{"operation":"document","citation":"CPF 220086003M","title":"TPM, INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-08-21","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(7), 195.452(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220086003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220086003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220086003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220086003M","body":"Notice of Amendment involving TPM, INC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(7),  195.452(i). The case was opened on 2008-08-21 and is reported as closed as of 2009-03-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220086003M_notice of amendment_08212008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220086003M/220086003M_notice%20of%20amendment_08212008.pdf\n\n220086003m_notice of amendment_08212008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220086003M/220086003m_notice%20of%20amendment_08212008_text.pdf\n\n220086003m_notice of amendment_08212008_text.pdf\n\nU. S. Depahment\nof Transportation\nI'ipeilne ana\nActministratlon\n233 Peachtree Street Ste. 600\nAtlanta, GA 30303\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nAugust 21, 2008\nMr. Larry F. Clynch\nChairman\nTPM Incorporated\nP 0 Box 486\nAlpharetta, GA 30009-0486\nCPF 2-2008-6003M\nDear Mr, Clynch:\nOn May 27-30, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\nTPM Inc. Integrity Management Plan in Memphis, Tennessee.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nthe TPM Integrity Management Plan (IMP), as described below:\n195. 452(i) What preventive and mitigative measures must an operator take to\nprotect the high consequence area?\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline release\noccurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited to\n195. 452(i)(2)(i) thru 195. 452(i)(2)(viii) risk factors.\nTPM has contracted with American Innovations to perform a risk assessment of the\npipeline system ei ery three years. TPM must amend its IMP to consider all relevant risk\nfactors in performing the risk analysis process. The current IMP does not adequately\naddress the risk analysis process in a manner that considers:\n~ Determination of the most effective mitigation measures for identified threats;\n~ Assessment of the integrity impact from modified inspection intervals;\n~ Assessment of the use of or need for alternative inspection methodologies; or\n~ Facilitation of decisions to address risks along a pipeline or within a facility.\n\n\n\n2. 192. 452(f) What are the elements of an integrity management program?\n(7) Methods to measure the program's effectiveness.\nTPM lacked adequate documentation of the process to evaluate and measure the\nprogram's effectiveness in assessing and evaluating pipeline integrity and in protecting\nthe high consequences areas.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S. C. Il 60108(a) and 49 C. F. R. II 190. 237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U. S. C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C. F. R. II 190. 237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 45 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 2-2008-6003M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":4864}