{"operation":"document","citation":"CPF 12021001NOA","title":"PAULSBORO NATURAL GAS PIPELINE COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-01-14","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021001noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021001noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021001noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021001NOA","body":"Notice of Amendment involving PAULSBORO NATURAL GAS PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(1). The case was opened on 2021-01-14 and is reported as closed as of 2021-02-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021001NOA_Closure Letter_02172021_(20-171837).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021001NOA/12021001NOA_Closure%20Letter_02172021_(20-171837).pdf\n\n12021001NOA_Closure Letter_02172021_(20-171837)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021001NOA/12021001NOA_Closure%20Letter_02172021_(20-171837)_text.pdf\n\n12021001NOA_Notice of Amendment_01142021_(20-171837).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021001NOA/12021001NOA_Notice%20of%20Amendment_01142021_(20-171837).pdf\n\n12021001NOA_Notice of Amendment_01142021_(20-171837)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021001NOA/12021001NOA_Notice%20of%20Amendment_01142021_(20-171837)_text.pdf\n\n12021001NOA_Operator Response to Notice_02052021_(20-171837).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021001NOA/12021001NOA_Operator%20Response%20to%20Notice_02052021_(20-171837).pdf\n\n12021001NOA_Notice of Amendment_01142021_(20-171837)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJanuary 14, 2021\nMr. Jim Fedena\nSenior Vice President, Logistics\nPaulsboro Natural Gas Pipeline Company, LLC\n4550 Wrangle Hill Road\nDelaware City, DE 19706\nCPF 1-2021-001-NOA\nDear Mr. Fedena:\nFrom February 27, 2020 to October 2, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected Paulsboro Natural Gas Pipeline Company, LLC’s (Paulsboro) procedures for\nits pipeline system in Gloucester, New Jersey and Delaware, Pennsylvania.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nPaulsboro’s plans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nPaulsboro’s manual of written procedures was inadequate. Specifically, Paulsboro’s Gas\nOperations and Maintenance Manual, dated 07/2019 (O&M Procedure), failed to include details\nof how Paulsboro ensures appropriate odorant levels are contained in its combustible gases in\naccordance with § 192.625.\n\n\n\nCPF 1-2021-001-NOA\nDuring the inspection, the PHMSA inspector requested Paulsboro’s procedures regarding\nodorization. Paulsboro provided its O&M procedure, which references § 192.625(b) and (f)1\n.\nHowever, the written procedure did not provide any guidance on how the operator will ensure the\nproper concentration of odorant. When the PHMSA inspector requested additional procedures or\nguidance related to odorization procedures, Paulsboro stated there was no further guidance.\nTherefore, Paulsboro failed to include details in its procedures of its process to ensure the proper\nconcentration of odorant levels are contained in its combustible gases in accordance with\n§ 192.625, as required by § 192.605(b)(1). Paulsboro must amend its O&M Procedure to include\ndetails of how it will ensure appropriate odorant levels are contained in its combustible gases in\naccordance with § 192.625.\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\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 Paulsboro Natural Gas Pipeline Company, 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 1-2021-001-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.\n12021001NOA_Notice of Amendment_01142021_(20-171837)_text Page 2 of 3\n\n\n\nCPF 1-2021-001-NOA\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 Enforcement Proceedings\n1 § 192.625 Odorization of gas\n…\n(b) After December 31, 1976, a combustible gas in a transmission line in a Class 3 or Class 4 location must comply\nwith the requirements of paragraph (a) of this section unless:\n(1) At least 50 percent of the length of the line downstream from that location is in a Class 1 or Class 2 location;\n(2) The line transports gas to any of the following facilities which received gas without an odorant from that line\nbefore May 5, 1975:\n(i) An underground storage field;\n(ii) A gas processing plant;\n(iii) A gas dehydration plant; or\n(iv) An industrial plant using gas in a process where the presence of an odorant:\n(A) Makes the end product unfit for the purpose for which it is intended;\n(B) Reduces the activity of a catalyst; or\n(C) Reduces the percentage completion of a chemical reaction\n(3) In the case of a lateral line which transports gas to a distribution center, at least 50 percent of the length of that\nline is in a Class 1 or Class 2 location.; or\n(4) The combustible gas is hydrogen intended for use as a feedstock in a manufacturing process.\n…\n(f) To assure the proper concentration of odorant in accordance with this section, each operator must conduct\nperiodic sampling of combustible gases using an instrument capable of determining the percentage of gas in air at\nwhich the odor becomes readily detectable. Operators of master meter systems may comply with this requirement\nby-\n(1) Receiving written verification from their gas source that the gas has the proper concentration of odorant; and\n(2) Conducting periodic \"sniff\" tests at the extremities of the system to confirm that the gas contains odorant.\n12021001NOA_Notice of Amendment_01142021_(20-171837)_text Page 3 of 3\n\n12021001NOA_Closure Letter_02172021_(20-171837)_text.pdf\n\nVIA ELECTRONIC MAIL TO: jim.fedena@pbfenergy.com\nFebruary 17, 2021\nMr. Jim Fedena\nSenior Vice President, Logistics\nPaulsboro Natural Gas Pipeline Company, LLC\n4550 Wrangle Hill Road\nDelaware City, DE 19706\nCPF 1-2021-001-NOA\nDear Mr. Fedena:\nFrom February 27, 2020 to October 2, 2020, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted a pipeline safety inspection of Paulsboro Natural Gas Pipeline Company, LLC\n(Paulsboro). As a result of the inspection, Paulsboro was issued a Notice of Amendment on January\n14, 2021, which proposed amendment of your procedures.\nPaulsboro submitted its amended procedures on February 5, 2021. 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","truncated":false,"body_characters":9452}