# UTICA EAST OHIO MIDSTREAM LLC — Notice of Amendment - **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:** Not available - **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. Official case documents: 120176002M_Closure letter_03022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Closure%20letter_03022018.pdf 120176002M_Closure letter_03022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Closure%20letter_03022018_text.pdf 120176002M_Notice of Amendment_06082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Notice%20of%20Amendment_06082017.pdf 120176002M_Notice of Amendment_06082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Notice%20of%20Amendment_06082017_text.pdf 120176002M_Operator Response To Notice_09272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176002M/120176002M_Operator%20Response%20To%20Notice_09272017.pdf 120176002M_Closure letter_03022018_text.pdf OVERNIGHT EXPRESS DELIVERY March 2, 2018 James Roberts Vice President of Environmental, Health, and Safety Utica East Ohio Midstream LLC 600 Travis, Suite 5600 Houston, TX 77002 CPF 1-2017-6002M Dear Mr. Roberts: From August 10 – 14, 2015, a representative from the Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety pursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Utica East Ohio Midstream LLC’s (UEO) procedures in Salineville, Ohio. As a result of the inspection, UEO was issued a Notice of Amendment (NOA) on June 8, 2017, which proposed amendments of its procedures. UEO submitted its amended procedures on September 27, 2017. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in the NOA have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 120176002M_Notice of Amendment_06082017_text.pdf NOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY June 8, 2017 James Roberts Vice President of Environmental, Health, and Safety Utica East Ohio Midstream LLC 600 Travis, Suite 5600 Houston, TX 77002 CPF 1-2017-6002M Dear Mr. Roberts: From August 10 to 14, 2015, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected certain procedures in Utica East Ohio Midstream LLC’s (UEO) Momentum Gas & Liquid Pipeline Integrity Management Program, Last Revision Date July 2015 (IMP) and Operation, Maintenance and Emergency Manual, Revised July 2015 (OM&E Manual) in Salineville, Ohio.1 Based on the inspection, PHMSA has identified the apparent inadequacies found within UEO’s plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. 1 UEO is a joint venture between Access Midstream Partners L.P. (Access) (Williams Partners L.P. merged with Access), M3 Midstream LLC (Momentum) and EV Energy Partners, L.P. See, William’s website, available at http://investor.williams.com/press-release/access-midstream-partners-projects/utica-east-ohio-announces-major- expansion (last accessed May 10, 2017). CPF 1-2017-6002M (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for reviewing the manual at intervals not exceeding 15 months, but at least once each calendar year in accordance with §195.402(a) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Section 2 – Plan Review did not include a clear, detailed process for reviewing the manual and documenting recommendations within the required interval. Subsection 2.1 Manual Review 195.402(a) on page 1 of 3 states: “This plan will be evaluated for effectiveness every year (not to exceed 15 months) by the Vice President of Operations or his designee. The review designee should utilize the latest DOT Pipeline Standard Inspection Checklist… The DOT Pipeline Standard Inspection Checklist site is: https://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/PHMSA Form 1 200 9.pdf.” 1. The “Inspection Checklist” referenced in the procedure is PHMSA standard inspection report of a gas transmission pipeline form rev. 03/23/09. This form is out-of-date and UEO had a liquid pipeline system. Therefore, the procedure did not include an applicable checklist or questionnaire to assist with determining needed changes or improvements in the manual. Moreover, the procedure did not include further instructions for reviewing the manual and determining whether changes or improvements are necessary. 2. The procedure did not provide details on documenting recommendations and justifications for changes or improvements in the manual. 3. Section 2 – Plan Review referenced Form 20.2 to document the reviews and revisions. However, the form only had one column for a date – so it is unclear when a review or a revision occurred. In addition, the form did not require the review date to be month/day/year format to demonstrate manual review completed within the required interval. Thus, the procedures were inadequate for reviewing the manual at intervals not exceeding 15 months, but at least once each calendar year in accordance with §195.402(a). 2. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: 120176002M_Notice of Amendment_06082017_text Page 2 of 28 CPF 1-2017-6002M (1) … (2) Gathering of data needed for reporting accidents under subpart B of this part in a timely and effective manner. UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual, Subsection 19.14 Telephonic Notification did not identify who is responsible for making a notice in accordance with §195.52(a).2 According to §195.52(a), at the earliest practicable moment following discovery, of a release of the hazardous liquid or carbon dioxide transported resulting in an event described in §195.50, but no later than one hour after confirmed discovery, the operator of the system must give notice, in accordance with §195.52(b) of any failure that meets the criteria therein. Section 195.52(b) requires the notice to include the information listed under that paragraph to the National Response Center (NRC). Subsection 19.4 Telephonic Notification did not state the person who is responsible for making the notice and giving the required information to the NRC. Therefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in a timely and effective manner in accordance with§195.52(a). 3. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (2) Gathering of data needed for reporting accidents under subpart B of this part in a timely and effective manner. UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual, Subsection 19.14 Telephonic Notification did not require the minimum information in the notice in accordance with §195.52(b)(6). According to §195.52(b)(6), the initial estimate of amount of product released must be included in the notice made to the National Response Center. 2 Section 195.52(a) was in effect at the time of the PHMSA’s inspection but subsequently amended, effective March 24, 2017. 82 Fed. Reg. 7999 (Jan. 23, 2017). 120176002M_Notice of Amendment_06082017_text Page 3 of 28 CPF 1-2017-6002M Subsection 19.14 Telephonic Notification required the following information: 1. 2. 3. 4. 5. 6. Name and address of the operator. Name and telephone number of the reporter. The location of the failure. The time of the failure. The fatalities and personal injuries (if any). All other significant facts known by the operator that are relevant to the cause of the failure or extent of the damages. The procedure did not include the requirement for including the initial estimate of amount of product released in the notice. Thus, the procedures were inadequate for reporting accidents under subpart B of Part 195 in a timely and effective manner in accordance with §195.52(b)(6). 4. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (2) Gathering of data needed for reporting accidents under subpart B of this part in a timely and effective manner. UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual, Subsection 19.14 Telephonic Notification did not include a written procedure for calculating a reasonable initial release estimate in accordance with §195.52(c). 5. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … 120176002M_Notice of Amendment_06082017_text Page 4 of 28 CPF 1-2017-6002M (2) Gathering of data needed for reporting accidents under subpart B of this part in a timely and effective manner. UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual, Subsection 19.14 Telephonic Notification did not include a process for revising or confirming its initial notice in accordance with §195.52(d).3 6. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (2) Gathering of data needed for reporting accidents under subpart B of this part in a timely and effective manner. UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual, Subsection 19.15 Incident Written Notification did not require accidents reports to be electronically filed as soon as practicable but not later than 30 days after discovery in accordance with §195.54(a). According to the PHMSA F 7000-1 (Instructions for Form), accident reports must be submitted online through the PHMSA Portal unless an alternate method is approved.4 Subsection 19.15 Incident Written Notification on page 12 of 16 states in part: “Submit the Department of Transportation / Office of Pipeline Safety / Transmission Incident Report (RSPA 7100.2) within 30 days after discovery of the incident to the following to the written report addresses listed below: … Liquid Report PHMSA 7000-1.1.” The procedures did not require electronic reporting. In addition, for an accident that meets the criteria in §195.50, Form PHMSA F 7000-1 must be filed as soon as practicable but not more than 30 days after discovery of the accident as described in §195.54(a). The procedure did not require reports be filed “as soon as practicable.” Therefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in 3 Section 195.52(d) was in effect at the time of the PHMSA’s inspection but subsequently amended, effective March 24, 2017. 82 Fed. Reg. 7999 (Jan. 23, 2017). 4 See, http://phmsa.dot.gov/pipeline/library/forms. 120176002M_Notice of Amendment_06082017_text Page 5 of 28 CPF 1-2017-6002M a timely and effective manner in accordance with §195.54(a). 7. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (2) Gathering of data needed for reporting accidents under subpart B of this part in a timely and effective manner. UEO’s manual had inadequate procedures for reporting accidents under subpart B of Part 195 in a timely and effective manner as prescribed in §195.402(c)(2). Specifically, the OM&E Manual, Subsection 19.15 Incident Written Notification did not require the supplemental report be filed within 30 days of receiving changes or additions to the originally reported information in accordance with §195.54(b). Subsection 19.15 Incident Written Notification on page 13 of 16, states in part: “Where additional related information is obtained after a report is submitted as listed… must make a supplement report (as soon as practicable) with clear reference by date and subject to the original report (emphasis added).” The procedure did not give specific instructions to “submit” or “file” the supplemental report online through the PHMSA Portal within the 30-day timeframe. Therefore, the procedures were inadequate for reporting accidents under subpart B of Part 195 in a timely and effective manner in accordance with §195.54(b). 8. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had procedures that did not adequately require maintaining current maps and records of all crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines in 120176002M_Notice of Amendment_06082017_text Page 6 of 28 CPF 1-2017-6002M accordance with §195.404(a)(2) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 5.4 Record Retention 195.404 did not include provisions to comply with §195.404(a)(2). In addition, Section 5- Recordkeeping did not describe the manner in which personnel must maintain records, for example hard copies, electronic files, intranet, etc. 9. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had procedures that did not adequately require maintaining current maps and records of the diameter, grade, type, and nominal wall thickness of all pipe in accordance with §195.404(a)(4) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 5.4 Record Retention 195.404 did not include provisions to comply with §195.404(a)(4). In addition, Section 5- Recordkeeping did not describe the manner in which personnel must maintain records, for example hard copies, electronic files, intranet, etc. 10. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for conducting inspections of rights-of-way (ROW) in accordance with §195.412(a), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 7.1 Pipeline Patrol 195.412 did not include guidance for ensuring mitigation measure will be taken when conditions are found along the ROW. Subsection 7.1 Pipeline Patrol 195.412 referenced Form 20.3 for documenting the ROW 120176002M_Notice of Amendment_06082017_text Page 7 of 28 CPF 1-2017-6002M inspection. Neither document gave instructions for documenting the actions taken to ensure safe operation of the pipeline when a condition is found along the ROW. In addition, Subsection 7.1 Pipeline Patrol 195.412 did not specify who must receive notification of a condition found along the ROW such as a leak or soil erosion to inform them to take the appropriate action(s). Thus, the procedures were inadequate for conducting inspections of rights-of-way (ROW) in accordance with §195.412(a). 11. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. . . (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for inspecting each mainline valve to determine that it is functioning properly in accordance with §195.420(b) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 11.1 Valve Inspection 195.420 did not contain a detailed process for inspecting and maintaining mainline valves on its pipeline system. Subsection 11.1 Valve Inspection 195.420 of the OM&E Manual did not include: 1. Guidelines on inspecting the general appearance of valves on its pipeline system, particularly, the paint and coating finish. a. The procedure states to prepare Form 20.8 if there is evidence of corrosion but there was no guidance – no coating criteria or rating to determine next appropriate action(s) i.e. to prepare Form 20.8. b. The procedures refer to Form 20.9 for documentation of valve inspection but the form did not have a place for recording the paint and coating condition. There is no connection between the Form 20.8 and Form 20.9. 2. A specified timeframe to correct deficiencies identified during valve inspection and documenting remedial actions. 3. Guidance for maintaining valves on the pipeline system that have solar panels. 4. A process for the winterization of valves and making sure valves with an indicator, clearly show the valve position. 120176002M_Notice of Amendment_06082017_text Page 8 of 28 CPF 1-2017-6002M 5. Instructions to safely inspect and maintain valves; for example, checking for vapors and gas level, removing hazards from valves before attempting an inspection or repair, and lockout/tagout practices. The procedures did not reference other sections of the manual or documents (manufacturer's specifications) for additional guidance. Thus, the procedures were inadequate for inspecting each mainline valve to determine that it is functioning properly in accordance with §195.420(b). 12. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for inspecting and testing each highly volatile liquids (HVLs) pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment in accordance with §195.428(a) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 9.8 Pressure Limiting Devices Inspection 195.428 and Forms 20.4(A) and (B) did not include details such as: 1. Recording the “as found” and “as left” settings when inspecting overpressure safety devices except Form 20.4 (B), this had a field for recording “as left” pressure. 2. Documenting calculations of capacities include the piping size and length associated with the relief device. 3. Establishing a schedule for repairing or replacing devices if capacity is not satisfactory. 4. Determining what is acceptable “as found” setting. Thus, the procedures were inadequate for inspecting and testing each HVL pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment in accordance with §195.428(a). 13. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance 120176002M_Notice of Amendment_06082017_text Page 9 of 28 CPF 1-2017-6002M and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s had procedures that did not adequately require documents that support decisions and analyses, any modifications, justifications, deviations and determination made, variances, and actions taken to implement and evaluate each element of the integrity management program listed in §195.524(f) to be maintained for the useful life of the pipeline in accordance with §195.452(l)(1)(ii) as prescribed in §195.402(c)(3). During this inspection, UEO presented Section 1 Identification of Could Affect HCAs, Table 1.1 – Record Retention of its IMP as the recordkeeping procedure for the integrity management program. Neither Table 1.1 nor the OM&E Manual included specific instructions for maintaining the records listed in §195.452(l)(1)(ii). 14. 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for requiring and verifying that supervisors maintain a thorough knowledge of that portion of the corrosion control procedures established under §195.402(c)(3) for which they are responsible for insuring compliance in accordance with §195.555 as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Section 10 Corrosion Control did not explicitly address requirements for a supervisor to maintain knowledge and insure compliance with the corrosion control procedures. Section 10 on page 1 of 12 states: “Corrosion control procedures required by this section (including those for the design, installation, operation and maintenance of cathodic protection systems), must be carried out by, or under the direction of, a person qualified in pipeline corrosion control methods. Qualification may include person certified by the National Association of Corrosion Engineers or other qualified persons identified in the Momentum Operator Qualification Program (emphasis added).” First, the procedure did not address a supervisor. The procedure addressed “qualified personnel” 120176002M_Notice of Amendment_06082017_text Page 10 of 28 CPF 1-2017-6002M which is general. Second, the procedure said, “carried out by, or under the direction of” – this statement does not seem like it is meant for a supervisor. The supervisor is responsible for insuring compliance of the corrosion control procedures. Finally, the procedure did not state the qualification requirements for a supervisor to maintain knowledge of the corrosion control procedures. The procedure said, “qualification may include persons certified by [NACE] or other qualified persons identified in the Momentum Operator Qualification Program (emphasis added).” The procedure did not ensure the supervisor would be knowledgeable and educated and/or experienced in corrosion control. Thus, the procedures were inadequate for requiring and verifying that supervisors maintain a thorough knowledge of that portion of the corrosion control procedures established under §195.402(c)(3) for which they are responsible for insuring compliance in accordance with §195.555. 15. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for the protection of pipe at soil-to-air interfaces in accordance with §195.581(a), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.7 Atmospheric Corrosion 195.569 did not require cleaning and coating the pipe at soil-to-air interfaces that are exposed to the atmosphere. Pursuant to §195.581(a), an operator must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under §195.581(c). Section 195.581(c) provides exceptions to clean and coat each pipeline or portion of pipeline exposed to the atmosphere, which does not include pipe at soil-to-air interfaces. Accordingly, an operator must clean and coat the pipe at soil-to-air interfaces when exposed to the atmosphere. Subsection 10.7 Atmospheric Corrosion 195.569, on page 1 of 12, states: “An operator need not comply with this paragraph if the operator can demonstrate by test, investigation, or experience in the area of application, that a corrosive atmosphere does not exist.” The procedures did not require cleaning and coating pipe at soil-to-air interfaces when exposed to the atmosphere. Thus, the procedures were inadequate for protecting the pipe at soil-to-air interfaces in accordance with §195.581(a). 16. §195.402 Procedural manual for operations, maintenance, and emergencies. 120176002M_Notice of Amendment_06082017_text Page 11 of 28 CPF 1-2017-6002M (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for monitoring atmospheric corrosion control in accordance with §195.583(b), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.7 Atmospheric Corrosion 195.569 did not include instructions for performing inspections of aboveground facilities at the specific areas described in §195.583(b). Pursuant to §195.583(b), an operator must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans during inspections. Subsection 10.7 Atmospheric Corrosion 195.569, on page 8 of 12, states, “at interval not exceeding 3 years, reevaluate each pipeline that is exposed to the atmosphere and take remedial action whenever necessary to maintain protection against atmospheric corrosion.” Subsection 10.7 Atmospheric Corrosion 195.569 also states to “[v]isually inspect the condition of the coating [and that if] coating is disbonded, remove disbonded coating and inspected using the steps for uncoated pipe below.” The procedures did not describe how to give particular attention to pipe at soil-to-air interfaces and pipe at pipe supports. Therefore, the procedures were inadequate for monitoring atmospheric corrosion control in accordance with §195.583(b). 17. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. 120176002M_Notice of Amendment_06082017_text Page 12 of 28 CPF 1-2017-6002M UEO’s manual had inadequate procedures for providing enough looping or slack so backfilling will not unduly stress or break the lead and the lead will otherwise remain mechanically secure and electrically conductive in accordance with §195.567(b)(2), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.573, .567(b) did not include sufficient details to ensure the test leads will remain mechanically secure and electrically conductive following backfilling. Subsection 10.5 Test Leads, 195.573, .567(b), on page 7 of 12, restates the requirement in code section 195.567(b)(2). The procedure did not include details about measuring and documenting the pipe-to-soil reading to ensure conductivity between the wire and pipe following backfilling. In addition, the procedure did not include a process for backfilling to ensure that there are no disturbances to the test station and wire. The procedures did not reference other sections of the manual or documents for additional guidance. Therefore, the procedures were inadequate for providing enough looping or slack so backfilling will not unduly stress or break the lead and the lead will otherwise remain mechanically secure and electrically conductive in accordance with §195.567(b)(2). 18. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for preventing lead attachments from causing stress concentration on pipe in accordance with §195.567(b)(3), as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.573, .567(b) did not include sufficient guidance for installing test leads. Subsection 10.5 Test Leads, 195.573, .567(b) on page 7 of 12, restates the requirement in code section 195.567(b)(3). The procedure did not provide details about the method used to attach the test leads such as thermite welding, solder connection, and/or mechanical connection. The procedure did not reference another section of the manual or documents for additional guidance. Thus, the procedures were inadequate for preventing lead attachments from causing stress concentration on pipe in accordance with §195.567(b)(3). 19. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of 120176002M_Notice of Amendment_06082017_text Page 13 of 28 CPF 1-2017-6002M written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for maintaining test lead in a condition that enables electrical measurements to determine whether cathodic protection complies with §195.571 in accordance with §195.567(c) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.5 Test Leads, 195.567(b) did not include a process or a timeframe to repair a damaged or defective test lead. Subsection 10.5 Test Leads, 195.567(b) on page 7of 12 states: “Existing test leads will be maintained so that adequate electrical measurements can be made to monitor each facility’s cathodic protection…” The procedure did not provide details such as: 1. Repairing the test leads. 2. Timeframe to repair the damaged or defective test leads. 3. Documentation of test lead repair. Thus, the procedures were inadequate for maintaining test lead in a condition that enables electrical measurements to determine whether cathodic protection complies with §195.571 in accordance with §195.567(c). 20. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies… (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) … (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. UEO’s manual had inadequate procedures for the inspection of all external pipe coating required by §195.557 just prior to lowering the pipe into the ditch or submerging the pipe in accordance 120176002M_Notice of Amendment_06082017_text Page 14 of 28 CPF 1-2017-6002M with §195.561(a) as prescribed in §195.402(c)(3). Specifically, the OM&E Manual, Subsection 10.2 External Corrosion 195.573 did not include a detailed process for inspecting the external pipe coating. Subsection 10.2 External Corrosion 195.573, on page 3 of 12, states that “[i]f coated pipe is installed by boring, driving, or other similar method, precautions must be taken to minimize damage to the coating during installation and inspected prior to lowering the pipe in the ditch or submerging the pipe.” The procedure did not provide details such as: 1. Method for coating inspection such as visual and electrical testing (holiday detector/jeeping). 2. Inspection and calibration of equipment used for coating inspection, if any. The procedures did not reference other sections of the manual or documents (manufacturer's specifications) for additiona - **truncated:** true - **body characters:** 77098