PAULSBORO NATURAL GAS PIPELINE COMPANY, LLC — Notice of Amendment

party submissionOfficial PDF12021001NOA_Operator Response to Notice_02052021_(20-171837).pdf#

12021001NOA_Notice of Amendment_01142021_(20-171837)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY January 14, 2021 Mr. Jim Fedena Senior Vice President, Logistics Paulsboro Natural Gas Pipeline Company, LLC 4550 Wrangle Hill Road Delaware City, DE 19706 CPF 1-2021-001-NOA Dear Mr. Fedena: From February 27, 2020 to October 2, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Paulsboro Natural Gas Pipeline Company, LLC’s (Paulsboro) procedures for its pipeline system in Gloucester, New Jersey and Delaware, Pennsylvania. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Paulsboro’s plans or procedures, as described below: 1. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) … (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and Subpart M of this part. Paulsboro’s manual of written procedures was inadequate. Specifically, Paulsboro’s Gas Operations and Maintenance Manual, dated 07/2019 (O&M Procedure), failed to include details of how Paulsboro ensures appropriate odorant levels are contained in its combustible gases in accordance with § 192.625.#

12021001NOA_Notice of Amendment_01142021_(20-171837)_text.pdf, page 2CPF 1-2021-001-NOA During the inspection, the PHMSA inspector requested Paulsboro’s procedures regarding odorization. Paulsboro provided its O&M procedure, which references § 192.625(b) and (f)1 . However, the written procedure did not provide any guidance on how the operator will ensure the proper concentration of odorant. When the PHMSA inspector requested additional procedures or guidance related to odorization procedures, Paulsboro stated there was no further guidance. Therefore, Paulsboro failed to include details in its procedures of its process to ensure the proper concentration of odorant levels are contained in its combustible gases in accordance with § 192.625, as required by § 192.605(b)(1). Paulsboro must amend its O&M Procedure to include details of how it will ensure appropriate odorant levels are contained in its combustible gases in accordance with § 192.625. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Paulsboro Natural Gas Pipeline Company, LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2021-001-NOA on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office. 12021001NOA_Notice of Amendment_01142021_(20-171837)_text Page 2 of 3#

12021001NOA_Notice of Amendment_01142021_(20-171837)_text.pdf, page 3CPF 1-2021-001-NOA Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings 1 § 192.625 Odorization of gas … (b) After December 31, 1976, a combustible gas in a transmission line in a Class 3 or Class 4 location must comply with the requirements of paragraph (a) of this section unless: (1) At least 50 percent of the length of the line downstream from that location is in a Class 1 or Class 2 location; (2) The line transports gas to any of the following facilities which received gas without an odorant from that line before May 5, 1975: (i) An underground storage field; (ii) A gas processing plant; (iii) A gas dehydration plant; or (iv) An industrial plant using gas in a process where the presence of an odorant: (A) Makes the end product unfit for the purpose for which it is intended; (B) Reduces the activity of a catalyst; or (C) Reduces the percentage completion of a chemical reaction (3) In the case of a lateral line which transports gas to a distribution center, at least 50 percent of the length of that line is in a Class 1 or Class 2 location.; or (4) The combustible gas is hydrogen intended for use as a feedstock in a manufacturing process. … (f) To assure the proper concentration of odorant in accordance with this section, each operator must conduct periodic sampling of combustible gases using an instrument capable of determining the percentage of gas in air at which the odor becomes readily detectable. Operators of master meter systems may comply with this requirement by- (1) Receiving written verification from their gas source that the gas has the proper concentration of odorant; and (2) Conducting periodic "sniff" tests at the extremities of the system to confirm that the gas contains odorant. 12021001NOA_Notice of Amendment_01142021_(20-171837)_text Page 3 of 3#

12021001NOA_Closure Letter_02172021_(20-171837)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: jim.fedena@pbfenergy.com February 17, 2021 Mr. Jim Fedena Senior Vice President, Logistics Paulsboro Natural Gas Pipeline Company, LLC 4550 Wrangle Hill Road Delaware City, DE 19706 CPF 1-2021-001-NOA Dear Mr. Fedena: From February 27, 2020 to October 2, 2020, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted a pipeline safety inspection of Paulsboro Natural Gas Pipeline Company, LLC (Paulsboro). As a result of the inspection, Paulsboro was issued a Notice of Amendment on January 14, 2021, which proposed amendment of your procedures. Paulsboro submitted its amended procedures on February 5, 2021. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment 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#