{"operation":"document","citation":"CPF 12022001NOA","title":"COLLINS PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.452(f)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022001noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022001noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022001noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022001NOA","body":"Notice of Amendment involving COLLINS PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.452(f)(3). The case was opened on 2022-02-08 and is reported as closed as of 2022-04-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022001NOA_Closure Letter_04212022_(20-190175).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022001NOA/12022001NOA_Closure%20Letter_04212022_(20-190175).pdf\n\n12022001NOA_Closure Letter_04212022_(20-190175)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022001NOA/12022001NOA_Closure%20Letter_04212022_(20-190175)_text.pdf\n\n12022001NOA_Notice of Amendment_02082022_(20-190175).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022001NOA/12022001NOA_Notice%20of%20Amendment_02082022_(20-190175).pdf\n\n12022001NOA_Notice of Amendment_02082022_(20-190175)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022001NOA/12022001NOA_Notice%20of%20Amendment_02082022_(20-190175)_text.pdf\n\n12022001NOA_Operator Response to Notice_04082022_(20-190175).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022001NOA/12022001NOA_Operator%20Response%20to%20Notice_04082022_(20-190175).pdf\n\n12022001NOA_Notice of Amendment_02082022_(20-190175)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nFebruary 8, 2022\nMr. Tom Nimbley\nPresident and Chief Executive Officer\nCollins Pipeline Co.\n1 Sylvan Way, Second Floor\nParsippany, NJ 07054\nCPF 1-2022-001-NOA\nDear Mr. Nimbley:\nFrom October 29th, 2020 - June 10th, 2021 a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nCollins Pipeline Co.’s (Collins Pipeline) procedures, records, and made observations during an\nIntegrated Inspection in Collins, MS; Chalmette, LA; and via virtual meetings.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCollins Pipeline’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.\nCollins Pipeline’s written procedures for conducting maintenance and normal operations were\ninadequate. Specifically, Collins Pipeline’s written procedures failed to identify and define ratings\nthat will be utilized on the PL-0595 Annual Physical Tank Inspection form (Form PL-0595) or\n\n\n\nCPF 1-2022-001-NOA\nsimilar form when performing inspections of in-service breakout tanks.\nDuring the inspection, PHMSA reviewed Collins Pipeline’s Form PL-0595, and its DOT Liquids\nManual, Gulf Coast, Effective December 31, 2020 (DOT Liquids Manual). Form PL-0595\nincluded multiple fields requiring the tank inspector to check and document conditions for various\naspects of the tank. Ratings that were required to be entered on the form for these fields were\nneither identified nor defined in the written procedures or on the form itself.\nTherefore, Collins failed to prepare adequate procedures regarding documenting inspections as\nrequired by § 195.402(c)(3). Collins Pipeline must revise its DOT Liquids Manual to identify and\ndefine ratings that will be utilized on its forms for documenting these inspections.\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.\nCollins Pipeline’s written procedures for maintenance and normal operations were inadequate.\nSpecifically, Collins Pipeline’s corrosion control procedures failed to contain adequate details\nrelative to taking corrective action under § 195.573(e)a\n.\nDuring the inspection, PHMSA reviewed Collins Pipeline’s DOT Compliance Manual - December\n2019 – Delaware, revised May 2020 (the Manual). Section 1.6.1 of the Manual stated,\n“Deficiencies identified during cathodic protection surveys will be corrected as soon as practical,\nbut unless due to unusual conditions and documented in writing, prior to the following cathodic\nprotection survey\". Collins Pipeline did not provide a definition of the term \"unusual conditions\".\nBy not defining the term “unusual conditions” as it pertains to correcting deficiencies identified\nduring cathodic protection surveys, the requirement to correct deficiencies prior to the following\ncathodic protection survey could be bypassed without adequate justification, and the procedural\nrequirements negated.\nTherefore, Collins failed to prepare adequate procedures pertaining to § 195.573, as required by\n§ 195.402(c)(3). Collins Pipeline must revise the Manual to clarify its requirements for “unusual\ncondition” exceptions to correcting deficiencies identified during cathodic protection surveys as\nsoon as practical, and prior to the following cathodic protection survey.\na § 195.573 What must I do to monitor external corrosion control?\n(a) …\n(e) Corrective action. You must correct any identified deficiency in corrosion control as required by § 195.401(b).\nHowever, if the deficiency involves a pipeline in an integrity management program under § 195.452, you must\ncorrect the deficiency as required by § 195.452(h).\n12022001NOA_Notice of Amendment_02082022_(20-190175)_text Page 2 of 4\n\n\n\nCPF 1-2022-001-NOA\n3. §195.452 Pipeline integrity management in high consequence areas.\n(a) …\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity\nassessments, and other maintenance and surveillance data, and\nevaluation of consequences of a failure on the high consequence area.\nAn operator must include, at minimum, each of the following elements\nin its written integrity management program:\n(1) …\n(3) An analysis that integrates all available information about the\nintegrity of the entire pipeline and the consequences of a failure (see\nparagraph (g) of this section).\nCollins Pipeline’s written integrity management procedures were inadequate. Specifically, Collins\nPipeline’s integrity management procedures failed to define ratings that were utilized on the 2018\nRisk Model (Threats) spreadsheet (Risk Model) required to analyze and integrate available\ninformation about the integrity of the entire pipeline and the consequences of a failure pursuant to\n§ 195.452(g)b\n.\nDuring the inspection, PHMSA reviewed Collin Pipeline’s Risk Model and its Pipeline Integrity\nManagement Plan; Hazardous Liquids Pipelines, dated June 30, 2020 (IM Plan). These documents\ndid not define the ratings utilized in the spreadsheet. By not defining the ratings that were entered\nin the Risk Model, Collins Pipeline’s IM Plan failed to provide the necessary basis to effectively\nanalyze and integrate its available information about the integrity of the entire pipeline and the\nconsequences of a failure.\nTherefore, Collins Pipeline failed to include adequate written integrity management procedures\nregarding performing an information analysis pursuant to § 195.452(g), as required by §\n195.452(f)(3).\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.\nb § 195.452 Pipeline integrity management in high consequence areas.\n(a) …\n(g) What is an information analysis? In periodically evaluating the integrity of each pipeline segment (see paragraph\n(j) of this section), an operator must analyze all available information about the integrity of its entire pipeline and the\nconsequences of a possible failure along the pipeline. Operators must continue to comply with the data integration\nelements specified in § 195.452(g) that were in effect on October 1, 2018, until October 1, 2022. Operators must\nbegin to integrate all the data elements specified in this section starting October 1, 2020, with all attributes\nintegrated by October 1, 2022. This analysis must:\n…\n12022001NOA_Notice of Amendment_02082022_(20-190175)_text Page 3 of 4\n\n\n\nCPF 1-2022-001-NOA\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 Collin’s Pipeline Co. maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. In correspondence concerning this matter, please refer to CPF 1-2022-001-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\naccompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12022001NOA_Notice of Amendment_02082022_(20-190175)_text Page 4 of 4\n\n12022001NOA_Closure Letter_04212022_(20-190175)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nApril 21, 2022\nMr. Tom Nimbley\nPresident and Chief Executive Officer\nCollins Pipeline Co.\n1 Sylvan Way, Second Floor\nParsippany, NJ 07054\nCPF 1-2022-001-NOA\nDear Mr. Nimbley:\nFrom October 29, 2020 to June 10, 2021, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Collins Pipeline Co’s (Collins Pipeline) procedures, records and made observations\nduring an Integrated Inspection in Collins, MS, Chalmette, LA, and via virtual meetings. As a\nresult of the inspection, Collins Pipeline was issued a Notice of Amendment on February 8, 2022,\nwhich proposed amendment of your procedures.\nCollins Pipeline submitted its amended procedures on April 8, 2022. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\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\nCc: Thomas McLane <Thomas.mclane@pbfenergy.com>","truncated":false,"body_characters":12595}