{"operation":"document","citation":"CPF 220115004M","title":"MARKWEST RANGER PIPELINE COMPANY, L.L.C. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-03-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(13), 195.505(c), 195.571, 195.577(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220115004M","body":"Notice of Amendment involving MARKWEST RANGER PIPELINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(13),  195.505(c),  195.571,  195.577(a). The case was opened on 2011-03-14 and is reported as closed as of 2011-06-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220115004M_closure letter_06142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115004M/220115004M_closure%20letter_06142011.pdf\n\n220115004M_closure Letter_06142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115004M/220115004M_closure%20Letter_06142011_text.pdf\n\n220115004M_notice of amendment_03142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115004M/220115004M_notice%20of%20amendment_03142011.pdf\n\n220115004M_notice of amendment_03142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115004M/220115004M_notice%20of%20amendment_03142011_text.pdf\n\n220115004M_Operator response_04222011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115004M/220115004M_Operator%20response_04222011.pdf\n\n220115004M_closure Letter_06142011_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 14, 2011\nJohn C. Mollenkopf\nSr. Vice President and COO\nMarkWest Energy Appalachia, LLC\n1515 Arapahoe Street, Tower 2, Suite 700\nDenver, CO 80202\nCPF 2-2011-5004M\nDear Mr. Mollenkopf:\nBetween November 29 and December 3, 2010, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected the MarkWest Energy Appalachia, LLC\n(MarkWest) procedural manual for operations, maintenance, and emergencies at your office\nin Ashland, Kentucky, pursuant to Chapter 601 of 49 United States Code. As a result of the\ninspection, PHMSA issued a Notice of Amendment (NOA) to MarkWest on March 14, 2011.\nThe PHMSA Southern Region received MarkWest’s initial response to the NOA in a letter\ndated April 22, 2011. On May 3, 2011, we explained to you by return letter that we had\nreviewed the initial response to the NOA and found it inadequate. We have since received\nand reviewed MarkWest’s second response to the NOA dated May 26, 2011.\nThis letter is to inform you that MarkWest has complied with the terms of the NOA and that\nno further action is necessary with regards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2011-5004M) and not to any\nother PHMSA pending cases. Also be advised that nothing herein states or implies that the\nabove described procedural manual meets the requirements of the federal pipeline safety\nregulations or that the procedural manual is approved. The MarkWest pipeline system and the\nprocedural manual remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220115004M_notice of amendment_03142011_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 14, 2011\nJohn C. Mollenkopf,\nSr. Vice President and COO\nMarkwest Energy Appalachia, LLC\n1515 Arapahoe Street, Tower 2, Suite 700\nDenver, CO 80202\nCPF 2-2011-5004M\nDear Mr. Mollenkopf:\nBetween November 29 and December 3, 2010, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected the Markwest Energy Appalachia, LLC\n(Markwest) procedural manual for operations, maintenance, and emergencies at your pipeline\noffice in Ashland, Kentucky, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within\nMarkwest’s procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n… (c) Maintenance and normal operations. The manual required by paragraph\n(a) of this section must include procedures for the following to provide safety\nduring maintenance and normal operations:\n… (13) Periodically reviewing the work done by operator personnel to determine\nthe effectiveness of the procedures used in normal operation and maintenance\nand taking corrective action where deficiencies are found.\nMarkwest's operations and maintenance (O&M) procedures were inadequate because\nthey did not include specific procedure(s) covering the periodic review of work done\nby Markwest or contractor personnel to determine the effectiveness of the procedures\nused in maintenance and operations, and for taking corrective action if and when\ndeficiencies were found.\nIn discussions with the operator during the inspection, it appeared the operator was\nhaving difficulties differentiating personnel performance from the effectiveness of the\nO&M procedures themselves.\n\n\n\n2. § 195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The\nprogram shall include provisions to:\n… (c) Allow individuals that are not qualified pursuant to this subpart to\nperform a covered task if directed and observed by an individual that is\nqualified;\nMarkwest’s Operator Qualification (OQ) procedures were inadequate because\nMarkwest did not include provisions to allow individuals that are not OQ qualified to\nperform a covered task, if directed, and observed by an individual that is OQ qualified.\nSpecifically, Markwest did not address in its procedures the unique factors that\ninfluence the span of control for each covered task, but instead applied a span of\ncontrol of 7-to-1 to all covered tasks.\n3. § 195.571 What criteria must I use to determine the adequacy of cathodic\nprotection?\nCathodic protection required by this Subpart must comply with one or more of\nthe applicable criteria and other considerations for cathodic protection contained\nin paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference, see\n§195.3).\nMarkwest’s corrosion control procedures were inadequate because they did not\nexplain how Markwest would consider voltage drops (other than those across the\nstructure-to-electrolyte boundary) in its annual cathodic protection survey pipe-to-soil\nreadings. NACE SP0169–2007 Section 6.2.2.1.1 requires consideration be given to\nthese voltage drops for valid interpretation of the voltage measurement.\n4. § 195.577 What must I do to alleviate interference currents?\n(a) For pipelines exposed to stray currents, you must have a program to identify,\ntest for, and minimize the detrimental effects of such currents.\nMarkwest’s corrosion control procedures for alleviating interference currents related\nto AC current interference were inadequate because they did not specify what\nMarkwest considers as an acceptable level of AC current interference or the steps it\nwould take to minimize the detrimental effects of such interference currents.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 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\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\n2\n\n\n\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\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 30 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that Markwest maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to Wayne T. Lemoi, Director, Southern Region,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 2-2011-5004M and, for each document you submit, please\nprovide a copy in electronic format whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":9050}