents that support decisions and\nanalyses, any modifications, justifications, deviations and determination made, variances, and\nactions taken to implement and evaluate each element of the integrity management program listed\nin §195.524(f) to be maintained for the useful life of the pipeline in accordance with\n§195.452(l)(1)(ii) as prescribed in §195.402(c)(3).\nDuring this inspection, UEO presented Section 1 Identification of Could Affect HCAs, Table 1.1 –\nRecord Retention of its IMP as the recordkeeping procedure for the integrity management program.\nNeither Table 1.1 nor the OM&E Manual included specific instructions for maintaining the records\nlisted in §195.452(l)(1)(ii).\n14. 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for requiring and verifying that supervisors maintain a\nthorough knowledge of that portion of the corrosion control procedures established under\n§195.402(c)(3) for which they are responsible for insuring compliance in accordance with\n§195.555 as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Section 10 Corrosion\nControl did not explicitly address requirements for a supervisor to maintain knowledge and insure\ncompliance with the corrosion control procedures.\nSection 10 on page 1 of 12 states: “Corrosion control procedures required by this section (including\nthose for the design, installation, operation and maintenance of cathodic protection systems), must\nbe carried out by, or under the direction of, a person qualified in pipeline corrosion control\nmethods. Qualification may include person certified by the National Association of Corrosion\nEngineers or other qualified persons identified in the Momentum Operator Qualification Program\n(emphasis added).”\nFirst, the procedure did not address a supervisor. The procedure addressed “qualified personnel”\n120176002M_Notice of Amendment_06082017_text Page 10 of 28\n\n\n\nCPF 1-2017-6002M\nwhich is general. Second, the procedure said, “carried out by, or under the direction of” – this\nstatement does not seem like it is meant for a supervisor. The supervisor is responsible for insuring\ncompliance of the corrosion control procedures. Finally, the procedure did not state the\nqualification requirements for a supervisor to maintain knowledge of the corrosion control\nprocedures. The procedure said, “qualification may include persons certified by [NACE] or other\nqualified persons identified in the Momentum Operator Qualification Program (emphasis added).”\nThe procedure did not ensure the supervisor would be knowledgeable and educated and/or\nexperienced in corrosion control.\nThus, the procedures were inadequate for requiring and verifying that supervisors maintain a\nthorough knowledge of that portion of the corrosion control procedures established under\n§195.402(c)(3) for which they are responsible for insuring compliance in accordance with\n§195.555.\n15. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for the protection of pipe at soil-to-air interfaces in\naccordance with §195.581(a), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,\nSubsection 10.7 Atmospheric Corrosion 195.569 did not require cleaning and coating the pipe at\nsoil-to-air interfaces that are exposed to the atmosphere.\nPursuant to §195.581(a), an operator must clean and coat each pipeline or portion of pipeline that\nis exposed to the atmosphere, except pipelines under §195.581(c). Section 195.581(c) provides\nexceptions to clean and coat each pipeline or portion of pipeline exposed to the atmosphere, which\ndoes not include pipe at soil-to-air interfaces. Accordingly, an operator must clean and coat the\npipe at soil-to-air interfaces when exposed to the atmosphere.\nSubsection 10.7 Atmospheric Corrosion 195.569, on page 1 of 12, states: “An operator need not\ncomply with this paragraph if the operator can demonstrate by test, investigation, or experience in\nthe area of application, that a corrosive atmosphere does not exist.” The procedures did not require\ncleaning and coating pipe at soil-to-air interfaces when exposed to the atmosphere.\nThus, the procedures were inadequate for protecting the pipe at soil-to-air interfaces in accordance\nwith §195.581(a).\n16. §195.402 Procedural manual for operations, maintenance, and emergencies.\n120176002M_Notice of Amendment_06082017_text Page 11 of 28\n\n\n\nCPF 1-2017-6002M\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for monitoring atmospheric corrosion control in\naccordance with §195.583(b), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,\nSubsection 10.7 Atmospheric Corrosion 195.569 did not include instructions for performing\ninspections of aboveground facilities at the specific areas described in §195.583(b).\nPursuant to §195.583(b), an operator must give particular attention to pipe at soil-to-air interfaces,\nunder thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck\npenetrations, and in spans during inspections.\nSubsection 10.7 Atmospheric Corrosion 195.569, on page 8 of 12, states, “at interval not exceeding\n3 years, reevaluate each pipeline that is exposed to the atmosphere and take remedial action\nwhenever necessary to maintain protection against atmospheric corrosion.” Subsection 10.7\nAtmospheric Corrosion 195.569 also states to “[v]isually inspect the condition of the coating [and\nthat if] coating is disbonded, remove disbonded coating and inspected using the steps for uncoated\npipe below.” The procedures did not describe how to give particular attention to pipe at soil-to-air\ninterfaces and pipe at pipe supports.\nTherefore, the procedures were inadequate for monitoring atmospheric corrosion control in\naccordance with §195.583(b).\n17. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\n120176002M_Notice of Amendment_06082017_text Page 12 of 28\n\n\n\nCPF 1-2017-6002M\nUEO’s manual had inadequate procedures for providing enough looping or slack so backfilling\nwill not unduly stress or break the lead and the lead will otherwise remain mechanically secure\nand electrically conductive in accordance with §195.567(b)(2), as prescribed in §195.402(c)(3).\nSpecifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.573, .567(b) did not include\nsufficient details to ensure the test leads will remain mechanically secure and electrically\nconductive following backfilling.\nSubsection 10.5 Test Leads, 195.573, .567(b), on page 7 of 12, restates the requirement in code\nsection 195.567(b)(2). The procedure did not include details about measuring and documenting\nthe pipe-to-soil reading to ensure conductivity between the wire and pipe following backfilling. In\naddition, the procedure did not include a process for backfilling to ensure that there are no\ndisturbances to the test station and wire. The procedures did not reference other sections of the\nmanual or documents for additional guidance.\nTherefore, the procedures were inadequate for providing enough looping or slack so backfilling\nwill not unduly stress or break the lead and the lead will otherwise remain mechanically secure\nand electrically conductive in accordance with §195.567(b)(2).\n18. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for preventing lead attachments from causing stress\nconcentration on pipe in accordance with §195.567(b)(3), as prescribed in §195.402(c)(3).\nSpecifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.573, .567(b) did not include\nsufficient guidance for installing test leads.\nSubsection 10.5 Test Leads, 195.573, .567(b) on page 7 of 12, restates the requirement in code\nsection 195.567(b)(3). The procedure did not provide details about the method used to attach the\ntest leads such as thermite welding, solder connection, and/or mechanical connection. The\nprocedure did not reference another section of the manual or documents for additional guidance.\nThus, the procedures were inadequate for preventing lead attachments from causing stress\nconcentration on pipe in accordance with §195.567(b)(3).\n19. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\n120176002M_Notice of Amendment_06082017_text Page 13 of 28\n\n\n\nCPF 1-2017-6002M\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for maintaining test lead in a condition that enables\nelectrical measurements to determine whether cathodic protection complies with §195.571 in\naccordance with §195.567(c) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual,\nSubsection 10.5 Test Leads, 195.567(b) did not include a process or a timeframe to repair a\ndamaged or defective test lead.\nSubsection 10.5 Test Leads, 195.567(b) on page 7of 12 states: “Existing test leads will be\nmaintained so that adequate electrical measurements can be made to monitor each facility’s\ncathodic protection…”\nThe procedure did not provide details such as:\n1. Repairing the test leads.\n2. Timeframe to repair the damaged or defective test leads.\n3. Documentation of test lead repair.\nThus, the procedures were inadequate for maintaining test lead in a condition that enables electrical\nmeasurements to determine whether cathodic protection complies with §195.571 in accordance\nwith §195.567(c).\n20. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nUEO’s manual had inadequate procedures for the inspection of all external pipe coating required\nby §195.557 just prior to lowering the pipe into the ditch or submerging the pipe in accordance\n120176002M_Notice of Amendment_06082017_text Page 14 of 28\n\n\n\nCPF 1-2017-6002M\nwith §195.561(a) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection\n10.2 External Corrosion 195.573 did not include a detailed process for inspecting the external pipe\ncoating.\nSubsection 10.2 External Corrosion 195.573, on page 3 of 12, states that “[i]f coated pipe is\ninstalled by boring, driving, or other similar method, precautions must be taken to minimize\ndamage to the coating during installation and inspected prior to lowering the pipe in the ditch or\nsubmerging the pipe.”\nThe procedure did not provide details such as:\n1. Method for coating inspection such as visual and electrical testing (holiday\ndetector/jeeping).\n2. Inspection and calibration of equipment used for coating inspection, if any.\nThe procedures did not reference other sections of the manual or documents (manufacturer's\nspecifications) for additiona","truncated":true,"body_characters":77098}