{"operation":"document","citation":"CPF 12024032NOA","title":"CITGO PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-07-05","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3), 195.402(e)(2), 195.402(e)(5), 195.402(e)(7).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024032noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024032noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024032noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024032NOA","body":"Notice of Amendment involving CITGO PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  195.402(e)(2),  195.402(e)(5),  195.402(e)(7). The case was opened on 2024-07-05 and is reported as closed as of 2025-03-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024032NOA_Closure Letter_03262025_(23-263975).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Closure%20Letter_03262025_(23-263975).pdf\n\n12024032NOA_Closure Letter_03262025_(23-263975)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Closure%20Letter_03262025_(23-263975)_text.pdf\n\n12024032NOA_Notice of Amendment_07052024_(23-263975).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Notice%20of%20Amendment_07052024_(23-263975).pdf\n\n12024032NOA_Notice of Amendment_07052024_(23-263975)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Notice%20of%20Amendment_07052024_(23-263975)_text.pdf\n\n12024032NOA_Operator Response to Notice and Request Time Extension_08042024_(23-263975).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Operator%20Response%20to%20Notice%20and%20Request%20Time%20Extension_08042024_(23-263975).pdf\n\n12024032NOA_Notice of Amendment_07052024_(23-263975)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Cjorda@citgo.com\nJuly 5, 2024\nMr. Carlos Jorda\nPresident and Chief Executive Officer\nCitgo Pipeline Co\n1289 Eldridge Parkway\nHouston, Texas 77077\nCPF 1-2024-032-NOA\nDear Mr. Jorda:\nOn March 27, 2023 through November 7, 2023, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) conducted an integrated inspection of Citgo Pipeline Company, Citgo Petroleum\nCorporation Terminals and Citgo Products Pipeline Company (Citgo) procedures in Everglades,\nFlorida, Niles, Michigan, Linden, New Jersey, Toledo, Ohio and Sour Lake, Texas.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nCitgo’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline system a manual of written procedures for conducting normal\noperations and maintenance activities and handling abnormal\noperations and emergencies. This manual shall be reviewed at intervals\nnot exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a\npipeline system commence, and appropriate parts shall be kept at\nlocations where operations and maintenance activities are conducted.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\n\n\n\nFacility Response Plans failed to state the manuals shall be reviewed at intervals not exceeding 15\nmonths, but at least once each calendar year, and appropriate changes made as necessary to insure\nthat the manual is effective, in accordance with § 195.402(a).\nDuring the inspection, PHMSA requested Citgo’s procedures regarding annual reviews of its\nemergency manual pursuant to § 195.402(a). Citgo provided, Gulf Coast Response Zone – FRP,\ndated 02/23/23, Linden FRP, dated 02/23/23, Niles FRP, dated 03/09/23, Port Everglades FRP,\ndated 02/23/23 and Toledo FRP, dated 02/23/23 (FRP). Citgo also identified that the emergency\nmanual required by § 195.402(e) is the FRPs.\nThe FRP’s stated in part that “…this plan will be reviewed annually and modified to address new\nor different operating conditions or information included in the Plan.”\nHowever, the FRPs failed to state that the manuals be reviewed at the proper interval of at least\nonce each calendar year, and not to exceed 15 months.\nTherefore, Citgo’s procedures failed to state the manual shall be reviewed at intervals not\nexceeding 15 months but at least once each calendar year, in accordance with § 195.402(a). Citgo\nmust revise its procedures to address this requirement.\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline system a manual of written procedures for conducting normal\noperations and maintenance activities and handling abnormal\noperations and emergencies. This manual shall be reviewed at intervals\nnot exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a\npipeline system commence, and appropriate parts shall be kept at\nlocations where operations and maintenance activities are conducted.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo's\nOM Manual Section Q – Abandonment of Facilities, dated 10/19/00 (OM - Section Q) failed to\nstate adequate details for reporting abandonment or deactivation of facilities, in accordance with §\n195.59.\nSection 195.59 states:\nThe preferred method to submit data on pipeline facilities abandoned after October\n10, 2000 is to the National Pipeline Mapping System (NPMS) in accordance with\nthe NPMS “Standards for Pipeline and Liquefied Natural Gas Operator\nSubmissions.” To obtain a copy of the NPMS Standards, please refer to the NPMS\nhomepage at http://www.npms.phmsa.dot.gov or contact the NPMS National\nRepository at 703-317-3073. A digital data format is preferred, but hard copy\nsubmissions are acceptable if they comply with the NPMS Standards. In addition to\nthe NPMS-required attributes, operators must submit the date of abandonment,\ndiameter, method of abandonment, and certification that, to the best of the operator's\n\n\n\nknowledge, all of the reasonably available information requested was provided and,\nto the best of the operator's knowledge, the abandonment was completed in\naccordance with applicable laws. Refer to the NPMS Standards for details in\npreparing your data for submission. The NPMS Standards also include details of\nhow to submit data. Alternatively, operators may submit reports by mail, fax or e-\nmail to the Office of Pipeline Safety, Pipeline and Hazardous Materials Safety\nAdministration, U.S. Department of Transportation, Information Resources\nManager, PHP-10, 1200 New Jersey Avenue, SE., Washington, DC 20590-0001; fax\n(202) 366-4566; e-mail, “InformationResourcesManager@phmsa.@phmsa.dot.gov.\nDuring the inspection, PHMSA requested procedures related to abandonment. Citgo provided OM\n– Section Q. Section Q stated in part: Alternatively, operators may submit reports by mail, fax or\ne-mail to the Information Officer, Research and Special Programs Administration (RSPA),\nDepartment of Transportation, Room 7128, 400 Seventh Street, SW, Washington DC 20590; FAX\n(202) 366-4566; E-MAIL, roger.little@rspa.dot.gov. The information in the report must contain\nall reasonably available information related to the facility, including information in the possession\nof a third party.\nThe OM – Section Q, however, failed to state the correct agency name, address and email contact\nto submit the abandonment reports to.\nTherefore, Citgo procedures failed to state adequate details for reporting abandonment or\ndeactivation of facilities, in accordance with § 195.59. Citgo must revise its procedures to address\nthis requirement.\n3. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline system a manual of written procedures for conducting normal\noperations and maintenance activities and handling abnormal\noperations and emergencies. This manual shall be reviewed at intervals\nnot exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a\npipeline system commence, and appropriate parts shall be kept at\nlocations where operations and maintenance activities are conducted.\nCitgo's procedures for safety-related condition reports were inadequate. Specifically, Citgo's OM\nManual Section G – Accident Reporting, dated 09/27/22 (OM - Section G) failed to include\ninstructions enabling personnel who perform operation and maintenance (O&M) activities to\nrecognize conditions that potentially may be safety-related conditions (SRCs) that are subject to\nthe reporting requirements of § 195.55.\nDuring the inspection, PHMSA requested Citgo's procedure regarding recognizing safety-related\nconditions. Citgo provided the OM - Section G. Section G, page G-22 reiterated the list of SRCs\nfound in § 195.55(a). When PHMSA asked Citgo where the process details were related to\nproviding instructions to enable personnel who perform O&M activities to recognize conditions\n\n\n\nthat may be SRCs, Citgo was unable to provide a relevant section of the O&M which indicated\ncompliance with this requirement. The OM – Section G lacked any guidance, criteria or examples\nthat would allow Citgo personnel to differentiate between what is and what is not a potential safety-\nrelated condition, nor did it reference any other relevant procedures or training that provide O&M\npersonnel the required instruction.\nTherefore, Citgo failed to include instructions in its written procedures for personnel who perform\noperation and maintenance activities to recognize conditions that potentially may be safety-related\nconditions subject to the reporting requirements of § 195.55 in accordance with § 195.402(f).\nCitgo must revise its procedures to address this requirement.\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) …\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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nIntegrity Management Program for Hazardous Liquids Pipelines Pipeline Integrity Assessment,\ndated 10/01/22 (LIMP-03) failed to contain an analysis that integrates all available information\nabout the integrity of the entire pipeline(s) and the consequence of a failure, per the requirements\nof § 195.452(f)(3).\nSection § 195.452(f)(3) stated in part:\n…An operator must include, at minimum, each of the following elements in its\nwritten integrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section)\nDuring the inspection, PHMSA requested Citgo’s procedures regarding the process for evaluating\nin-line inspection results and data integration. Citgo provided the LIMP-03. The LIMP-03 –\nSection 5.14.1 stated in part that the integrity engineer will ensure that all available data that is\nrelevant to the assessment will be integrated and used in information analysis. ILI vendor data,\ndata stored in GIS/PODS, PCS-CPDM and MS Access databases will be primary data sources.\nHowever, the LIMP-03 failed to describe the process and details behind how and when Citgo\nconducts this analysis, as well as in what method Citgo integrates this data amongst their programs.\nWhen PHMSA asked Citgo where this information was documented Citgo discussed that their\nprocess is not spelled out indicating instructions or further guidance.\nTherefore, Citgo’s procedures failed to contain an analysis that integrates all available information\n\n\n\nabout the integrity of the entire pipeline(s) and the consequence of a failure, in accordance with §\n195.452(f)(3). Citgo must revise its procedures to address this requirement.\n5. § 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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nIntegrity Management Program for Hazardous Liquids Pipelines Pipeline Integrity Assessment,\ndated 10/01/22 (LIMP-03) and Integrity Management Program for Hazardous Liquids Pipelines-\nPipeline Remediation, dated 05/01/21 (LIMP-04) failed to prioritize repairs for its non-high\nconsequence areas (HCA), per the requirements of § 195.401(b)(3).\nSection 195.401(b) states in part:\n(1) Non-Integrity management repairs. Whenever an operator discovers any\ncondition that could adversely affect the safe operation of its pipeline system, it\nmust correct the condition within a reasonable time. However, if the condition is of\nsuch a nature that it presents an immediate hazard to persons or property, the\noperator may not operate the affected part of the system until it has corrected the\nunsafe condition.\n…\n(3) Prioritizing repairs: An operator must consider the risk to people, property, and\nthe environment in prioritizing the correction of any conditions referenced in\nparagraphs (b)(1) and (2) of this section.\nDuring the inspection, PHMSA requested Citgo’s procedures regarding the process for pipeline\ndefect repairs in non-HCA areas. Citgo provided the LIMP-03 and LIMP-04. The LIMP-03\nprovided for ‘Immediate Hazard Conditions’ on non-HCA segments for certain criteria described\nin Section 5.8.6. Section 5.8.7 stated:\nSpecific conditions for evaluation and investigation--Citgo may select these\nfollowing conditions on HCA and non-HCA segments for further validation and\ninvestigation, as determined by the integrity engineer.\n- Any metal loss greater than 50%\n- Any dent near foreign line crossing\n- Verification of external corrosion anomaly\n- Verification of internal corrosion anomaly\n- Verification based on remaining life calculations\n- Any 49 CFR 195.452(h)(4) condition in non-HCA\n\n\n\nHowever, the LIMP-03 failed to describe any prioritization of repairs for non-HCA segments\noutside of Immediate Hazard Conditions. When PHMSA asked Citgo where this information was\ndocumented, Citgo this is done on a case-by-case basis and there is no set schedule for repairs.\nTherefore, Citgo’s procedures failed to contain a process for prioritizing its non-HCA segment\nrepairs, in accordance with § 195.401(b)(3). Citgo must revise its procedures to address this\nrequirement.\n6. § 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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nIntegrity Management Program for Hazardous Liquids Pipelines – Leak Detection Capabilities\nEvaluation, dated 07/01/20 (LIMP-11) failed to require a leak detection evaluation on its pipeline\nsystems, per the requirements of § 195.452(i)(3).\nSection § 195.452(i)(3) stated in part:\n(i) What preventive and mitigative measures must an operator take to protect the high\nconsequence area\n(3) Leak detection. An operator must have a means to detect leaks on its pipeline\nsystem. An operator must evaluate the capability of its leak detection means and modify,\nas necessary, to protect the high consequence area. An operator's evaluation must, at\nleast, consider, the following factors - length and size of the pipeline, type of product\ncarried, the pipeline's proximity to the high consequence area, the swiftness of leak\ndetection, location of nearest response personnel, leak history, and risk assessment\nresults.\nDuring the inspection, PHMSA requested Citgo’s procedures regarding leak detection system\nevaluations. Citgo provided the LIMP-11. The LIMP-11 – Section 5.3 stated in part: Citgo\nconducts leak detection evaluations on every pipeline system or reviews the results of the previous\nleak detection evaluation during or after P&M measure evaluation meetings which usually occur\nevery 5 years after the completion of a risk assessment.\nHowever, LIMP-11 failed to include any set requirement for Citgo to conduct a leak detection\nevaluation at a specified interval. When PHMSA asked Citgo where this information was\ndocumented, Citgo stated there is no set timeframe for a leak detection evaluation but it is usually\nafter an integrity assessment.\nTherefore, Citgo’s procedures failed to require a leak detection evaluation on its pipeline systems,\n\n\n\nper the requirements of § 195.452(i)(3). Citgo must revise its procedures to clarify when it\nperforms leak detection evaluations pursuant to § 195.452(i)(3).\n7. § 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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nControl Room Management Plan – Alarm Management Plan, dated 01/01/23 (CRM-06) and Citgo\nPipeline Operations Manual – Field and Control Center, dated 09/26/22 (OM Section T) failed to\ndetail how its computational pipeline monitoring (CPM) leak detection systems comply with API\nRP 1130 in operating, maintaining, testing, record keeping and dispatcher training for its systems,\nin accordance with § 195.444(c).\nSection § 195.444(c) stated in part:\n(c) CPM leak detection systems. Each computational pipeline monitoring (CPM)\nleak detection system installed on a hazardous liquid pipeline must comply with API\nRP 1130 (incorporated by reference, see § 195.3) in operating, maintaining, testing,\nrecord keeping, and dispatcher training of the system.\nDuring the inspection, PHMSA requested Citgo’s procedures regarding CPM systems. Citgo\nprovided the CRM-06 and OM Section T. The O&M Section T stated in part that Citgo maintains\na CPM system that aids in the detection of pipeline leaks. It also stated that this system complies\nwith API 1130 regarding operating, maintaining, testing, recordkeeping and dispatcher training.\nHowever, OM Section T failed to include details on how Citgo’s CPM systems meet these\nrequirements. When PHMSA asked Citgo which pipeline or system this procedure applies to as\nwell as how the system(s) meets the operating, maintaining and testing requirements of API 1130,\nCitgo stated that the leak detection systems vary across the pipeline terminals but there is no further\nguidance on this process that is documented.\nTherefore, Citgo’s procedures failed to detail how its CPM leak detection systems comply with\nAPI RP 1130 in operating, maintaining, testing, record keeping and dispatcher training for its\nsystems, in accordance with § 195.444(c). Citgo must revise its procedures to address this\nrequirement.\n8. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n\n\n\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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nFacility Response Plans failed include details for a notification of potential rupture, in accordance\nwith § 195.417(a).\nSection § 195.417(a) stated in part:\nAs used in this part, a notification of potential rupture means the notification to, or\nobservation by, an operator (e.g., by or to its controller(s) in a control room, field\npersonnel, nearby pipeline or utility personnel, the public, local responders, or public\nauthorities) of one or more of the below indicia of a potential unintentional or\nuncontrolled release of a large volume of hazardous liquids from a pipeline:\nDuring the inspection, PHMSA requested the procedures regarding notifications of potential\nruptures. Citgo provided, Gulf Coast Response Zone – FRP, dated 02/23/23, Linden FRP, dated\n02/23/23, Niles FRP, dated 03/09/23, Port Everglades FRP, dated 02/23/23 and Toledo FRP,\ndated 02/23/23 (FRP). Citgo also identified that the emergency manual required by § 195.402(e)\nis the FRPs.\nThe FRPs failed to include details covering the notification process of a potential rupture. The\nFRPs also failed to define an unanticipated or unexplained pressure loss scenario. When PHMSA\nasked for clarification on where these processes are located, Citgo stated that all notifications are\non premises and that they follow FRP Section 2.1. The FRP Section 2.1, however, did not indicate\nany details regarding a notification process for the § 195.417(a) requirements.\nTherefore, Citgo’s procedures failed to include details for a notification of potential rupture, in\naccordance with § 195.417(a). Citgo must revise its procedures to address this requirement.\n9. § 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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nOM Manual Section J – Inspection and Maintenance, dated 09/23/22 (OM - Section J) failed to\n\n\n\nprovide adequate details in its procedures for overpressure safety device inspection and testing in\naccordance with § 195.428(a).\nDuring the inspection, PHMSA requested Citgo’s procedures regarding the § 195.428\nrequirements. Citgo provided the OM - Section J. Section J-28 stated in part, Inspect and test\neach pressure limiting device, relief valve, pressure regulator, or other item of pressure control\nequipment. Determine that the device is: Functioning properly, in good mechanical condition,\nadequate in capacity and reliability for the service in which it is used, set to function at the\ncorrect pressure, properly installed and protected from anything that might prevent proper\noperation…and document each inspection of an overpressure safety device on the Check List for\nSafety Device Inspection, CPL-31 or equivalent form…\nThe OM – Section J failed to provide sufficient guidance on conducting and documenting pressure\nrelief valve inspections, such as:\n1. 2. 3. 4. What are the criteria for determining “satisfactory” and “unsatisfactory.”\nHow is “operational”, “mechanical” and “general condition” to be evaluated.\nWhen is a device to be evaluated for an initial test or re-calibration.\nWhat criteria are used to determine an acceptable “as-found” and “as-left” relief\npressure.\n5. What actions must be taken if the relief valve pressure does not meet the criteria.\nTherefore, Citgo failed to provide adequate details in its procedures for overpressure safety device\ninspection and testing in accordance with § 195.428(a). Citgo must revise its procedures to address\nthis requirement.\n10. § 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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo's\nOM Manual Section J – Inspection and Maintenance, dated 09/23/22 (OM - Section J), failed to\nprovide sufficient guidance for protecting pipeline systems against ignitions arising out of static\nelectricity, lightning, and stray currents during operation and maintenance activities involving\naboveground breakout tanks in accordance with API RP 2003, per the requirement of § 195.405(a).\nSection 195.405(a) states:\nAfter October 2, 2000, protection provided against ignitions arising out of static\nelectricity, lightning, and stray currents during operation and maintenance activities\ninvolving aboveground breakout tanks must be in accordance with API RP 2003\n\n\n\n(incorporated by reference, see §195.3), unless the operator notes in the procedural\nmanual (§ 195.402(c)) why compliance with all or certain provisions of API RP 2003\nis not necessary for the safety of a particular breakout tank.\nDuring the inspection, PHMSA requested Citgo's procedures regarding the §195.405(a)\nrequirements. Citgo provided the OM – Section J and TPL-EPCC-TK100 – New tanks, bottoms,\nleak protection and ignition protection, dated 04/01/22 (TK100). The OM – Section J, page J-21\nstated in part: after October 2, 2000, protection provided against ignitions arising out of static\nelectricity, lightning, and stray currents during operation and maintenance activities involving\naboveground breakout tanks must be in accordance with API Recommended Practice 2003, unless\nCitgo notes in this procedure manual why compliance with all or certain provisions of API RP\n2003 is not necessary for the safety of a particular tank.\nOM Section J failed to indicate or reference any process or details for protection against ignitions\ninvolving aboveground breakout tanks, nor did it provide a reason why compliance with all or\ncertain provisions of API RP 2003 is not necessary for the safety of a particular breakout tank.\nTK100 was associated with new tanks and did not include any details or processes related to\nprotection against ignitions. Furthermore, the TK100 was not referenced or linked to the Citgo\nOM manual. When PHMSA asked for additional procedures as well as reasoning why TK100 was\nnot referenced in the OM manual, Citgo was unable to provide a response.\nTherefore, Citgo procedures failed to include provisions for protecting against ignitions arising out\nof static electricity, lightning, and stray currents during operation and maintenance activities\ninvolving aboveground breakout tanks in accordance with API RP 2003, per the requirement of §\n195.405(a). Citgo must revise its procedures to address this requirement.\n11. § 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.\nCitgo’s procedures for maintenance normal operations and emergencies were inadequate.\nSpecifically, Citgo's OM Manual Section A – Normal Operation and Maintenance Introduction,\ndated 04/01/21 (OM - Section A), failed to state the manuals shall be reviewed at intervals not\nexceeding 15 months, but at least once each calendar year, in accordance with § 195.402(a).\nDuring the inspection, PHMSA requested Citgo's procedures regarding the § 195.402(a)\nrequirements. Citgo provided the OM – Section A. The OM – Section A stated in part: II\nProcedure reviews will be documented on forms provided on SHAREPOINT and will be evaluated\nannually during the O&M Manual review by the respective sections' SME or document owner.\n\n\n\nThis annual (not to exceed 15 months) review will not preclude the immediate modification of any\nprocedure should circumstances warrant such a change.\nOM Section A also mentioned various other programs that Citgo maintains manuals for, including\nbut not limited to, Integrity Management Plans, Corrosion Manuals and Control Room\nManagement Plans. When PHMSA asked Citgo if these manuals and all referenced documents,\nforms and site-specific procedures were included in the required § 195.402(a) at intervals not\nexceeding 15 months but at least once each calendar year, Citgo stated that they are not, and\noperate on various intervals for review. However, per § 195.402(c) these manuals are required to\nbe a part of the manual required by § 195.402(a) and are subject to its review interval.\nPHMSA reviewed example Citgo documents such as: Integrity Management Program for\nHazardous Liquids Pipelines Integrity Assessment – TPL-EPCC-LIMP03, dated 09/23/22 (IMP),\nIntegrity Management Program for Hazardous Liquids Pipelines Pipeline Risk Assessment – TPL-\nEPCC-LIMP05, dated 09/23/22 (IMP), Incident Notification, Reporting and Investigation – HSE-\nSTD-SAF-013, dated 10/12/22 (HSE), Terminals and Pipelines – Internal Corrosion – TPL-\nEPCC-CCG12, dated 9/18/19 (IC) and Facility Response Plans (all), dated 2023 (FRP).\nThe IMP stated in part: Review cycle – 5 years.\nThe HSE stated in part: Review cycle – 3 years.\nThe IC stated in part: Review cycle – 5 years.\nThe FRP stated in part: This plan will be reviewed annually.\nTherefore, Citgo procedures failed to state the manuals shall be reviewed at intervals not exceeding\n15 months, but at least once each calendar year, in accordance with § 195.402(a). Citgo must\nrevise its procedures to address this requirement.\n12. § 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.\nCitgo’s procedures for maintenance and normal operation were inadequate. Specifically, Citgo’s\nOM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K), failed to include a\ndescription or details of its methodology for evaluating the severity of coating and atmospheric\ncorrosion deficiencies of pipe inspected pursuant to § 195.583, and for documenting these\ninspections.\nDuring the inspection, PHMSA requested Citgo’s procedure for atmospheric corrosion\ninspections. Citgo provided the OM – Section K. Citgo’s OM - Section K, page K-9 stated in part:\n\n\n\nAll onshore aboveground piping shall be inspected at least once every 3 calendar\nyears, but with intervals not exceeding 39 months (§195.583 (a))…and inspect each\nsegment of the facility. This may have to be divided up into groups such as tank\npiping, manifold piping, etc.… all atmospheric inspections shall be documented\naccording to the following: Aboveground piping/components - Atmospheric\nCoatings Inspection Report, Spans or normally exposed pipe - Span or Exposed\nPipe Inspection Form.\nWhile the OM – Section K did identify the proper frequency for inspection, it failed to include any\ndetailed procedures for evaluating the existence or severity of these coating and atmospheric\ncorrosion conditions for the purposes of requiring or prioritizing remediation. The OM – Section\nK also failed to include any process details addressing how the atmospheric corrosion inspection\nis to be documented aside from referencing the forms to be used. When PHMSA requested if there\nwere additional procedures or guidance related to atmospheric corrosion, Citgo discussed that they\ndo not document the actual conditions, rather they only document a suggested repair and\nprioritization schedule, if needed.\nTherefore, Citgo’s procedures failed to include a description or details of its methodology for\nevaluating the severity of coating and atmospheric corrosion deficiencies of pipe inspected\npursuant to § 195.583, and for documenting these inspections. Citgo must revise its procedures to\naddress this deficiency.\n13. § 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.\nCitgo’s procedures for maintenance and normal operation were inadequate. Specifically, Citgo’s\nOM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K), failed to adequately\ndetail when and how cathodic protection systems will be inspected on its breakout tanks, in\naccordance with § 195.573(d).\nDuring the inspection, PHMSA requested Citgo’s procedure for breakout tank cathodic protection.\nCitgo provided the OM – Section K. Citgo’s OM - Section K stated in part:\nCathodic protection of Aboveground Storage Tanks (AST) shall be in accordance with\nNACE Standard RP0193-2001,\"External Cathodic Protection of On-Grade Carbon Steel\nStorage Tank Bottoms,\" Title 49 CFR 195 and API Recommended practice 651-2007 Third\nEdition, Cathodic Protection of Above Ground Storage Tanks, and Cathodic protection\nshall be installed in accordance with API Recommended Practice 651 in order to protect the\nbottoms of aboveground breakout tanks of more than 500 barrel capacity and built to latest\nversions of API Specification 12F, API Standard 620, or API Standard 650 (or its predecessor\n\n\n\nStandard 12C). For breakout tanks, each cathodic protection system used to control corrosion\non the bottom of an aboveground breakout tank must be inspected to ensure that operation\nand maintenance of the system are in accordance with API Recommended Practice 651. The\nresults of this inspection shall be reported in the \"Annual Cathodic Protection Survey Report\"\nor electronic equal and retained according to paragraph Records of this section.\nWhile the OM – Section K did identify that cathodic protection shall be in accordance with NACE\nRP-0193 and shall be installed in accordance with API RP 651, it failed to include any details on\na proper frequency for inspection, any instruction on how the inspections will be conducted and\ndocumented, and procedures for how cathodic protection readings are taken on each breakout tank\ndepending on the type of cathodic protection system installed.\nFurthermore, during the inspection, Citgo noted that a single form can be used to document an\ninspection of each and every breakout tank in the facility. However, the procedures failed to\nprovide any instruction or reference in how this would be conducted. When PHMSA requested if\nthere were additional information, Citgo did not provide any further details.\nTherefore, Citgo’s procedures failed to adequately detail when and how cathodic protection\nsystems will be inspected on its breakout tanks, in accordance with § 195.573(d). Citgo must\nrevise its procedures to address this deficiency.\n14. § 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.\nCitgo’s procedures for maintenance and normal operation were inadequate. Specifically, Citgo’s\nOM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K), failed to require\nand include a process to verify that supervisors maintain a thorough knowledge of that portion of\nthe corrosion control procedures established under § 195.402(c)(3) for which they are responsible\nfor insuring compliance.\nSection § 195.555 stated in part:\nYou must require and verify that supervisors maintain a thorough knowledge of that\nportion of the corrosion control procedures established under § 195.402(c)(3) for\nwhich they are responsible for insuring compliance.\nDuring the inspection, PHMSA requested Citgo’s procedures regarding the § 195.555\nrequirements. Citgo provided the OM – Section K. Citgo’s OM - Section K stated in part: the\nSupervisor of Corrosion Control shall review and update Section K of the O&M Manual annually,\nnot to exceed 15 months.\n\n\n\nWhile the OM – Section K did identify a requirement to review the Section K of the O&M\nmanually at a set interval, the procedures failed to include a review of all incorporated by reference\ncathodic protection related procedures and forms as part of the review for the supervisors.\nWhen PHMSA requested follow-up information on why all cathodic protection related procedures,\nreferences and forms were not required to be included as part of the supervisors’ annual review to\nmaintain knowledge on the applicable procedures, Citgo confirmed that only Section K was part\nof this review.\nTherefore, Citgo’s procedures failed to require and verify that supervisors maintain a thorough\nknowledge of that portion of the corrosion control procedures established under § 195.402(c)(3)\nfor which they are responsible for insuring compliance. Citgo must revise its procedures to address\nthis deficiency.\n15. § 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.\nCitgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s\nOM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K) failed to include\ndetails on protecting the pipeline against damage from fault currents or lightning, in accordance\nwith § 195.575(e).\nSection § 195.575(e) stated in part:\nIf a pipeline is in close proximity to electrical transmission tower footings, ground\ncables, or counterpoise, or in other areas where it is reasonable to foresee fault\ncurrents or an unusual risk of lightning, you must protect the pipeline against damage\nfrom fault currents or lightning and take protective measures at insulating devices.\nDuring the inspection, PHMSA requested Citgo’s procedures for fault current and lightning\nprotection. Citgo provided the OM – Section K. The OM – Section K reiterated the § 195.575(e)\nrequirements and failed to include any process or details for how Citgo protects the pipeline against\ndamage from fault currents or lightning. When PHMSA asked for additional details regarding the\nrequirements, Citgo discussed a grounding inspection form for all tanks and provided New Tanks\n– Bottoms, Leak Detection and Ignition Protection – TPL-EPCC-TK100, dated 04/01/22 (New\nTank Procedure).\nThe New Tank Procedure stated in part: The purpose of this specification is to provide\nrequirements for tank bottom installation and protection against ignitions arising from static,\n\n\n\nlightning, and stray currents on newly constructed tanks.\nThe New Tank Procedure, however, was not incorporated o","truncated":true,"body_characters":54743}