# DOUGLAS PIPELINE CO — Notice of Amendment

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

Official case documents:

12025026NOA_Closure Letter_09102025_(24-295885).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Closure%20Letter_09102025_(24-295885).pdf

12025026NOA_Closure Letter_09102025_(24-295885)_txt.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Closure%20Letter_09102025_(24-295885)_txt.pdf

12025026NOA_Notice of Amendment_07012025_(24-295885).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025026NOA/12025026NOA_Notice%20of%20Amendment_07012025_(24-295885).pdf

12025026NOA_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

12025026NOA_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

12025026NOA_Notice of Amendment_07012025_(24-295885)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: restabrook@douglaspipeline.com
July 1, 2025
Mr. Ryan Estabrook
President
Douglas Pipeline Company
901 Castle Shannon Boulevard
Pittsburgh, Pennsylvania 15234
CPF 1-2025-026-NOA
Dear Mr. Estabrook:
From February 22 through July 24, 2024, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected Douglas Pipeline Company’s (DPC) procedures for its pipeline facilities in Shawville,
Pennsylvania.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within DPC’s
plans or procedures. The items inspected and the alleged inadequacies and proposed revisions are
described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline, a manual of written procedures for conducting operations and
maintenance activities and for emergency response. For transmission
lines, the manual must also include procedures for handling abnormal
operations. This manual must be reviewed and updated by the operator
at intervals not exceeding 15 months, but at least once each calendar
year. This manual must be prepared before operations of a pipeline
system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
DPC’s manual of written procedures for maintenance and normal operations were inadequate to
ensure pipeline safety in accordance with section 192.605(a). Specifically, DPC’s, Operation and
Maintenance Manual, Natural Gas Transmission Pipeline, for the Penn Production Group,
Shawville Power plant, Clearfield County, PA, V.2023-2 (3/9/2024) (O&M Manual) failed to



provide adequate instructions for performing the annual review of its manual.
During the inspection, PHMSA requested information regarding DPC’s process for reviewing its
procedural manual pursuant to section 192.605(a). Section 1 of the O&M Manual states that “[t]his
Manual is to be reviewed once per calendar year at intervals not exceeding 15 months. The review
must be completed and documented by a Douglas Pipeline representative and representatives of
the facility owner if applicable.”
The O&M Manual failed to provide clear guidance on how the annual review must be documented.
DPC’s O&M Manual lacked information such as the roles and responsibilities of the reviewers,
management approvals, statement of annual review and associated version number, origin date,
and the effective date of the last revision on every document cover page.
After the inspection, DPC responded to PHMSA’s request for items from the inspection, which
included O&M Manual section 1, and also provided a revised O&M, V.2023-24-1, cover page
(6/17/2024) and O&M, V.2023-24-1, Manual Review Log (6/17/2024). While the updated O&M
Manual added two entries to the review log, these logged changes were unrelated to revisions to
the process of performing the annual review of its manual.
Therefore, DPC’s manual of written procedures for maintenance and normal operations were
inadequate to ensure pipeline safety in accordance with § 192.605(a). PHMSA proposes that DPC
must revise its procedures to include adequate instructions for performing the annual review of its
manuals of written procedures pursuant to section 192.605(a), including specifying the roles and
responsibilities of DPC personnel who perform these reviews.
2. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) …
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and Subpart
M of this part.
DPC’s manual of written procedures for maintenance and normal operations were inadequate to
ensure pipeline safety in accordance with section 192.605(b)(1). Specifically, DPC’s O&M
Manual failed to detail the steps that must be taken to prevent accidental ignition where gas
presents a hazard of fire or explosion pursuant to section 192.751.
During the inspection, DPC presented its O&M Manual and its Job Safety Analysis, Form 17,
Revision 2 (12/21/21) (JSA). Both documents failed to provide adequate steps for preventing
accidental ignition, such as isolating potential combustible vapors and eliminating all potential
ignition sources through ensuring the proper grounding of equipment or appurtenances.
Additionally, O&M section 5 also stated “…Douglas Pipeline Company’s Job Safety Analysis –
Program 17 (JSA) shall be completed prior to performing tasks outside of normal operations and



maintenance….” work.
DPC’s JSA process contained steps for preventing accidental ignition pursuant
to section 192.751, but this requirement was not mandated for normal operations and maintenance
Therefore, DPC’s manual of written procedures for maintenance and normal operations were
inadequate to ensure pipeline safety in accordance with section 192.605(b)(1). PHMSA proposes
that DPC must revise its procedures and forms to address this deficiency.
3. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) …
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in
accordance with each of the requirements of this subpart and Subpart
M of this part.
DPC’s manual of written procedures for maintenance and normal operations were inadequate to
ensure pipeline safety in accordance with section 192.605(b)(1). Specifically, DPC’s O&M
Manual failed to provide adequate instructions for determining the maximum allowable operating
pressure for a pipeline (MAOP) segment in accordance with section 192.619.
Section 7.1 in DPC’s O&M Manual copied the regulatory text in section 192.619(a) without
including additional detail specific to its pipeline facilities. For example, the O&M Manual failed
to define the roles and responsibilities of DPC’s qualified personnel who are involved in the
MAOP calculation and verification of technical data, not limited to pipeline design data and
material properties. It also failed to specify which form is used to document the overall MAOP
determination process. In addition, the O&M Manual failed to include the footnotes related to
Table 1 in section 192.619(a)(2)(ii).
Therefore, DPC’s manual of written procedures for maintenance and normal operations were
inadequate to ensure pipeline safety in accordance with section 192.605(b)(1). PHMSA proposes
that DPC must revise its procedures to include the overall process and roles and responsibilities of
the involved personnel.
4. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) …
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) …
(2) Controlling corrosion in accordance with the operations and
maintenance requirements of subpart I of this part.
DPC’s manual of written procedures for maintenance and normal operations were inadequate to
control corrosion in accordance with section 192.605(b)(2). Specifically, DPC’s O&M processes



for internal corrosion control were inadequate pursuant to the requirements of sections 192.475
and 192.477.
During the inspection, DPC presented its O&M sections 8.12 and 8.14. In addition, DPC presented
its referenced Standard Operating Procedure #40, Gas Sampling for Internal Corrosion –
Monitoring. V-1 (5/19/2024) (SOP #40), Standard Operating Procedure #40a, Visually Inspect
Removed Pipe for Internal Corrosion, V-1 (8/26/2019) (SOP #40a), and Standard Operating
Procedure #40b, Measure Suspected Internal Corrosion, V-1 (8/26/2019) (SOP #40b). These
procedures all lacked sufficient details, including:
• Section 8.12 failed to provide the specific action that DPC will take if internal corrosion
is found. This section did not reference any SOP and primarily mirrored the language
of section 192.475.
• Section 8.14 did not attribute the roles and responsibilities, and the procedure to follow
for internal corrosion monitoring at DPC. It also did not specify the frequency of the
gas quality sampling to monitor the potential corrosive constituents present in the gas
supplied by Eastern Gas Transmission and PPG wells. Additionally, this section only
listed water vapor and hydrogen sulfide as potential constituents.
After the inspection, DPC responded to PHMSA’s requested items from the inspection and
provided the following sections of its revised O&M, V-3:2023-24-1 (06/17/24): section 8.12,
section 8.13, and section 8.14, along with its referenced SOP #40 V-2 (8/23/2024). However,
these revised sections still contained the following inadequacies:
• The revised section 8.12 now referenced specific SOPs to follow when pipe is exposed
and if corrosion is found, but it still does not provide sufficient detail procedure of the
investigation and actions to be taken to minimize internal corrosion when found and
was found to still be primarily reiterative of section 192.475.
• The revised section 8.14 failed to call out the frequency of the gas quality sampling to
monitor the potential corrosive constituents present in the gas supplied by Eastern Gas
Transmission and PPG wells consistently with its revised SOP #40, V-2, page 2
(8/23/2024) (“Samples from potential sources of pipeline contamination must be
sampled quarterly when flowing gas into Douglas Pipeline Company operated
systems.”).
• The defined frequency of sampling in SOP #40, page 1 (“As necessary to determine if
gas being transported in the pipeline has corrosive contaminants.”) conflicted with the
above frequency found on page 2.
Therefore, DPC’s manual of written procedures for maintenance and normal operations were
inadequate to control corrosion in accordance with section 192.605(b)(2). PHMSA proposes that
DPC must revise its procedures to address the identified deficiencies.
5. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) …



(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following,
if applicable, to provide safety during maintenance and operations.
(1) …
(8) Periodically reviewing the work done by operator personnel to
determine the effectiveness, and adequacy of the procedures used in
normal operation and maintenance and modifying the procedures
when deficiencies are found.
DPC’s manual of written procedures for maintenance and normal operations were inadequate to
ensure pipeline safety in accordance with section 192.605(b)(8). Specifically, DPC’s O&M
Manual failed to reference the documentation supporting the procedural effectiveness review and
failed to define the frequency for performing the periodic effectiveness review.
During the inspection, DPC presented its O&M Manual, section 9.2. This procedure stated in part
that “[t]he effectiveness and adequacy of procedures used in normal operations and maintenance,
and by DPC’s contractors, will be reviewed periodically by Douglas Pipeline technicians and
supervisors …” and “[p]rocedures will be modified should any deficiencies be found. Exhibit 1 of
this manual will document this procedure review which will occur periodically and as needed
should the operator deem a procedure review is necessary….”
O&M Manual section 9.2 referred to an Exhibit 1 of the manual as the form for documenting the
procedural effectiveness review, but the O&M Manual did not contain a form labeled as Exhibit
1. Instead, DPC’s Operator Personnel – Procedure Effectiveness appeared to be the form DPC
utilized, as it contained a log of the findings and revisions of the reviewed procedure, reviewers,
and review dates. The procedure also failed to describe how the effectiveness review is performed
to determine if the procedure is adequate, and how often DPC must perform the effectiveness
review.
Therefore, DPC’s manual of written procedures for maintenance and normal operations were
inadequate to ensure pipeline safety in accordance with section 192.605(b)(8). PHMSA proposes
that DPC must revise its procedures to addresses the inadequacies discussed above.
6. § 192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize
the hazard resulting from a gas pipeline emergency. At a minimum, the
procedures must provide for the following:
(1) …
(12) Each operator must develop written rupture identification
procedures to evaluate and identify whether a notification of potential
rupture, as defined in § 192.3, is an actual rupture event or a non-
rupture event. These procedures must, at a minimum, specify the
sources of information, operational factors, and other criteria that
operator personnel use to evaluate a notification of potential rupture
and identify an actual rupture. For operators installing valves in
accordance with § 192.179(e), § 192.179(f), or that are subject to the



requirements in § 192.634, those procedures must provide for rupture
identification as soon as practicable.
DPC’s written procedures to minimize the hazards resulting from gas pipeline emergencies were
inadequate to ensure pipeline safety in accordance with section 192.615(a)(12). Specifically,
DPC’s Emergency Response Plan, V.3.2023-24 (7/1/2023) (ERP) and its O&M Manual were
inadequate as they did not provide a sufficient detailed plan for DPC personnel to follow to
investigate and identify a potential rupture.
During the inspection, DPC presented its ERP section 7 which stated in part that “[w]hen there is
an unexpected or unexplained pressure loss outside of the pipeline’s normal operating pressures
(as defined in the O&M manual), procedures shall be employed to survey the system and eliminate
conditions that could endanger life or property.”
When PHMSA requested to see the procedures referenced in DPC’s O&M Manual, DPC presented
O&M Manual, section 12.1, Rupture Identification 192.615(12). This procedure failed to include
specific steps for potential rupture identification as required in DPC’s ERP. Instead, it stated that
“[e]ach operator must develop written rupture identification procedures to evaluate and identify
whether a notification of potential rupture, as defined in section 192.3, is an actual rupture event
or a non-rupture event.” The ERP and O&M Manual lacked clear criteria for what magnitude of
pressure loss is outside the pipeline’s normal operating pressures pursuant to
section 192.635(a)(1), and it failed to discuss the criteria in sections 192.635(a)(2) and (a)(3).
Moreover, the O&M Manual was improperly referenced as it lacked specific information related
to the section 192.635 requirements.
Therefore, DPC’s written procedures to minimize the hazards resulting from gas pipeline
emergencies were inadequate to ensure pipeline safety in accordance with section 192.615(a)(12).
PHMSA proposes that DPC must revise its procedures to provide sufficient guidance for
identifying potential ruptures.
7. § 192.805 Qualification program.
Each operator shall have and follow a written qualification
program. The program shall include provisions to:
(a) …
(e) Evaluate an individual if the operator has reason to believe that
the individual is no longer qualified to perform a covered task;
DPC’s written qualification program was inadequate to ensure pipeline safety in accordance with
section 192.805(e). Specifically, DPC’s Natural Gas Pipeline Operator Qualification Program,
V-14, (8/31/2023) (OQ Plan) failed to include adequate provisions for granting exceptions to
requalification requirements for individuals disqualified from a covered task due to prolonged
periods of physical, mental, or medical impairment.
DPC’s OQ Plan, section 3.8 stated in part “[n]ote: Disqualification because of a physical, mental,
or medical impairment may not require remediation and re-qualification.”
During the inspection, DPC presented its OQ Plan. However, the OQ Plan did not clearly define



the conditions under which someone disqualified due to physical, mental, or medical impairment
could either follow specific re-qualification steps or perform a covered task under the direction
and observation of a qualified individual, in accordance with section 192.805(b) and
section 192.805(c).
Therefore, DPC’s written qualification program was inadequate to ensure pipeline safety in
accordance with section 192.805(e). PHMSA proposes that DPC must revise its procedures to
clarify when an individual must be requalified under these circumstances.
Response to this Notice
Please refer to this document and note the response options. Be advised that all material you submit
in response to this enforcement action is subject to being made publicly available. If you believe
that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §
552(b), along with the complete original document you must provide a second copy of the
document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under section 190.211. If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue an Order Directing Amendment. If your plans
or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your
plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Douglas Pipeline Company maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,
Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 1-2025-026-NOA and, for each document you submit,
please provide a copy in electronic format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

12025026NOA_Closure Letter_09102025_(24-295885)_txt.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
VIA ELECTRONIC MAIL TO: restabrook@douglaspipeline.com
September 10, 2025
Mr. Ryan Estabrook, President
Douglas Pipeline Company
901 Castle Shannon Boulevard
Pittsburgh, Pennsylvania 15234
RE: CPF 1-2025-026-NOA
Dear Mr. Estabrook:
From February 22 through July 24, 2024, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
inspected Douglas Pipeline Company’s (DPC) procedures for its pipeline facilities in Shawville,
Pennsylvania. As a result of the inspection, DPC was issued a Notice of Amendment on July 1,
2025, which proposed amendment of your procedures.
DPC submitted its amended procedures on July 31, 2025. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary, and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

12025026NOA_Closure Letter_09102025_(24-295885).pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
VIA ELECTRONIC MAIL TO: restabrook@douglaspipeline.com
September 10, 2025
Mr. Ryan Estabrook, President
Douglas Pipeline Company
901 Castle Shannon Boulevard
Pittsburgh, Pennsylvania 15234
RE: CPF 1-2025-026-NOA
Dear Mr. Estabrook:
From February 22 through July 24, 2024, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
inspected Douglas Pipeline Company’s (DPC) procedures for its pipeline facilities in Shawville,
Pennsylvania. As a result of the inspection, DPC was issued a Notice of Amendment on July 1,
2025, which proposed amendment of your procedures.
DPC submitted its amended procedures on July 31, 2025. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary, and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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