{"operation":"document","citation":"CPF 12025026NOA","title":"DOUGLAS PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-01","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a), 192.605(b)(1), 192.605(b)(2), 192.605(b)(8), 192.615(a)(12), 192.805(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025026noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025026noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025026noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025026NOA","body":"Notice of Amendment involving DOUGLAS PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(1),  192.605(b)(2),  192.605(b)(8),  192.615(a)(12),  192.805(e). The case was opened on 2025-07-01 and is reported as closed as of 2025-09-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025026NOA_Closure Letter_09102025_(24-295885).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Closure%20Letter_09102025_(24-295885).pdf\n\n12025026NOA_Closure Letter_09102025_(24-295885)_txt.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Closure%20Letter_09102025_(24-295885)_txt.pdf\n\n12025026NOA_Notice of Amendment_07012025_(24-295885).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Notice%20of%20Amendment_07012025_(24-295885).pdf\n\n12025026NOA_Notice of Amendment_07012025_(24-295885)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Notice%20of%20Amendment_07012025_(24-295885)_text.pdf\n\n12025026NOA_Operator Response to Notice_07312025_(24-295885).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Operator%20Response%20to%20Notice_07312025_(24-295885).pdf\n\n12025026NOA_Notice of Amendment_07012025_(24-295885)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: restabrook@douglaspipeline.com\nJuly 1, 2025\nMr. Ryan Estabrook\nPresident\nDouglas Pipeline Company\n901 Castle Shannon Boulevard\nPittsburgh, Pennsylvania 15234\nCPF 1-2025-026-NOA\nDear Mr. Estabrook:\nFrom February 22 through July 24, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Douglas Pipeline Company’s (DPC) procedures for its pipeline facilities in Shawville,\nPennsylvania.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within DPC’s\nplans or procedures. The items inspected and the alleged inadequacies and proposed revisions are\ndescribed below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nDPC’s manual of written procedures for maintenance and normal operations were inadequate to\nensure pipeline safety in accordance with section 192.605(a). Specifically, DPC’s, Operation and\nMaintenance Manual, Natural Gas Transmission Pipeline, for the Penn Production Group,\nShawville Power plant, Clearfield County, PA, V.2023-2 (3/9/2024) (O&M Manual) failed to\n\n\n\nprovide adequate instructions for performing the annual review of its manual.\nDuring the inspection, PHMSA requested information regarding DPC’s process for reviewing its\nprocedural manual pursuant to section 192.605(a). Section 1 of the O&M Manual states that “[t]his\nManual is to be reviewed once per calendar year at intervals not exceeding 15 months. The review\nmust be completed and documented by a Douglas Pipeline representative and representatives of\nthe facility owner if applicable.”\nThe O&M Manual failed to provide clear guidance on how the annual review must be documented.\nDPC’s O&M Manual lacked information such as the roles and responsibilities of the reviewers,\nmanagement approvals, statement of annual review and associated version number, origin date,\nand the effective date of the last revision on every document cover page.\nAfter the inspection, DPC responded to PHMSA’s request for items from the inspection, which\nincluded O&M Manual section 1, and also provided a revised O&M, V.2023-24-1, cover page\n(6/17/2024) and O&M, V.2023-24-1, Manual Review Log (6/17/2024). While the updated O&M\nManual added two entries to the review log, these logged changes were unrelated to revisions to\nthe process of performing the annual review of its manual.\nTherefore, DPC’s manual of written procedures for maintenance and normal operations were\ninadequate to ensure pipeline safety in accordance with § 192.605(a). PHMSA proposes that DPC\nmust revise its procedures to include adequate instructions for performing the annual review of its\nmanuals of written procedures pursuant to section 192.605(a), including specifying the roles and\nresponsibilities of DPC personnel who perform these reviews.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nDPC’s manual of written procedures for maintenance and normal operations were inadequate to\nensure pipeline safety in accordance with section 192.605(b)(1). Specifically, DPC’s O&M\nManual failed to detail the steps that must be taken to prevent accidental ignition where gas\npresents a hazard of fire or explosion pursuant to section 192.751.\nDuring the inspection, DPC presented its O&M Manual and its Job Safety Analysis, Form 17,\nRevision 2 (12/21/21) (JSA). Both documents failed to provide adequate steps for preventing\naccidental ignition, such as isolating potential combustible vapors and eliminating all potential\nignition sources through ensuring the proper grounding of equipment or appurtenances.\nAdditionally, O&M section 5 also stated “…Douglas Pipeline Company’s Job Safety Analysis –\nProgram 17 (JSA) shall be completed prior to performing tasks outside of normal operations and\n\n\n\nmaintenance….” work.\nDPC’s JSA process contained steps for preventing accidental ignition pursuant\nto section 192.751, but this requirement was not mandated for normal operations and maintenance\nTherefore, DPC’s manual of written procedures for maintenance and normal operations were\ninadequate to ensure pipeline safety in accordance with section 192.605(b)(1). PHMSA proposes\nthat DPC must revise its procedures and forms to address this deficiency.\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and Subpart\nM of this part.\nDPC’s manual of written procedures for maintenance and normal operations were inadequate to\nensure pipeline safety in accordance with section 192.605(b)(1). Specifically, DPC’s O&M\nManual failed to provide adequate instructions for determining the maximum allowable operating\npressure for a pipeline (MAOP) segment in accordance with section 192.619.\nSection 7.1 in DPC’s O&M Manual copied the regulatory text in section 192.619(a) without\nincluding additional detail specific to its pipeline facilities. For example, the O&M Manual failed\nto define the roles and responsibilities of DPC’s qualified personnel who are involved in the\nMAOP calculation and verification of technical data, not limited to pipeline design data and\nmaterial properties. It also failed to specify which form is used to document the overall MAOP\ndetermination process. In addition, the O&M Manual failed to include the footnotes related to\nTable 1 in section 192.619(a)(2)(ii).\nTherefore, DPC’s manual of written procedures for maintenance and normal operations were\ninadequate to ensure pipeline safety in accordance with section 192.605(b)(1). PHMSA proposes\nthat DPC must revise its procedures to include the overall process and roles and responsibilities of\nthe involved personnel.\n4. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) …\n(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of subpart I of this part.\nDPC’s manual of written procedures for maintenance and normal operations were inadequate to\ncontrol corrosion in accordance with section 192.605(b)(2). Specifically, DPC’s O&M processes\n\n\n\nfor internal corrosion control were inadequate pursuant to the requirements of sections 192.475\nand 192.477.\nDuring the inspection, DPC presented its O&M sections 8.12 and 8.14. In addition, DPC presented\nits referenced Standard Operating Procedure #40, Gas Sampling for Internal Corrosion –\nMonitoring. V-1 (5/19/2024) (SOP #40), Standard Operating Procedure #40a, Visually Inspect\nRemoved Pipe for Internal Corrosion, V-1 (8/26/2019) (SOP #40a), and Standard Operating\nProcedure #40b, Measure Suspected Internal Corrosion, V-1 (8/26/2019) (SOP #40b). These\nprocedures all lacked sufficient details, including:\n• Section 8.12 failed to provide the specific action that DPC will take if internal corrosion\nis found. This section did not reference any SOP and primarily mirrored the language\nof section 192.475.\n• Section 8.14 did not attribute the roles and responsibilities, and the procedure to follow\nfor internal corrosion monitoring at DPC. It also did not specify the frequency of the\ngas quality sampling to monitor the potential corrosive constituents present in the gas\nsupplied by Eastern Gas Transmission and PPG wells. Additionally, this section only\nlisted water vapor and hydrogen sulfide as potential constituents.\nAfter the inspection, DPC responded to PHMSA’s requested items from the inspection and\nprovided the following sections of its revised O&M, V-3:2023-24-1 (06/17/24): section 8.12,\nsection 8.13, and section 8.14, along with its referenced SOP #40 V-2 (8/23/2024). However,\nthese revised sections still contained the following inadequacies:\n• The revised section 8.12 now referenced specific SOPs to follow when pipe is exposed\nand if corrosion is found, but it still does not provide sufficient detail procedure of the\ninvestigation and actions to be taken to minimize internal corrosion when found and\nwas found to still be primarily reiterative of section 192.475.\n• The revised section 8.14 failed to call out the frequency of the gas quality sampling to\nmonitor the potential corrosive constituents present in the gas supplied by Eastern Gas\nTransmission and PPG wells consistently with its revised SOP #40, V-2, page 2\n(8/23/2024) (“Samples from potential sources of pipeline contamination must be\nsampled quarterly when flowing gas into Douglas Pipeline Company operated\nsystems.”).\n• The defined frequency of sampling in SOP #40, page 1 (“As necessary to determine if\ngas being transported in the pipeline has corrosive contaminants.”) conflicted with the\nabove frequency found on page 2.\nTherefore, DPC’s manual of written procedures for maintenance and normal operations were\ninadequate to control corrosion in accordance with section 192.605(b)(2). PHMSA proposes that\nDPC must revise its procedures to address the identified deficiencies.\n5. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n\n\n\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) …\n(8) Periodically reviewing the work done by operator personnel to\ndetermine the effectiveness, and adequacy of the procedures used in\nnormal operation and maintenance and modifying the procedures\nwhen deficiencies are found.\nDPC’s manual of written procedures for maintenance and normal operations were inadequate to\nensure pipeline safety in accordance with section 192.605(b)(8). Specifically, DPC’s O&M\nManual failed to reference the documentation supporting the procedural effectiveness review and\nfailed to define the frequency for performing the periodic effectiveness review.\nDuring the inspection, DPC presented its O&M Manual, section 9.2. This procedure stated in part\nthat “[t]he effectiveness and adequacy of procedures used in normal operations and maintenance,\nand by DPC’s contractors, will be reviewed periodically by Douglas Pipeline technicians and\nsupervisors …” and “[p]rocedures will be modified should any deficiencies be found. Exhibit 1 of\nthis manual will document this procedure review which will occur periodically and as needed\nshould the operator deem a procedure review is necessary….”\nO&M Manual section 9.2 referred to an Exhibit 1 of the manual as the form for documenting the\nprocedural effectiveness review, but the O&M Manual did not contain a form labeled as Exhibit\n1. Instead, DPC’s Operator Personnel – Procedure Effectiveness appeared to be the form DPC\nutilized, as it contained a log of the findings and revisions of the reviewed procedure, reviewers,\nand review dates. The procedure also failed to describe how the effectiveness review is performed\nto determine if the procedure is adequate, and how often DPC must perform the effectiveness\nreview.\nTherefore, DPC’s manual of written procedures for maintenance and normal operations were\ninadequate to ensure pipeline safety in accordance with section 192.605(b)(8). PHMSA proposes\nthat DPC must revise its procedures to addresses the inadequacies discussed above.\n6. § 192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize\nthe hazard resulting from a gas pipeline emergency. At a minimum, the\nprocedures must provide for the following:\n(1) …\n(12) Each operator must develop written rupture identification\nprocedures to evaluate and identify whether a notification of potential\nrupture, as defined in § 192.3, is an actual rupture event or a non-\nrupture event. These procedures must, at a minimum, specify the\nsources of information, operational factors, and other criteria that\noperator personnel use to evaluate a notification of potential rupture\nand identify an actual rupture. For operators installing valves in\naccordance with § 192.179(e), § 192.179(f), or that are subject to the\n\n\n\nrequirements in § 192.634, those procedures must provide for rupture\nidentification as soon as practicable.\nDPC’s written procedures to minimize the hazards resulting from gas pipeline emergencies were\ninadequate to ensure pipeline safety in accordance with section 192.615(a)(12). Specifically,\nDPC’s Emergency Response Plan, V.3.2023-24 (7/1/2023) (ERP) and its O&M Manual were\ninadequate as they did not provide a sufficient detailed plan for DPC personnel to follow to\ninvestigate and identify a potential rupture.\nDuring the inspection, DPC presented its ERP section 7 which stated in part that “[w]hen there is\nan unexpected or unexplained pressure loss outside of the pipeline’s normal operating pressures\n(as defined in the O&M manual), procedures shall be employed to survey the system and eliminate\nconditions that could endanger life or property.”\nWhen PHMSA requested to see the procedures referenced in DPC’s O&M Manual, DPC presented\nO&M Manual, section 12.1, Rupture Identification 192.615(12). This procedure failed to include\nspecific steps for potential rupture identification as required in DPC’s ERP. Instead, it stated that\n“[e]ach operator must develop written rupture identification procedures to evaluate and identify\nwhether a notification of potential rupture, as defined in section 192.3, is an actual rupture event\nor a non-rupture event.” The ERP and O&M Manual lacked clear criteria for what magnitude of\npressure loss is outside the pipeline’s normal operating pressures pursuant to\nsection 192.635(a)(1), and it failed to discuss the criteria in sections 192.635(a)(2) and (a)(3).\nMoreover, the O&M Manual was improperly referenced as it lacked specific information related\nto the section 192.635 requirements.\nTherefore, DPC’s written procedures to minimize the hazards resulting from gas pipeline\nemergencies were inadequate to ensure pipeline safety in accordance with section 192.615(a)(12).\nPHMSA proposes that DPC must revise its procedures to provide sufficient guidance for\nidentifying potential ruptures.\n7. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification\nprogram. The program shall include provisions to:\n(a) …\n(e) Evaluate an individual if the operator has reason to believe that\nthe individual is no longer qualified to perform a covered task;\nDPC’s written qualification program was inadequate to ensure pipeline safety in accordance with\nsection 192.805(e). Specifically, DPC’s Natural Gas Pipeline Operator Qualification Program,\nV-14, (8/31/2023) (OQ Plan) failed to include adequate provisions for granting exceptions to\nrequalification requirements for individuals disqualified from a covered task due to prolonged\nperiods of physical, mental, or medical impairment.\nDPC’s OQ Plan, section 3.8 stated in part “[n]ote: Disqualification because of a physical, mental,\nor medical impairment may not require remediation and re-qualification.”\nDuring the inspection, DPC presented its OQ Plan. However, the OQ Plan did not clearly define\n\n\n\nthe conditions under which someone disqualified due to physical, mental, or medical impairment\ncould either follow specific re-qualification steps or perform a covered task under the direction\nand observation of a qualified individual, in accordance with section 192.805(b) and\nsection 192.805(c).\nTherefore, DPC’s written qualification program was inadequate to ensure pipeline safety in\naccordance with section 192.805(e). PHMSA proposes that DPC must revise its procedures to\nclarify when an individual must be requalified under these circumstances.\nResponse to this Notice\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(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 section 190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your plans\nor procedures are found inadequate as alleged in this Notice, you may be ordered to amend your\nplans or procedures to correct the inadequacies (49 CFR § 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 Douglas Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2025-026-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n12025026NOA_Closure Letter_09102025_(24-295885)_txt.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: restabrook@douglaspipeline.com\nSeptember 10, 2025\nMr. Ryan Estabrook, President\nDouglas Pipeline Company\n901 Castle Shannon Boulevard\nPittsburgh, Pennsylvania 15234\nRE: CPF 1-2025-026-NOA\nDear Mr. Estabrook:\nFrom February 22 through July 24, 2024, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Douglas Pipeline Company’s (DPC) procedures for its pipeline facilities in Shawville,\nPennsylvania. As a result of the inspection, DPC was issued a Notice of Amendment on July 1,\n2025, which proposed amendment of your procedures.\nDPC submitted its amended procedures on July 31, 2025. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary, and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12025026NOA_Closure Letter_09102025_(24-295885).pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: restabrook@douglaspipeline.com\nSeptember 10, 2025\nMr. Ryan Estabrook, President\nDouglas Pipeline Company\n901 Castle Shannon Boulevard\nPittsburgh, Pennsylvania 15234\nRE: CPF 1-2025-026-NOA\nDear Mr. Estabrook:\nFrom February 22 through July 24, 2024, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Douglas Pipeline Company’s (DPC) procedures for its pipeline facilities in Shawville,\nPennsylvania. As a result of the inspection, DPC was issued a Notice of Amendment on July 1,\n2025, which proposed amendment of your procedures.\nDPC submitted its amended procedures on July 31, 2025. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary, and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":23210}