# CITGO PIPELINE CO — Notice of Amendment

- **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:** Not available
- **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).
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- **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.

Official case documents:

12024032NOA_Closure Letter_03262025_(23-263975).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Closure%20Letter_03262025_(23-263975).pdf

12024032NOA_Closure Letter_03262025_(23-263975)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Closure%20Letter_03262025_(23-263975)_text.pdf

12024032NOA_Notice of Amendment_07052024_(23-263975).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024032NOA/12024032NOA_Notice%20of%20Amendment_07052024_(23-263975).pdf

12024032NOA_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

12024032NOA_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

12024032NOA_Notice of Amendment_07052024_(23-263975)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: Cjorda@citgo.com
July 5, 2024
Mr. Carlos Jorda
President and Chief Executive Officer
Citgo Pipeline Co
1289 Eldridge Parkway
Houston, Texas 77077
CPF 1-2024-032-NOA
Dear Mr. Jorda:
On March 27, 2023 through November 7, 2023, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) conducted an integrated inspection of Citgo Pipeline Company, Citgo Petroleum
Corporation Terminals and Citgo Products Pipeline Company (Citgo) procedures in Everglades,
Florida, Niles, Michigan, Linden, New Jersey, Toledo, Ohio and Sour Lake, Texas.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Citgo’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline system a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal
operations and emergencies. This manual shall be reviewed at intervals
not exceeding 15 months, but at least once each calendar year, and
appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a
pipeline system commence, and appropriate parts shall be kept at
locations where operations and maintenance activities are conducted.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s



Facility Response Plans failed to state the manuals shall be reviewed at intervals not exceeding 15
months, but at least once each calendar year, and appropriate changes made as necessary to insure
that the manual is effective, in accordance with § 195.402(a).
During the inspection, PHMSA requested Citgo’s procedures regarding annual reviews of its
emergency manual pursuant to § 195.402(a). Citgo provided, Gulf Coast Response Zone – FRP,
dated 02/23/23, Linden FRP, dated 02/23/23, Niles FRP, dated 03/09/23, Port Everglades FRP,
dated 02/23/23 and Toledo FRP, dated 02/23/23 (FRP). Citgo also identified that the emergency
manual required by § 195.402(e) is the FRPs.
The FRP’s stated in part that “…this plan will be reviewed annually and modified to address new
or different operating conditions or information included in the Plan.”
However, the FRPs failed to state that the manuals be reviewed at the proper interval of at least
once each calendar year, and not to exceed 15 months.
Therefore, Citgo’s procedures failed to state the manual shall be reviewed at intervals not
exceeding 15 months but at least once each calendar year, in accordance with § 195.402(a). Citgo
must revise its procedures to address this requirement.
2. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline system a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal
operations and emergencies. This manual shall be reviewed at intervals
not exceeding 15 months, but at least once each calendar year, and
appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a
pipeline system commence, and appropriate parts shall be kept at
locations where operations and maintenance activities are conducted.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo's
OM Manual Section Q – Abandonment of Facilities, dated 10/19/00 (OM - Section Q) failed to
state adequate details for reporting abandonment or deactivation of facilities, in accordance with §
195.59.
Section 195.59 states:
The preferred method to submit data on pipeline facilities abandoned after October
10, 2000 is to the National Pipeline Mapping System (NPMS) in accordance with
the NPMS “Standards for Pipeline and Liquefied Natural Gas Operator
Submissions.” To obtain a copy of the NPMS Standards, please refer to the NPMS
homepage at http://www.npms.phmsa.dot.gov or contact the NPMS National
Repository at 703-317-3073. A digital data format is preferred, but hard copy
submissions are acceptable if they comply with the NPMS Standards. In addition to
the NPMS-required attributes, operators must submit the date of abandonment,
diameter, method of abandonment, and certification that, to the best of the operator's



knowledge, all of the reasonably available information requested was provided and,
to the best of the operator's knowledge, the abandonment was completed in
accordance with applicable laws. Refer to the NPMS Standards for details in
preparing your data for submission. The NPMS Standards also include details of
how to submit data. Alternatively, operators may submit reports by mail, fax or e-
mail to the Office of Pipeline Safety, Pipeline and Hazardous Materials Safety
Administration, U.S. Department of Transportation, Information Resources
Manager, PHP-10, 1200 New Jersey Avenue, SE., Washington, DC 20590-0001; fax
(202) 366-4566; e-mail, “InformationResourcesManager@phmsa.@phmsa.dot.gov.
During the inspection, PHMSA requested procedures related to abandonment. Citgo provided OM
– Section Q. Section Q stated in part: Alternatively, operators may submit reports by mail, fax or
e-mail to the Information Officer, Research and Special Programs Administration (RSPA),
Department of Transportation, Room 7128, 400 Seventh Street, SW, Washington DC 20590; FAX
(202) 366-4566; E-MAIL, roger.little@rspa.dot.gov. The information in the report must contain
all reasonably available information related to the facility, including information in the possession
of a third party.
The OM – Section Q, however, failed to state the correct agency name, address and email contact
to submit the abandonment reports to.
Therefore, Citgo procedures failed to state adequate details for reporting abandonment or
deactivation of facilities, in accordance with § 195.59. Citgo must revise its procedures to address
this requirement.
3. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline system a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal
operations and emergencies. This manual shall be reviewed at intervals
not exceeding 15 months, but at least once each calendar year, and
appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a
pipeline system commence, and appropriate parts shall be kept at
locations where operations and maintenance activities are conducted.
Citgo's procedures for safety-related condition reports were inadequate. Specifically, Citgo's OM
Manual Section G – Accident Reporting, dated 09/27/22 (OM - Section G) failed to include
instructions enabling personnel who perform operation and maintenance (O&M) activities to
recognize conditions that potentially may be safety-related conditions (SRCs) that are subject to
the reporting requirements of § 195.55.
During the inspection, PHMSA requested Citgo's procedure regarding recognizing safety-related
conditions. Citgo provided the OM - Section G. Section G, page G-22 reiterated the list of SRCs
found in § 195.55(a). When PHMSA asked Citgo where the process details were related to
providing instructions to enable personnel who perform O&M activities to recognize conditions



that may be SRCs, Citgo was unable to provide a relevant section of the O&M which indicated
compliance with this requirement. The OM – Section G lacked any guidance, criteria or examples
that would allow Citgo personnel to differentiate between what is and what is not a potential safety-
related condition, nor did it reference any other relevant procedures or training that provide O&M
personnel the required instruction.
Therefore, Citgo failed to include instructions in its written procedures for personnel who perform
operation and maintenance activities to recognize conditions that potentially may be safety-related
conditions subject to the reporting requirements of § 195.55 in accordance with § 195.402(f).
Citgo must revise its procedures to address this requirement.
4. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
Integrity Management Program for Hazardous Liquids Pipelines Pipeline Integrity Assessment,
dated 10/01/22 (LIMP-03) failed to contain an analysis that integrates all available information
about the integrity of the entire pipeline(s) and the consequence of a failure, per the requirements
of § 195.452(f)(3).
Section § 195.452(f)(3) stated in part:
…An operator must include, at minimum, each of the following elements in its
written integrity management program:
(3) An analysis that integrates all available information about the integrity of the
entire pipeline and the consequences of a failure (see paragraph (g) of this section)
During the inspection, PHMSA requested Citgo’s procedures regarding the process for evaluating
in-line inspection results and data integration. Citgo provided the LIMP-03. The LIMP-03 –
Section 5.14.1 stated in part that the integrity engineer will ensure that all available data that is
relevant to the assessment will be integrated and used in information analysis. ILI vendor data,
data stored in GIS/PODS, PCS-CPDM and MS Access databases will be primary data sources.
However, the LIMP-03 failed to describe the process and details behind how and when Citgo
conducts this analysis, as well as in what method Citgo integrates this data amongst their programs.
When PHMSA asked Citgo where this information was documented Citgo discussed that their
process is not spelled out indicating instructions or further guidance.
Therefore, Citgo’s procedures failed to contain an analysis that integrates all available information



about the integrity of the entire pipeline(s) and the consequence of a failure, in accordance with §
195.452(f)(3). Citgo must revise its procedures to address this requirement.
5. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
Integrity Management Program for Hazardous Liquids Pipelines Pipeline Integrity Assessment,
dated 10/01/22 (LIMP-03) and Integrity Management Program for Hazardous Liquids Pipelines-
Pipeline Remediation, dated 05/01/21 (LIMP-04) failed to prioritize repairs for its non-high
consequence areas (HCA), per the requirements of § 195.401(b)(3).
Section 195.401(b) states in part:
(1) Non-Integrity management repairs. Whenever an operator discovers any
condition that could adversely affect the safe operation of its pipeline system, it
must correct the condition within a reasonable time. However, if the condition is of
such a nature that it presents an immediate hazard to persons or property, the
operator may not operate the affected part of the system until it has corrected the
unsafe condition.
…
(3) Prioritizing repairs: An operator must consider the risk to people, property, and
the environment in prioritizing the correction of any conditions referenced in
paragraphs (b)(1) and (2) of this section.
During the inspection, PHMSA requested Citgo’s procedures regarding the process for pipeline
defect repairs in non-HCA areas. Citgo provided the LIMP-03 and LIMP-04. The LIMP-03
provided for ‘Immediate Hazard Conditions’ on non-HCA segments for certain criteria described
in Section 5.8.6. Section 5.8.7 stated:
Specific conditions for evaluation and investigation--Citgo may select these
following conditions on HCA and non-HCA segments for further validation and
investigation, as determined by the integrity engineer.
- Any metal loss greater than 50%
- Any dent near foreign line crossing
- Verification of external corrosion anomaly
- Verification of internal corrosion anomaly
- Verification based on remaining life calculations
- Any 49 CFR 195.452(h)(4) condition in non-HCA



However, the LIMP-03 failed to describe any prioritization of repairs for non-HCA segments
outside of Immediate Hazard Conditions. When PHMSA asked Citgo where this information was
documented, Citgo this is done on a case-by-case basis and there is no set schedule for repairs.
Therefore, Citgo’s procedures failed to contain a process for prioritizing its non-HCA segment
repairs, in accordance with § 195.401(b)(3). Citgo must revise its procedures to address this
requirement.
6. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
Integrity Management Program for Hazardous Liquids Pipelines – Leak Detection Capabilities
Evaluation, dated 07/01/20 (LIMP-11) failed to require a leak detection evaluation on its pipeline
systems, per the requirements of § 195.452(i)(3).
Section § 195.452(i)(3) stated in part:
(i) What preventive and mitigative measures must an operator take to protect the high
consequence area
(3) Leak detection. An operator must have a means to detect leaks on its pipeline
system. An operator must evaluate the capability of its leak detection means and modify,
as necessary, to protect the high consequence area. An operator's evaluation must, at
least, consider, the following factors - length and size of the pipeline, type of product
carried, the pipeline's proximity to the high consequence area, the swiftness of leak
detection, location of nearest response personnel, leak history, and risk assessment
results.
During the inspection, PHMSA requested Citgo’s procedures regarding leak detection system
evaluations. Citgo provided the LIMP-11. The LIMP-11 – Section 5.3 stated in part: Citgo
conducts leak detection evaluations on every pipeline system or reviews the results of the previous
leak detection evaluation during or after P&M measure evaluation meetings which usually occur
every 5 years after the completion of a risk assessment.
However, LIMP-11 failed to include any set requirement for Citgo to conduct a leak detection
evaluation at a specified interval. When PHMSA asked Citgo where this information was
documented, Citgo stated there is no set timeframe for a leak detection evaluation but it is usually
after an integrity assessment.
Therefore, Citgo’s procedures failed to require a leak detection evaluation on its pipeline systems,



per the requirements of § 195.452(i)(3). Citgo must revise its procedures to clarify when it
performs leak detection evaluations pursuant to § 195.452(i)(3).
7. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
Control Room Management Plan – Alarm Management Plan, dated 01/01/23 (CRM-06) and Citgo
Pipeline Operations Manual – Field and Control Center, dated 09/26/22 (OM Section T) failed to
detail how its computational pipeline monitoring (CPM) leak detection systems comply with API
RP 1130 in operating, maintaining, testing, record keeping and dispatcher training for its systems,
in accordance with § 195.444(c).
Section § 195.444(c) stated in part:
(c) CPM leak detection systems. Each computational pipeline monitoring (CPM)
leak detection system installed on a hazardous liquid pipeline must comply with API
RP 1130 (incorporated by reference, see § 195.3) in operating, maintaining, testing,
record keeping, and dispatcher training of the system.
During the inspection, PHMSA requested Citgo’s procedures regarding CPM systems. Citgo
provided the CRM-06 and OM Section T. The O&M Section T stated in part that Citgo maintains
a CPM system that aids in the detection of pipeline leaks. It also stated that this system complies
with API 1130 regarding operating, maintaining, testing, recordkeeping and dispatcher training.
However, OM Section T failed to include details on how Citgo’s CPM systems meet these
requirements. When PHMSA asked Citgo which pipeline or system this procedure applies to as
well as how the system(s) meets the operating, maintaining and testing requirements of API 1130,
Citgo stated that the leak detection systems vary across the pipeline terminals but there is no further
guidance on this process that is documented.
Therefore, Citgo’s procedures failed to detail how its CPM leak detection systems comply with
API RP 1130 in operating, maintaining, testing, record keeping and dispatcher training for its
systems, in accordance with § 195.444(c). Citgo must revise its procedures to address this
requirement.
8. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …



(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
Facility Response Plans failed include details for a notification of potential rupture, in accordance
with § 195.417(a).
Section § 195.417(a) stated in part:
As used in this part, a notification of potential rupture means the notification to, or
observation by, an operator (e.g., by or to its controller(s) in a control room, field
personnel, nearby pipeline or utility personnel, the public, local responders, or public
authorities) of one or more of the below indicia of a potential unintentional or
uncontrolled release of a large volume of hazardous liquids from a pipeline:
During the inspection, PHMSA requested the procedures regarding notifications of potential
ruptures. Citgo provided, Gulf Coast Response Zone – FRP, dated 02/23/23, Linden FRP, dated
02/23/23, Niles FRP, dated 03/09/23, Port Everglades FRP, dated 02/23/23 and Toledo FRP,
dated 02/23/23 (FRP). Citgo also identified that the emergency manual required by § 195.402(e)
is the FRPs.
The FRPs failed to include details covering the notification process of a potential rupture. The
FRPs also failed to define an unanticipated or unexplained pressure loss scenario. When PHMSA
asked for clarification on where these processes are located, Citgo stated that all notifications are
on premises and that they follow FRP Section 2.1. The FRP Section 2.1, however, did not indicate
any details regarding a notification process for the § 195.417(a) requirements.
Therefore, Citgo’s procedures failed to include details for a notification of potential rupture, in
accordance with § 195.417(a). Citgo must revise its procedures to address this requirement.
9. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
OM Manual Section J – Inspection and Maintenance, dated 09/23/22 (OM - Section J) failed to



provide adequate details in its procedures for overpressure safety device inspection and testing in
accordance with § 195.428(a).
During the inspection, PHMSA requested Citgo’s procedures regarding the § 195.428
requirements. Citgo provided the OM - Section J. Section J-28 stated in part, Inspect and test
each pressure limiting device, relief valve, pressure regulator, or other item of pressure control
equipment. Determine that the device is: Functioning properly, in good mechanical condition,
adequate in capacity and reliability for the service in which it is used, set to function at the
correct pressure, properly installed and protected from anything that might prevent proper
operation…and document each inspection of an overpressure safety device on the Check List for
Safety Device Inspection, CPL-31 or equivalent form…
The OM – Section J failed to provide sufficient guidance on conducting and documenting pressure
relief valve inspections, such as:
1. 2. 3. 4. What are the criteria for determining “satisfactory” and “unsatisfactory.”
How is “operational”, “mechanical” and “general condition” to be evaluated.
When is a device to be evaluated for an initial test or re-calibration.
What criteria are used to determine an acceptable “as-found” and “as-left” relief
pressure.
5. What actions must be taken if the relief valve pressure does not meet the criteria.
Therefore, Citgo failed to provide adequate details in its procedures for overpressure safety device
inspection and testing in accordance with § 195.428(a). Citgo must revise its procedures to address
this requirement.
10. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo's
OM Manual Section J – Inspection and Maintenance, dated 09/23/22 (OM - Section J), failed to
provide sufficient guidance for protecting pipeline systems against ignitions arising out of static
electricity, lightning, and stray currents during operation and maintenance activities involving
aboveground breakout tanks in accordance with API RP 2003, per the requirement of § 195.405(a).
Section 195.405(a) states:
After October 2, 2000, protection provided against ignitions arising out of static
electricity, lightning, and stray currents during operation and maintenance activities
involving aboveground breakout tanks must be in accordance with API RP 2003



(incorporated by reference, see §195.3), unless the operator notes in the procedural
manual (§ 195.402(c)) why compliance with all or certain provisions of API RP 2003
is not necessary for the safety of a particular breakout tank.
During the inspection, PHMSA requested Citgo's procedures regarding the §195.405(a)
requirements. Citgo provided the OM – Section J and TPL-EPCC-TK100 – New tanks, bottoms,
leak protection and ignition protection, dated 04/01/22 (TK100). The OM – Section J, page J-21
stated in part: after October 2, 2000, protection provided against ignitions arising out of static
electricity, lightning, and stray currents during operation and maintenance activities involving
aboveground breakout tanks must be in accordance with API Recommended Practice 2003, unless
Citgo notes in this procedure manual why compliance with all or certain provisions of API RP
2003 is not necessary for the safety of a particular tank.
OM Section J failed to indicate or reference any process or details for protection against ignitions
involving aboveground breakout tanks, nor did it provide a reason why compliance with all or
certain provisions of API RP 2003 is not necessary for the safety of a particular breakout tank.
TK100 was associated with new tanks and did not include any details or processes related to
protection against ignitions. Furthermore, the TK100 was not referenced or linked to the Citgo
OM manual. When PHMSA asked for additional procedures as well as reasoning why TK100 was
not referenced in the OM manual, Citgo was unable to provide a response.
Therefore, Citgo procedures failed to include provisions for protecting against ignitions arising out
of static electricity, lightning, and stray currents during operation and maintenance activities
involving aboveground breakout tanks in accordance with API RP 2003, per the requirement of §
195.405(a). Citgo must revise its procedures to address this requirement.
11. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance normal operations and emergencies were inadequate.
Specifically, Citgo's OM Manual Section A – Normal Operation and Maintenance Introduction,
dated 04/01/21 (OM - Section A), failed to state the manuals shall be reviewed at intervals not
exceeding 15 months, but at least once each calendar year, in accordance with § 195.402(a).
During the inspection, PHMSA requested Citgo's procedures regarding the § 195.402(a)
requirements. Citgo provided the OM – Section A. The OM – Section A stated in part: II
Procedure reviews will be documented on forms provided on SHAREPOINT and will be evaluated
annually during the O&M Manual review by the respective sections' SME or document owner.



This annual (not to exceed 15 months) review will not preclude the immediate modification of any
procedure should circumstances warrant such a change.
OM Section A also mentioned various other programs that Citgo maintains manuals for, including
but not limited to, Integrity Management Plans, Corrosion Manuals and Control Room
Management Plans. When PHMSA asked Citgo if these manuals and all referenced documents,
forms and site-specific procedures were included in the required § 195.402(a) at intervals not
exceeding 15 months but at least once each calendar year, Citgo stated that they are not, and
operate on various intervals for review. However, per § 195.402(c) these manuals are required to
be a part of the manual required by § 195.402(a) and are subject to its review interval.
PHMSA reviewed example Citgo documents such as: Integrity Management Program for
Hazardous Liquids Pipelines Integrity Assessment – TPL-EPCC-LIMP03, dated 09/23/22 (IMP),
Integrity Management Program for Hazardous Liquids Pipelines Pipeline Risk Assessment – TPL-
EPCC-LIMP05, dated 09/23/22 (IMP), Incident Notification, Reporting and Investigation – HSE-
STD-SAF-013, dated 10/12/22 (HSE), Terminals and Pipelines – Internal Corrosion – TPL-
EPCC-CCG12, dated 9/18/19 (IC) and Facility Response Plans (all), dated 2023 (FRP).
The IMP stated in part: Review cycle – 5 years.
The HSE stated in part: Review cycle – 3 years.
The IC stated in part: Review cycle – 5 years.
The FRP stated in part: This plan will be reviewed annually.
Therefore, Citgo procedures failed to state the manuals shall be reviewed at intervals not exceeding
15 months, but at least once each calendar year, in accordance with § 195.402(a). Citgo must
revise its procedures to address this requirement.
12. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operation were inadequate. Specifically, Citgo’s
OM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K), failed to include a
description or details of its methodology for evaluating the severity of coating and atmospheric
corrosion deficiencies of pipe inspected pursuant to § 195.583, and for documenting these
inspections.
During the inspection, PHMSA requested Citgo’s procedure for atmospheric corrosion
inspections. Citgo provided the OM – Section K. Citgo’s OM - Section K, page K-9 stated in part:



All onshore aboveground piping shall be inspected at least once every 3 calendar
years, but with intervals not exceeding 39 months (§195.583 (a))…and inspect each
segment of the facility. This may have to be divided up into groups such as tank
piping, manifold piping, etc.… all atmospheric inspections shall be documented
according to the following: Aboveground piping/components - Atmospheric
Coatings Inspection Report, Spans or normally exposed pipe - Span or Exposed
Pipe Inspection Form.
While the OM – Section K did identify the proper frequency for inspection, it failed to include any
detailed procedures for evaluating the existence or severity of these coating and atmospheric
corrosion conditions for the purposes of requiring or prioritizing remediation. The OM – Section
K also failed to include any process details addressing how the atmospheric corrosion inspection
is to be documented aside from referencing the forms to be used. When PHMSA requested if there
were additional procedures or guidance related to atmospheric corrosion, Citgo discussed that they
do not document the actual conditions, rather they only document a suggested repair and
prioritization schedule, if needed.
Therefore, Citgo’s procedures failed to include a description or details of its methodology for
evaluating the severity of coating and atmospheric corrosion deficiencies of pipe inspected
pursuant to § 195.583, and for documenting these inspections. Citgo must revise its procedures to
address this deficiency.
13. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operation were inadequate. Specifically, Citgo’s
OM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K), failed to adequately
detail when and how cathodic protection systems will be inspected on its breakout tanks, in
accordance with § 195.573(d).
During the inspection, PHMSA requested Citgo’s procedure for breakout tank cathodic protection.
Citgo provided the OM – Section K. Citgo’s OM - Section K stated in part:
Cathodic protection of Aboveground Storage Tanks (AST) shall be in accordance with
NACE Standard RP0193-2001,"External Cathodic Protection of On-Grade Carbon Steel
Storage Tank Bottoms," Title 49 CFR 195 and API Recommended practice 651-2007 Third
Edition, Cathodic Protection of Above Ground Storage Tanks, and Cathodic protection
shall be installed in accordance with API Recommended Practice 651 in order to protect the
bottoms of aboveground breakout tanks of more than 500 barrel capacity and built to latest
versions of API Specification 12F, API Standard 620, or API Standard 650 (or its predecessor



Standard 12C). For breakout tanks, each cathodic protection system used to control corrosion
on the bottom of an aboveground breakout tank must be inspected to ensure that operation
and maintenance of the system are in accordance with API Recommended Practice 651. The
results of this inspection shall be reported in the "Annual Cathodic Protection Survey Report"
or electronic equal and retained according to paragraph Records of this section.
While the OM – Section K did identify that cathodic protection shall be in accordance with NACE
RP-0193 and shall be installed in accordance with API RP 651, it failed to include any details on
a proper frequency for inspection, any instruction on how the inspections will be conducted and
documented, and procedures for how cathodic protection readings are taken on each breakout tank
depending on the type of cathodic protection system installed.
Furthermore, during the inspection, Citgo noted that a single form can be used to document an
inspection of each and every breakout tank in the facility. However, the procedures failed to
provide any instruction or reference in how this would be conducted. When PHMSA requested if
there were additional information, Citgo did not provide any further details.
Therefore, Citgo’s procedures failed to adequately detail when and how cathodic protection
systems will be inspected on its breakout tanks, in accordance with § 195.573(d). Citgo must
revise its procedures to address this deficiency.
14. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operation were inadequate. Specifically, Citgo’s
OM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K), failed to require
and include a process to verify that supervisors maintain a thorough knowledge of that portion of
the corrosion control procedures established under § 195.402(c)(3) for which they are responsible
for insuring compliance.
Section § 195.555 stated in part:
You must require and verify that supervisors maintain a thorough knowledge of that
portion of the corrosion control procedures established under § 195.402(c)(3) for
which they are responsible for insuring compliance.
During the inspection, PHMSA requested Citgo’s procedures regarding the § 195.555
requirements. Citgo provided the OM – Section K. Citgo’s OM - Section K stated in part: the
Supervisor of Corrosion Control shall review and update Section K of the O&M Manual annually,
not to exceed 15 months.



While the OM – Section K did identify a requirement to review the Section K of the O&M
manually at a set interval, the procedures failed to include a review of all incorporated by reference
cathodic protection related procedures and forms as part of the review for the supervisors.
When PHMSA requested follow-up information on why all cathodic protection related procedures,
references and forms were not required to be included as part of the supervisors’ annual review to
maintain knowledge on the applicable procedures, Citgo confirmed that only Section K was part
of this review.
Therefore, Citgo’s procedures failed to require and verify that supervisors maintain a thorough
knowledge of that portion of the corrosion control procedures established under § 195.402(c)(3)
for which they are responsible for insuring compliance. Citgo must revise its procedures to address
this deficiency.
15. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) …
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) …
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
Citgo’s procedures for maintenance and normal operations were inadequate. Specifically, Citgo’s
OM Manual Section K – Corrosion Control, dated 08/31/21 (OM - Section K) failed to include
details on protecting the pipeline against damage from fault currents or lightning, in accordance
with § 195.575(e).
Section § 195.575(e) stated in part:
If a pipeline is in close proximity to electrical transmission tower footings, ground
cables, or counterpoise, or in other areas where it is reasonable to foresee fault
currents or an unusual risk of lightning, you must protect the pipeline against damage
from fault currents or lightning and take protective measures at insulating devices.
During the inspection, PHMSA requested Citgo’s procedures for fault current and lightning
protection. Citgo provided the OM – Section K. The OM – Section K reiterated the § 195.575(e)
requirements and failed to include any process or details for how Citgo protects the pipeline against
damage from fault currents or lightning. When PHMSA asked for additional details regarding the
requirements, Citgo discussed a grounding inspection form for all tanks and provided New Tanks
– Bottoms, Leak Detection and Ignition Protection – TPL-EPCC-TK100, dated 04/01/22 (New
Tank Procedure).
The New Tank Procedure stated in part: The purpose of this specification is to provide
requirements for tank bottom installation and protection against ignitions arising from static,



lightning, and stray currents on newly constructed tanks.
The New Tank Procedure, however, was not incorporated o
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