{"operation":"document","citation":"CPF 12020006NOA","title":"MARKWEST BLUESTONE ETHANE PIPELINE, L.L.C. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-08-11","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020006noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020006noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020006noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12020006NOA","body":"Notice of Amendment involving MARKWEST BLUESTONE ETHANE PIPELINE, L.L.C.. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2020-08-11 and is reported as closed as of 2020-08-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12020006NOA_Closure Letter_08272020_(20-172048).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020006NOA/12020006NOA_Closure%20Letter_08272020_(20-172048).pdf\n\n12020006NOA_Closure Letter_08272020_(20-172048)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020006NOA/12020006NOA_Closure%20Letter_08272020_(20-172048)_text.pdf\n\n12020006NOA_Notice of Amendment_08112020_(20-172048).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020006NOA/12020006NOA_Notice%20of%20Amendment_08112020_(20-172048).pdf\n\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020006NOA/12020006NOA_Notice%20of%20Amendment_08112020_(20-172048)_text.pdf\n\n12020006NOA_Operator Response to Notice_08172020_(20-172048).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020006NOA/12020006NOA_Operator%20Response%20to%20Notice_08172020_(20-172048).pdf\n\n12020006NOA_Closure Letter_08272020_(20-172048)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nAugust 27, 2020\nMr. Michael J. Hennigan\nChairman, President and Chief Executive Officer\nMPLX GP LLC\n539 South Main Street\nFindlay, Ohio 45840\nCPF 1-2020-006-NOA\nDear Mr. Hennigan:\nFrom May 13 to May 15, 2020, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nMarkWest Bluestone Ethane Pipeline LLC’s (MarkWest) procedures. As a result of the\ninspection, Markwest was issued a Notice of Amendment on August 11, 2020, which proposed\namendment of your procedures.\nMarkWest submitted its amended procedures on August 17, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCC: Mr. Gregory Floerk, Executive Vice President Gathering & Processing, Mark West\nBluestone Ethane Pipeline, LLC\n\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nAugust 11, 2020\nMr. Michael J. Hennigan\nChairman, President and Chief Executive Officer\nMPLX GP LLC\n539 South Main Street\nFindlay, Ohio 45840\nCPF 1-2020-006-NOA\nDear Mr. Hennigan:\nFrom May 13, 2020 to May 15, 2020, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected MarkWest Bluestone Ethane Pipeline LLC’s (MarkWest) procedures.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nMarkWest’s plans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following\nto provide safety during maintenance and normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in\naccordance with each of the requirements of this subpart and subpart\nH of this part.\nMarkWest’s procedures were inadequate. Specifically, MarkWest’s Operations, Maintenance,\nand Emergencies Manual, Section 37, dated 1/5/17 (Valve Inspection Procedure) failed to include\ndetails on how each valve is protected from unauthorized operation and vandalism in accordance\nwith § 195.420(c)a\n.\n\n\n\nCPF 1-2020-006-NOA\nDuring the inspection, the PHMSA inspector requested MarkWest’s procedures regarding valve\noperation and maintenance. MarkWest provided its Valve Inspection Procedure, which discusses\nvalve operation and maintenance in Section 37, Valve Inspection and Testing. The Valve\nInspection Procedure stated in part, “Valve sites shall be maintained in a secure fashion and shall\nbe secured…Use chain-and-padlock security measures to protect valves, electrical feeds, and DCS\nsystem components from tampering or damage on main line block valve stations and river crossing\nvalves, and station inlet and outlet facility valves.” However, the written procedure did not provide\nguidance on what protection is required for each valve, or state specifically how valve sites are to\nbe secured to prevent vandalism. The procedure was not clear on when the chain-and-padlock\nsecurity measures are employed as well as where they are to be located, such as on the valve site\nfence gate or on the valve stem, to prevent unauthorized operation and vandalism.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nvalve protection from unauthorized operation and vandalism, MarkWest stated there was no\nfurther guidance and that the current procedure could use some revision.\nTherefore, MarkWest failed to include details in its procedures of how each valve is protected\nfrom unauthorized operation and vandalism in accordance with § 195.420(c). MarkWest must\nrevise its Valve Inspection Procedure to clarify its requirements for protecting its valves from\nunauthorized operation and vandalism.\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following\nto provide safety during maintenance and normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in\naccordance with each of the requirements of this subpart and subpart\nH of this part.\nMarkWest’s procedures were inadequate. Specifically, MarkWest’s Operations, Maintenance,\nand Emergencies Manual, Section 8, dated 4/17/20 (Corrosion Control Procedures) failed to\ninclude details of how MarkWest inspects and evaluates pipe exposed to the atmosphere for\natmospheric corrosion in accordance with § 195.583b\n.\nDuring the inspection, the PHMSA inspector requested MarkWest’s procedures regarding\natmospheric corrosion inspections. MarkWest provided its Corrosion Control Procedures, which\ndiscusses atmospheric corrosion control in Subsections 8.34 and 8.35. However, the written\nprocedures did not provide any guidance on how the atmospheric corrosion control inspection is\nconducted and what criteria is applied when evaluating pipe and coating or jacketing condition.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nthe evaluation method used for atmospheric corrosion, MarkWest stated there was no further\nguidance.\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text Page 2 of 6\n\n\n\nCPF 1-2020-006-NOA\nTherefore, MarkWest failed to include details in its procedures of its process to inspect and\nevaluate atmospheric corrosion on its pipelines in accordance with § 195.583, as required by\n§ 195.402(c)(3). MarkWest must revise its Corrosion Control Procedures to include details for\nperforming atmospheric corrosion inspections and evaluating atmospheric corrosion on its\npipelines.\n3. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following\nto provide safety during maintenance and normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in\naccordance with each of the requirements of this subpart and subpart\nH of this part.\nMarkWest’s procedures were inadequate. Specifically, MarkWest’s Operations, Maintenance,\nand Emergencies Manual, dated 9/19/19 (Procedures) failed to include adequate details regarding\nmaintaining maps and records of its pipeline system in accordance with § 195.404(a)(1)c\n.\nDuring the inspection, the PHMSA inspector requested MarkWest’s procedures regarding\noperation and maintenance maps and records. MarkWest provided its Procedures, which discusses\noperation and maintenance records in Section ii - Introduction. The Procedures stated, “The\nmanual, records, and maps will be kept on file, for the prescribed periods of time, on the MarkWest\nCompany Intranet...” However, the written procedure did not include a detailed process for\nmaintaining current maps and records of its pipeline systems in accordance with § 195.404(a)(1).\nThe Procedures did not provide guidance on what information must be contained in maps or\nrecords, nor define where that information would be recorded. For example, the Procedures failed\nto direct personnel to include breakout tanks, pump stations, and pipeline valves on its maps or\nrecords.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nhow MarkWest maintains maps and records in accordance with § 195.404(a)(1), MarkWest stated\nthere was no further guidance and that the current procedure could use some revision.\nTherefore, MarkWest failed to include adequate details regarding maintaining maps and records\nof its pipeline system in accordance with § 195.404(a)(1). MarkWest must revise its Procedures\nto address this deficiency.\n4. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following\nto provide safety during maintenance and normal operations:\n(1) …\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text Page 3 of 6\n\n\n\nCPF 1-2020-006-NOA\n(3) Operating, maintaining, and repairing the pipeline system in\naccordance with each of the requirements of this subpart and subpart\nH of this part.\nMarkWest’s procedures were inadequate. Specifically, MarkWest’s Operations, Maintenance,\nand Emergencies Manual, Section 8, dated 4/17/20 (Corrosion Control Procedures) failed to\nprovide adequate details on how to remediate corrosion control deficiencies in accordance with\n§ 195.573(e)d\n.\nDuring the inspection, the PHMSA inspector requested MarkWest’s procedures regarding\ncorrecting corrosion control deficiencies. MarkWest provided its Corrosion Control Procedures,\nwhich discussed remedial actions for corrosion control deficiencies in Subsection 8.2 Definitions\nand Subsection 8.28 External Corrosion Inspections. Subsection 8.2 stated in part, “Damages\nFound-any damage to Rectifiers, Test Stations, Cad Welds, etc., shall be repaired as soon as\npracticable and documented on Form 118- Remedial Action Plan and/or a work order…”\nHowever, the written procedure did not provide adequate details to remediate corrosion control\ndeficiencies within a required timeframe. For example, the procedure failed to address methods\nand timeframes for correcting inadequate pipe-to-soil cathodic protection potential readings,\ninstead stating in Subsection 8.28 that “…corrective steps shall be taken”.\nWhen the PHMSA inspector requested if there were additional procedures or guidance, MarkWest\nstated there was no further guidance.\nTherefore, MarkWest failed to include adequate details regarding correction of corrosion control\ndeficiencies in accordance with § 195.573(e). MarkWest must revise its Corrosion Control\nProcedures to address methods and timeframes for correcting corrosion control deficiencies.\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 Enforcement\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 30 days of\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text Page 4 of 6\n\n\n\nCPF 1-2020-006-NOA\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 MarkWest Bluestone Ethane Pipeline, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough,\nDirector, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628.\nPlease refer to CPF 1-2020-006-NOA on each document you submit, and whenever possible\nprovide a signed PDF copy in electronic format. Smaller files may be emailed to\nrobert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the\noriginal 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\nCC: Mr. Gregory Floerk, Executive Vice President Gathering & Processing, MarkWest\nBluestone Ethane Pipeline, LLC\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\na Section 195.420(c) - Each operator shall provide protection for each valve from unauthorized operation and from\nvandalism.\nb Section 195.583 - What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of\natmospheric corrosion, as follows:\nIf the pipeline is located:\nThen the frequency of inspection is:\nOnshore\nAt least once every 3 calendar years, but with intervals not exceeding 39\nmonths\nOffshore\nAt least once each calendar year, but with intervals not exceeding 15\nmonths\n(b) During inspections you must give particular attention to pipe at soil-to-air interfaces, under thermal insulation,\nunder disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water.\n(c) If you find atmospheric corrosion during an inspection, you must provide protection against the corrosion as\nrequired by § 195.581.\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text Page 5 of 6\n\n\n\nCPF 1-2020-006-NOA\nc Section 195.404(a) - Each operator shall maintain current maps and records of its pipeline systems that include at\nleast the following information;\n(1) Location and identification of the following pipeline facilities;\n(i) Breakout tanks;\n(ii) Pump stations;\n(iii) Scraper and sphere facilities;\n(iv) Pipeline valves;\n(v) Facilities to which §195.402(c)(9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which §195.428 applies.\nd Section 195.573(e) Corrective action. You must correct any identified deficiency in corrosion control as required\nby §195.401(b). However, if the deficiency involves a pipeline in an integrity management program under §195.452,\nyou must correct the deficiency as required by §195.452(h).\n12020006NOA_Notice of Amendment_08112020_(20-172048)_text Page 6 of 6","truncated":false,"body_characters":16422}