MARKWEST RANGER PIPELINE COMPANY, L.L.C. — Notice of Amendment

party submissionOfficial PDF220075004M_Operator Response_06202007.pdf#

220075004m_notice letter_05022007_text.pdf, page 1Official PDFU 5 Department of Transportation Pipeline and Hazardous Materlats Safety Administration NOTICE OF AMENDMENT 233 Peachtrse Street Ste 600 Atlanta, GA 30303 CERTIFIED MAIL - RETURN RECEIPT RE UESTED May 2, 2007 Mr John Mollenkopf Senior Vice President and Clnef Operations Officer MarkWest Hydrocarbon, Inc 1515 Arapahoe Street, Tower 2, Suite 700 Denver, CO 80202 CPF 2-2007-5004M Dear Mr Mollenkopf Between December 5 and December 9, 2005, a representative of the Pipehne and Hazardous Matenals Safety Admuustration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected MarkWest Hydrocarbon, Inc (MarkWest) procedures for operation and maintenance in Kenova, West Virginia On the basis of the inspection, PHMSA has identified the apparent inadequacies found within MarkWest's plans or procedures, as descrtbed below I'1195 402 Procedural manual for operations, maintenance, and emergencies. (a) Genera/ Each operator shall prepare and follow for each pipehne system a manual of written procedures for conductmg normal operations and maintenance activities and handbag abnormal operations and emergencies. tt195. 214 Welding procedures. (a) Welding must be performed by a qualified welder in accordance with weldmg procedures quahfied under Section 5 of API 1104 or Section IX of the ASME Boder and Pressure Vessel Code (incorporated by reference, see tt 195. 3) The quality of the test welds used to quahfy the welding procedure shall be determined by destructive teshng. A. MarkWest welding procedures are incorrect Operations, Jtfamtenance, and Emergencies Manual (OM&E Manual) Section 6 5 references Section 2 of API 1104, mstead of Section 5 It is also noted that OM&E Manual Section 6 5 similarly incorrectly references other sections of API 1104 See III' 195 222(a), 195 234(b), and 195 230 to correct these inadequacies#

220075004m_notice letter_05022007_text.pdf, page 2$195. 310 Records. (a) A record must be made of each pressure test required by this subpart, and the record of the latest test must be retamed as long as the facility tested is m use. (b) The record required by paragraph (a) of this section must include. . . . . . (10) Temperature of the test medium or pipe during the test period. B. OM&E Manual Section 6 6 Hydrostatic Test Requirements does not require the temperature of the test medium or pipe to be recorded during the test period 2. t)195. 402 Procedural manual for operations, maintenance, and emergencies. . . . (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during mamtenance and normal operations. . (10) Abandoning pipehne facilities, mcludmg safe disconnection from an operating pipehne system, purgmg of combustibles, and seahng abandoned facdities left in place to minimize safety and environmental hazards. For each abandoned offshore pipehne facdity or each abandoned onshore pipehne facility that crosses over, under or through commercially navigable waterways the last operator of that facihty must file a report upon abandonment of that facility in accordance with $195. 59 of this part. OM&E Manual Section 7 5 Abandonment or Deactivation of Facihties aud Form 102 MarkWest Abandonment or Deactivation of Facilities are inadequate in that they do not differentiate between abandonment and deactivation Deactivation is not defined aud procedures do not specify the conditions under which operation and/or maintenance requirements, such as leak surveys, cathoChc protection, pubhc awareness programs, etc, can be terminated on deactivated pipelmes (1195. 402 Procedural manual for operations, maintenance, and emergencies. . . . (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: . . . (13) Periodically reviewmg the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and talung corrective action where deficiencies are found. MarkWest procedures do not address the requirement to determine the effect(veness of 9 d . 4 d 1!(193402()(13) OM&E M 1 9 I 79 7 g conveys the followtug Once per year and at intervals not to exceed fifteen months, MarkWest shall evaluate the program's effect(veness m achieving its oblectfves by reviewing personnel performance Make any appropmate changes to the trammg program as necessary to ensure its effectiveness#

220075004m_notice letter_05022007_text.pdf, page 34. ('l195. 402 Procedural manual for operahons, maintenance, and emergencies. . . . (e) Emergencies. The manual required by paragraph (a) of this section must mclude procedures for the following to provide safety when an emergency condition occurs; . . . (3) Having personnel, equipment, instruments, tools, and material avadable as needed at the scene of an emergency MarkWest procedures do not require personnel to have hand tools and flame retardant clothing available at the scene of an emergency These items are necessary, based on conversation with MarkWest employees 5. (t195. 402 Procedural manual for operations, mamtenance, and emergencies. (e) Emergencres. The manual required by paragraph (a) of this section must mclude procedures for the following to provide safety when an emergency condition occurs, . . . (8) In the case of fadure of a pipehne system transporting a highly volatile liquid, use of appropriate mstruments to assess the extent and coverage of the vapor cloud and determine the hazardous areas. MarkWest procedures do not adequately address the requirement to assess the extent and coverage of a vapor cloud and determine the hazardous areas OM&E Manual Section 5 1 5 (b) requires the use of detection instruments to determine the concentration of HVL vapors in the area, but does not provide adequate detiuls on how tins will be done MarkWest procedures does not address how to determine the potential cloud location, size, dispersion, and movement so that a monitonng plan with insixuments can be developed and implemented to identify the cloud coverage and hazard areas Use of information such as terram elevations, underground drainage systems, weather and wind information, spdl volume, and length of time since release are not mcluded in the procedures The number of available detection instruments and personnel should reflect the reqmrements of the plan Below is an excerpt from OM&E Manual Section 5 1 5 (b) 2 combustrble gas mdrcator or "flame romzatron gas detector" shall be used by a qualrflied Marks'est employee to determine the concentratron of HVL vapors m the area ln the mstance where flammable highly volatile liqurds are present, the supervisor shall use an "explosrmeter" to determme the extent and coverage of the vapor cloud and determine the hazardous areas ('t195. 402 Procedural manual for operahons, maintenance, and emergencies. . . . (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:#

220075004m_notice letter_05022007_text.pdf, page 4. . . (3) Operating, maintaining, and repairing the pipehne system m accordance with each of the requirements of this subpart and subpart H of this part. (1195. 408 Communications (b) The communication system required by paragraph (a) of this section must, as a minimum, include means for: . . . (3) Conductmg two-way vocal communication between a control center and the scene of abnormal operations and emergencies . . A. The Kenova cell phone number is not hsted on the Kenova emergency call list (OM&E Manual Section 11 2 2) The number was recommended to be distributed in a 2004 Abnormal Condition Review (1195. 426 Scraper and sphere facilities No operator may use a launcher or receiver that is not equipped with a relief device capable of safely relievmg pressure in the barrel before msertion or removal of scrapers or spheres The operator must use a suitable device to mdicate that pressure has been reheved m the barrel or must provide a means to prevent msertion or removal of scrapers or spheres if pressure has not been relieved m the barrel. B. MarkWest procedures do not adequately address the reqmrements of $195 426, as indicated m the following excerpt from OM&E Manual Section 7 11 The excerpt only apphes to launchers and receivers with vent valves, whereas $195 426 apphes to all launchers and receivers Also, allowing personnel to monitor the vent valve for audible and visual mdications to insure the pressure has been reheved before openmg the barrel to install or remove scrapers or spheres does not satisfy the requirement to use a suitable device, such as a pressure gauge, to indicate that pressure has been reheved For pipelmes havmg scraper and sphere launchmg and receiving facthttes with vent valves to depressurtze the barrel, operators shall either momtor the vent valve for audible and visual mdications, or install and observe pressure readmgs on a pressure gauge, to insure the pressure has been reheved before opemng the barrel to mstall or remove scrapers or spheres (1195. 430 Firefighting equipment. Each operator shall maintain adequate firefighttng equipment at each pump station and breakout tank area. The equipment must be- (a) In proper operahng condihon at all times; (b) Plainly marked so that its identity as firefighting equipment is clear; and (c) Located so that it is easily accessible during a fire. C. MarkWest procedures do not require adequate fire fighting equipment to be maintained at Kenova pump station, as required of 195 430#

220075004m_notice letter_05022007_text.pdf, page 5(l195. 444 CPM leak detection Each computational pipehne monitonng (CPM) leak detection system installed on a hazardous hquid pipeline transporting liquid in single phase (without gas m the hquid) must comply with API 1130 in operatmg, maintaming, testing, record keeping, and dispatcher training of the system. D. MarkWest procedures are not adequately descnptive OM&E Manual Section 6 I mimics the regulations, does not convey that MarkWest's recently installed SCADA system is a CPM system, and does not state the apphcable requirements of the referenced section of API 1130 Excerpt from OM&E Manual Section 6 11 is hsted below This section applies to each hazardous hquid pipelme transportmg hquid in smgle phase (without gas m the liquid) On such systems, each new computational pipelme momtoring (CPM) leak detection system and each replaced component of an existing CPM system shall comply with Section 4 2 of API 1130 m its design and with any other design cntena addressed in API 1130 for components of the CPM leak detection system tt195 559 What coating material may I use for external corrosion controlo Coating material for external corrosion control under t'l195. 557 must- (a) Be designed to mitigate corrosion of the buried or submerged pipeline; (b) Have sufficient adhesion to the metal surface to prevent under film migration of moisture; (c) Be sufficiently ductile to resist cracking; (d) Have enough strength to resist damage due to handhng and sod stress; (e) Support any supplemental cathodic protection; and (I) If the coating is an insulating type, have low moisture absorption and provide high electrical resistance. E. External protective coatmg procedures (OM&E Manual Sections 647 and 9 3) mimic the regulations, are very general, and do not provide a hst of approved coating products and stated applications and restrictions OM&E Manual Section 9 3 allows for coatings to be such as 'thm film epoxy", TGF-3, or any other acceptable coatmg Jomts, fittmgs, and tie-ms shall be coated with materials compatible with the coating on the pipe " ('1195. 573 What must I do to monitor external corrosion control" (a) Protected pipelines. You must do the followmg to determine whether cathodic protection required by this subpart complies with 11195. 571:#

220075004m_notice letter_05022007_text.pdf, page 6. . . (2) Identify before December 29, 2003 or not more than 2 years after cathodic protection is installed, whichever comes later, the circumstances in which a close-interval survey or comparable technology is practicable and necessary to accomphsh the ob)ecttves of paragraph 10 1. 1. 3 of NACK Standard RP0169-96 (incorporated by reference, see (t195. 3) F. MarkWest procedures do not convey the circumstances in winch a close-interval survey or comparable technology is practicable and necessary to accomplish the objectives of paragraph 10 1 1 3 of NACE Standard RP0169-96 For protected pipehnes, OM&E Manual Section 9 2 2 indicates the ob]ecttves of NACE Standard RP0169-96 $10 1 1 3 are to be met not more than two years after cathodic protection is mstalled No applicable identified circumstances are found in the procedures (t195. 573 What must I do to monitor external corrosion control? . . . (b) Unprotected pipe. You must reevaluate your unprotected buried or submerged pipe and cathodically protect the pipe m areas in which active corrosion is found, as follows: (1) Determine the areas of active corrosion by electrical survey, or where an electrical survey is impractical, by other means that include review and analysis of leak repair and inspection records, corrosion monitoring records, exposed pipe inspection records, and the pipeline environment. Selected definitions &om (t195. 553 What special definitions apply to this subpart" Active corrosion means contmuing corrosion which, unless controlled, could result in a condition that is detrimental to public safety or the environment. Electrical survey means a series of closely spaced pipe-to-sod readings over a pipehne that are subsequently analyzed to identify locations where a corrosive current is leaving the pipelme. G. MarkWest procedures are not specific in how MarkWest determines areas of active corrosion Procedures do not convey ~secific cntena used in deternumng the areas where active corrosion, unless controlled, could result in a condition that is detrimental to pubhc safety The procedures convey that consideration should be given to those areas near people, homes, budihngs, road crossings, and pipeline operating pressures, and that boundanes of Active Corrosion Zones will be determined, however, no specific cntena was found as to how these areas are estabhshed Excerpts from OM&E Manual Section 3 1 Definitions Active Corrosion — Continutng corrosion, which could, unless controlled, result in a condition that is detrimental to pubhc safety Consideration should be given to those areas near people, homes, buildings, road crossings, and pipeline operating pressures Active Corrosion Zone — An area where the pubhc could be exposed to hazards caused by active corroston Boundanes of other "Active Corrosion Zones" wtll be deterintned by an Engineermg Services Prpeltne/CorrostonlPtpehne Safety Engineer This method will not apply to pipehnes under cathodic protection#

220075004m_notice letter_05022007_text.pdf, page 7It195. 573 What must 1 do to monitor external corrosion controlo . . (e) Correct~re action. You must correct any identified deficiency m corrosion control as required by tj195. 401(b) tj195. 401 General requirements. (b) Whenever an operator discovers any condition that could adversely affect the safe operation of its pipeline system, it shall correct it withm a reasonable time. . . . H. MarkWest procedures do not convey the time allowed to correct a condition (that could adversely affect the safe operation of the pipehne) discovered while performing annual corrosion monitoring surveys OM&E Manual Section 9121 conveys If adequate protection ts not indicated, correcttve steps shall be taken to restore the structure to the proper degree of protect~on Procedures do not address how much time is allowed to correct the condition 7 It195. 505 Qualdication program Each operator shall have and follow a written quahfication program. The program shall include provisions to: . . . (b) Ensure through evaluation that individuals performmg covered tasks are qualified, tj195. 509 General . . . (e) After December 16, 2004, observation of on-the-job performance may not be used as the sole method of evaluation. A. MarkWest's Operator Quahfication Program (rev January, 2005) does not include provisions to ensure through evaluauon that individuals performing covered tasks are quahfied The program does not convey that after December 16, 2004, observation of on-the-Job performance may not be used as the sole method of evaluation . . . (h) After December 16, 2004, provide trainmg, as appropriate, to ensure that mdividuals performing covered tasks have the necessary knowledge and slulls to perform the tasks in a manner that ensures the safe operation of pipehne facdities . B. MarkWest's Operator Quahfication Program (rev January, 2005) does not include provisions for training, as appropnatc, as required of II195 505(h) (i) After December 16, 2004, notify the Administrator or a state agency participating under 49 U. S. C Chapter 601 if the operator significantly modifies the program after the Admmistrator or state agency has verified that it comphes with this section.#

220075004m_notice letter_05022007_text.pdf, page 8C. MarkWest's Operator Quahfication Program (rev January, 2005) does not include provisions to notify the Admiiustrator or a state agency as reqmred of tt195 505(i) Res onse to this Notice This Notice is provided pursuant to 49 U S C ) 60108(a) and 49 C F R IJ 190 237 Enclosed as part of this Notice is a document entitled Response Opt~one for Pipelme Operators in Compliance Proceedmgs Please refer to ttus document and note the response options Be advised that all material you submit in response to this enforcement action is sub)ect to being made publicly available If you beheve that any portion of your responsive material quahfies for confidential treatment under 5 U S C 552(b), along with the complete onginal document you must provide a second copy of the document with the portions you believe quahfy for confidential treatment redacted and an explanation of why you beheve the redacted information quahfies for confidential treatment under 5 U S C 552(b) If you do not respond vntlun 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 Pipehne Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order If, after opportunity for a hearmg, 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 C F R $ 190 237) If you are not contesting this Notice, we propose that you submit your amended procedures to my office witlun 60 days of receipt of tins Notice This period may be extended by wntten request for good cause Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed In correspondence concermng this matter, please refer to CPF 2-2007-5004M and, for each document you submit, please provide a copy in electronic format whenever possible Sincerely, Linda Daugherty Director, Southern Region Pipehne and Hazardous Materials Safety Administration Enclosure Response Options for Pipelme Operators m Comphance Proceedmgs#