{"operation":"document","citation":"CPF 120196002M","title":"ENLINK OHIO RIVER VALLEY PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.11(b)(10), 195.11(b)(9).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120196002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120196002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120196002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120196002M","body":"Notice of Amendment involving ENLINK OHIO RIVER VALLEY PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.11(b)(10),  195.11(b)(9). The case was opened on 2019-01-08 and is reported as closed as of 2019-03-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120196002M_Closure Letter_03192019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120196002M/120196002M_Closure%20Letter_03192019.pdf\n\n120196002M_Closure Letter_03192019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120196002M/120196002M_Closure%20Letter_03192019_text.pdf\n\n120196002M_Notice of Amendment_01082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120196002M/120196002M_Notice%20of%20Amendment_01082019.pdf\n\n120196002M_Notice of Amendment_01082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120196002M/120196002M_Notice%20of%20Amendment_01082019_text.pdf\n\n120196002M_Operator Response to Notice_02272019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120196002M/120196002M_Operator%20Response%20to%20Notice_02272019.pdf\n\n120196002M_Notice of Amendment_01082019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 8, 2019\nMichael LeBlanc\nSenior Vice President - Operations\nEnLink LBU-ORV\n60995 Derrick Road\nPlaquemine, LA 70764\nCPF 1-2019-6002M\nDear Mr. LeBlanc:\nFrom March 20 to May 24, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected EnLink\nLBU-ORV’s (EnLink) procedures for operation and maintenance of its crude oil pipeline system\nin the vicinity of Nashport, Ohio.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEnLink’s plans or procedures, as described below:\n1. § 195.11 What is a regulated rural gathering line and what requirements apply?\n(b) Safety requirements. Each operator must prepare, follow, and maintain written\nprocedures to carry out the requirements of this section. Except for the\nrequirements in paragraphs (b)(2), (b)(3), (b)(9) and (b)(10) of this section, the\nsafety requirements apply to all materials of construction.\n(9) For steel pipelines, comply with subpart H of this part, except corrosion control\nis not required for pipelines existing on July 3, 2008 before July 3, 2011.\nEnLink’s procedures for complying with Subpart H of Part 195 were inadequate. Specifically,\nEnLink’s procedures failed to include directions to personnel for examination of the interior\nsurface of pipe when the pipe is exposed and cut out, and for documentation of the results of the\ninspections.\n\n\n\nCPF 1-2019-6002M\nDuring the inspection, EnLink’s procedures and record form for internal pipe surface examinations\nwere reviewed. The EnLink form for examination of exposed pipe reviewed during the inspection\ndid not have any questions or checkboxes to document the presence or severity of internal\ncorrosion. However, several instances of an examination of a pipe's internal surface were added as\ncomments on the Examination of Exposed Pipe Form, the form which was used to document the\nexternal examination of the pipe.\nDuring the verbal exit interview on May 24, 2018, the PHMSA inspector and EnLink personnel\ndiscussed a form for comprehensively documenting bell hole inspections, which included internal\npipe surface examinations.\nEnLink subsequently provided a blank copy of this Excel form for review. Although current\nrecords do not reflect the use of this form, the form could be used prospectively to document bell\nhole inspections. However, the Hazardous Liquid Pipeline O&M Manual does not direct\npersonnel to specifically use this form.\nTherefore, EnLink’s procedures for complying with Subpart H of Part 195 were inadequate.\n2. § 195.11 What is a regulated rural gathering line and what requirements apply?\n(b) Safety requirements. Each operator must prepare, follow, and maintain written\nprocedures to carry out the requirements of this section. Except for the\nrequirements in paragraphs (b)(2), (b)(3), (b)(9) and (b)(10) of this section, the\nsafety requirements apply to all materials of construction.\n(9) For steel pipelines, comply with subpart H of this part, except corrosion control\nis not required for pipelines existing on July 3, 2008 before July 3, 2011.\nEnLink’s procedures for complying with Subpart H of Part 195 were inadequate. Specifically,\nEnLink’s procedures failed to provide any reference or guidance to evaluate the remaining strength\nof an internally corroded pipe.\nDuring the inspection, EnLink’s Hazardous Liquid Pipeline Operation and Maintenance Manual\nand Corrosion Manual were reviewed. It was found that there were no general references to the\ncommonly used or accepted methods noted in § 195.587 (B31G, R-STRENG), nor were there\nspecific references to any method utilized by EnLink’s engineering or integrity group.\nTherefore, EnLink’s procedures for complying with Subpart H of Part 195 were inadequate.\n3. § 195.11 What is a regulated rural gathering line and what requirements apply?\n(b) Safety requirements. Each operator must prepare, follow, and maintain written\nprocedures to carry out the requirements of this section. Except for the\nrequirements in paragraphs (b)(2), (b)(3), (b)(9) and (b)(10) of this section, the\nsafety requirements apply to all materials of construction.\n(10) For steel pipelines, establish and follow a comprehensive and effective program\nto continuously identify operating conditions that could contribute to internal\ncorrosion. The program must include measures to prevent and mitigate internal\ncorrosion, such as cleaning the pipeline and using inhibitors. This program must\n120196002M_Notice of Amendment_01082019_text Page 2 of 4\n\n\n\nCPF 1-2019-6002M\nbe established before transportation begins or if the pipeline exists on July 3,\n2008, before July 3, 2009.\nEnLink’s procedures for its program for internal corrosion of its regulated rural gathering line\nsystem were inadequate. Specifically, EnLink’s Hazardous Liquid Pipeline O&M Manual was\ninadequate in its description of a process to continuously identify operating conditions that would\ncontribute to internal corrosion. Additionally, EnLink’s Corrosion Manual, Section 6, Internal\nCorrosion Control did not address hazardous liquid pipeline internal corrosion in detail.\nDuring the inspection, the PHMSA inspector discussed EnLink’s operating practices to identify\nconditions which could contribute to internal corrosion. EnLink personnel described a practice of\nrunning cleaning pigs (in-line cleaning tools) through the pipeline, and the inspector requested and\nsubsequently reviewed records that documented the pigging activities. However, the Hazardous\nLiquid Pipeline O&M Manual did not provide a written description of a comprehensive program\nfor cleaning the pipeline or the use of corrosion inhibitors.\nThe detailed requirements of the Corrosion Manual addressing internal corrosion control appeared\nto be applicable to natural gas pipeline systems only.\nTherefore, EnLink’s written procedures fail to establish a comprehensive and effective program to\ncontinuously identify operating conditions that could contribute to internal corrosion.\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\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 EnLink maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\n120196002M_Notice of Amendment_01082019_text Page 3 of 4\n\n\n\nCPF 1-2019-6002M\nprocedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear\nTavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2019-6002M on each\ndocument you submit, and whenever possible provide a signed PDF copy in electronic format.\nSmaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD\naccompanied by the original paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120196002M_Notice of Amendment_01082019_text Page 4 of 4\n\n120196002M_Closure Letter_03192019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMarch 19, 2019\nMichael LeBlanc\nSenior Vice President - Operations\nEnLink LBU-ORV\n60995 Derrick Road\nPlaquemine, LA 70764\nCPF 1-2019-6002M\nDear Mr. LeBlanc:\nFrom March 20 to May 24, 2018, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of\nTitle 49 of the United States Code, inspected EnLink LBU-ORV’s (EnLink’s) procedures for\noperation and maintenance of its crude oil pipeline system in the vicinity of Nashport, Ohio.\nAs a result of the inspection, EnLink was issued a Notice of Amendment (NOA) on January 8,\n2019. On February 27, 2019, EnLink responded to the NOA and submitted documentation\nshowing it took certain actions to ensure compliance with the terms of the Notice.\nBased on our review of the documentation, it appears that the inadequacies outlined in this NOA\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":11367}