# NORFOLK SOUTHERN RAILWAY-BROSNAN YARD PIPELINE — Notice of Amendment

- **operation:** document
- **citation:** CPF 220116004M
- **title:** NORFOLK SOUTHERN RAILWAY-BROSNAN YARD PIPELINE — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-02-15
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.452(d)(3), 195.452(f)(1), 195.452(f)(8), 195.452(g), 195.452(h)(4), 195.452(i)(2), 195.452(j), 195.452(j)(2), 195.452(l)(1)(ii).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220116004M
**body:**

Notice of Amendment involving NORFOLK SOUTHERN RAILWAY-BROSNAN YARD PIPELINE. PHMSA's enforcement data identifies the cited regulations as 195.452(d)(3),  195.452(f)(1),  195.452(f)(8),  195.452(g),  195.452(h)(4),  195.452(i)(2),  195.452(j),  195.452(j)(2),  195.452(l)(1)(ii). The case was opened on 2011-02-15 and is reported as closed as of 2011-09-08. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220116004M_closure letter_09082011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116004M/220116004M_closure%20letter_09082011.pdf

220116004M_closure letter_09082011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116004M/220116004M_closure%20letter_09082011_text.pdf

220116004M_notice of amendment_02152011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116004M/220116004M_notice%20of%20amendment_02152011.pdf

220116004M_notice of amendment_02152011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116004M/220116004M_notice%20of%20amendment_02152011_text.pdf

220116004M_Operator response_03162011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116004M/220116004M_Operator%20response_03162011.pdf

220116004M_notice of amendment_02152011_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 15, 2011
Mr. Tim Heilig
Vice President of Mechanical Operations
Norfolk Southern Corporation
1200 Peachtree Street NE (Box 184)
Atlanta, Georgia 30309
CPF 2-2011-6004M
Dear Mr. Heilig:
On September 28- 29, 2009, November 30, 2009, and June 29, 2010, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the Norfolk
Southern Corporation (NSC) procedures for its Integrity Management Program in Macon,
Georgia, pursuant to Chapter 601 of 49 United States Code.
On the basis of the inspection, PHMSA has identified apparent inadequacies found in NSC’s
plans or procedures as described below:
1. §195.452 Pipeline integrity management in high consequence areas.
.... (f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions drawn
from results of the integrity assessments, and other maintenance and surveillance
data, and evaluation of consequences of a failure on the high consequence area. An
operator must include, at minimum, each of the following elements in its written
integrity management program:
(1) A process for identifying which pipeline segments could affect a high consequence
area;
§195.452 Pipeline integrity management in high consequence areas.
.... (d) When must operators complete baseline assessments? Operators must complete
baseline assessments as follows:
.... (3) Newly-identified areas. (i) When information is available from the information



analysis (see paragraph (g) of this section), or from Census Bureau maps, that the
population density around a pipeline segment has changed so as to fall within the
definition in §195.450 of a high population area or other populated area, the
operator must incorporate the area into its baseline assessment plan as a high
consequence area within one year from the date the area is identified. An operator
must complete the baseline assessment of any line pipe that could affect the newly-
identified high consequence area within five years from the date the area is
identified.
• Item 1A: §195.452(f)(1)
The Norfolk Southern Pipeline Integrity Management Plan (NSIMP) did not address
how NSC determined the volume of product spilled and the buffer distance it used to
identify pipeline segments that could affect a high consequence area (HCA).
• Item 1B: §195.452(d)(3)
NSC’s procedures were inadequate because Section 2 of the NSIMP did not address
using Census Bureau maps to determine changes in population density. NSC’s
procedures relied solely on the changes in population being reported by personnel who
perform the bi-weekly foot patrols along the pipeline.
2. §195.452 Pipeline integrity management in high consequence areas.
.... (f) What are the elements of an integrity management program?....
.... (3) An analysis that integrates all available information about the integrity of the
entire pipeline and the consequences of a failure (see paragraph (g) of this section);
§195.452 Pipeline integrity management in high consequence areas.
.... (g) What is an information analysis? In periodically evaluating the integrity of
each pipeline segment (paragraph (j) of this section), an operator must analyze all
available information about the integrity of the entire pipeline and the consequences
of a failure. This information includes:
(1) Information critical to determining the potential for, and preventing, damage due
to excavation, including current and planned damage prevention activities, and
development or planned development along the pipeline segment;
(2) Data gathered through the integrity assessment required under this section;
(3) Data gathered in conjunction with other inspections, tests, surveillance and
patrols required by this Part, including, corrosion control monitoring and cathodic
protection surveys; and
(4) Information about how a failure would affect the high consequence area, such as
location of the water intake.
• Item 2: §195.452(g)
NSC’s NSIMP did not adequately address how the nine risk factors in the plan were
evaluated and analyzed to determine the risk.
The regulations require that NSC have procedures to analyze all available information
about the integrity of its pipeline and the consequences of a failure. The NSIMP
indicated that NSC used the Subject Matter Expert (SME) method to analyze the
information, with a Risk Assessment Committee (RAC) performing the analysis. The
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SMEs in the RAC analyzed the pipeline segments and determined the relative
likelihood and consequences of a failure, from low to high, for each of the nine factors
in the NSIMP. While the NSIMP indicated the analysis was based on the knowledge
and experience of the SMEs, and from information from relevant industry
publications, it did not provide details on how this was accomplished.
Also, the NSIMP did not provide a logical, structured, and documented process or
guidelines for how the SME evaluations were performed. And, the NSIMP did not
provide justification or guidance for how the magnitude of relative likelihood and
consequence levels were established.
3. §195.452 Pipeline integrity management in high consequence areas.
.... (f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions drawn
from results of the integrity assessments, and other maintenance and surveillance
data, and evaluation of consequences of a failure on the high consequence area. An
operator must include, at minimum, each of the following elements in its written
integrity management program:
.... (8) A process for review of integrity assessment results and information analysis
by a person qualified to evaluate the results and information (see paragraph (h)(2) of
this section).
• Item 3A: §195.452(f)(8)
The NSIMP did not establish a process for the proper review of integrity assessment
results. While the NSIMP stated that the Manager of Pipeline Operations was to
review risk assessments and included the name of the engineer who witnessed and
approved NSC’s 2006 pressure test, the NSIMP did not include procedures for the
review of integrity assessment results.
• Item 3B: §195.452(f)(8)
NSC’s procedures did not address the qualifications required for the personnel who
reviewed and evaluated the results of NSC’s integrity assessment results and
information analysis. The NSIMP established that the Manager of Pipeline Operations
was to review risk assessments. It also included the name of the engineer who
witnessed and approved NSC’s 2006 pressure test, but the NSIMP did not include the
qualifications needed for the persons who reviewed and evaluated integrity assessment
results and the information analysis.
4. §195.452 Pipeline integrity management in high consequence areas.
.... (f) What are the elements of an integrity management program? ....
.... (4) Criteria for remedial actions to address integrity issues raised by the
assessment methods and information analysis (see paragraph (h) of this section);
§195.452 Pipeline integrity management in high consequence areas.
.... (h) What actions must an operator take to address integrity issues?
.... (4) Special requirements for scheduling remediation.
(i) Immediate repair conditions. An operator’s evaluation and remediation schedule
3



must provide for immediate repair conditions. To maintain safety, an operator must
temporarily reduce the operating pressure or shut down the pipeline until the
operator completes the repair of these conditions. An operator must calculate the
temporary reduction in operating pressure using the formula in section 451.7 of
ASME/ANSI B31.4 (incorporated by reference, see § 195.3), if applicable. If the
formula is not applicable to the type of anomaly or would produce a higher
operating pressure, an operator must use an alternative acceptable method to
calculate a reduced operating pressure. An operator must treat the following
conditions as immediate repair conditions:
(A) Metal loss greater than 80% of nominal wall regardless of dimensions.
(B) A calculation of the remaining strength of the pipe shows a predicted burst
pressure less than the established maximum operating pressure at the location of the
anomaly. Suitable remaining strength calculation methods include, but are not
limited to, ASME/ANSI B31G (“Manual for Determining the Remaining Strength of
Corroded Pipelines” (1991) or AGA Pipeline Research Committee Project PR-3-805
(“A Modified Criterion for Evaluating the Remaining Strength of Corroded Pipe”
(December 1989)). These documents are available at the addresses listed in §195.3.
(C) A dent located on the top of the pipeline (above the 4 and 8 o’clock positions)
that has any indication of metal loss, cracking or a stress riser.
(D) A dent located on the top of the pipeline (above the 4 and 8 o’clock positions)
with a depth greater than 6% of the nominal pipe diameter.
(E) An anomaly that in the judgment of the person designated by the operator to
evaluate the assessment results requires immediate action.
• Item 4: §195.452(h)(4)(i)
The NSIMP did not address how NSC would determine the temporary reduced
operating pressure for an “immediate repair condition” on its pipeline or explain
under what circumstances NSC would shut down the pipeline in lieu of taking a
temporary pressure reduction.
The regulations in §195.452(h)(4)(i)(A) - (E) define five “immediate repair
conditions,” which require an operator to have procedures to determine and
implement a temporary pressure reduction, or to shut down the pipeline, until the
“immediate repair condition” can be repaired. While the NSIMP addressed a
reduction of pressure in the possible responses for some anomalous conditions in
Figure 8-1(Anomalous Conditions & Responses), it did not provide guidance nor
specifics on how NSC would determine the pressure reduction for each of the five
“immediate repair conditions.”
5. §195.452 Pipeline integrity management in high consequence areas.
.... (f) What are the elements of an integrity management program? ....
.... (6) Identification of preventive and mitigative measures to protect the high
consequence area (see paragraph (i) of this section);
§195.452 Pipeline integrity management in high consequence areas.
(i) What preventive and mitigative measures must an operator take to protect the high
consequence area?
.... (2) Risk analysis criteria. In identifying the need for additional preventive and
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mitigative measures, an operator must evaluate the likelihood of a pipeline release
occurring and how a release could affect the high consequence area. This
determination must consider all relevant risk factors, including, but not limited to:
• Item 5: §195.452(i)(2)
NSC’s NSIMP did not have adequate procedures to identify preventative and
mitigative measures based on a risk analysis.
The regulations require an operator to have procedures to identify and evaluate
preventative and mitigative measures based on an analysis of the relevant risk factors.
The NSIMP contains a framework structure that states in Section 6, PREVENTATIVE
AND MITIGATIVE MEASURES, that “The Subject Matter Expert Team will develop
the guidelines to develop Preventative and Mitigative Measures required under this
section of the Integrity management Plan.” The NSIMP, however, did not include the
“guidelines” that the Subject Matter Expert Team were required to develop.
6. §195.452 Pipeline integrity management in high consequence areas.
.... (f) What are the elements of an integrity management program?....
§195.452 Pipeline integrity management in high consequence areas.
.... (j) What is a continual process of evaluation and assessment to maintain a pipeline's
integrity?
.... (2) Evaluation. An operator must conduct a periodic evaluation as frequently as
needed to assure pipeline integrity. An operator must base the frequency of
evaluation on risk factors specific to its pipeline, including the factors specified in
paragraph (e) of this section. The evaluation must consider the results of the baseline
and periodic integrity assessments, information analysis (paragraph (g) of this
section), and decisions about remediation, and preventive and mitigative actions
(paragraphs (h) and (i) of this section).
• Item 6A: §195.452(j)(2)
NSC’s NSIMP did not have adequate procedures to address how NSC would conduct
a periodic evaluation as frequently as needed to assure pipeline integrity and that such
an evaluation would consider the results of the baseline and periodic integrity
assessments, information analysis, decisions about remediation, and preventive and
mitigative actions. Moreover, the procedures did not address the use of risk factors
specific to the pipeline to establish the frequency of the evaluation.
The NSIMP contains a framework structure and stated in Section 5, REASSESSMENT
PLANS, that “…the Subject Matter Expert Method described in Section 4 of the
Integrity Management Plan” is also used to “develop Reassessment Plans.” The
NSIMP also discussed operations and maintenance activities (listed as existing
preventative and mitigative measures), but the NSIMP did not establish procedures to
address how NSC would perform a periodic evaluation of the pipeline or how the
frequency of the evaluation would be established.
5



• Item 6B: §195.452(j)(2)
NSC’s NSIMP did not have adequate procedures to review its corrosion control
program as part of its consideration of the risk factors required to establish the
frequency of the required periodic evaluation of the pipeline or for the information
analysis that must be considered as part of the periodic evaluation.
NSC used hydrostatic pressure testing to assess its pipeline but did not include a
comprehensive review of its corrosion control program in the NSIMP, Section 5 -
REASSESSMENT PLANS.
7. §195.452 Pipeline integrity management in high consequence areas.
.... (l) What records must be kept? (1) An operator must maintain for review during
an inspection:
.... (ii) Documents to support the decisions and analyses, including any modifications,
justifications, variances, deviations and determinations made, and actions taken, to
implement and evaluate each element of the integrity management program listed in
paragraph (f) of this section.
NSC’s procedures did not address maintaining documents that support the decisions,
analysis, justifications, modifications, and actions taken to implement and evaluate
each element of its NSIMP.
While the NSIMP provided basic guidance to retain Risk Assessment reviews
(NSIMP Section 4) and program evaluation reviews (NSIMP Section 7), the NSIMP
did not address maintaining documents to support its integrity management program
decisions and analysis nor other required items.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. 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). 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 a Final Order.
6



If, after opportunity for a hearing, 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 within 120 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.
In correspondence concerning this matter, please refer to CPF 2-2011-6004M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
7

220116004M_closure letter_09082011_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 8, 2011
Mr. Tim Heilig
Vice President of Mechanical Operations
Norfolk Southern Corporation
1200 Peachtree Street NE (Box 184)
Atlanta, GA 30309
CPF 2-2011-6004M
Dear Mr. Heilig:
On September 28- 29, 2009, November 30, 2009, and June 29, 2010, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the Norfolk
Southern Corporation (NSC) procedures for its Integrity Management Program (IMP) in
Macon, Georgia, pursuant to Chapter 601 of 49 United States Code. On the basis of the
inspection, PHMSA identified apparent inadequacies in NSC’s IMP plans or procedures and
issued a Notice of Amendment (NOA) on February 15, 2011.
In late August 2011, PHMSA received letters from NSC and Buckeye Development &
Logistics, LLC (Buckeye) confirming that as of July 1, 2011, Buckeye is the operator of the
Macon pipeline and that the Macon pipeline will be incorporated into Buckeye’s IMP.
The NOA referenced above required NSC to amend certain written procedures in its written
IMP. Since NSC is no longer the operator of the pipeline and because the pipeline will be
incorporated into Buckeye’s IMP, such amendments are now moot. Therefore, no further
action is necessary with regards to the NOA and this case is now closed.
Please be advised that this letter refers only to the NOA (CPF 2-2011-6004M) and not to any
other PHMSA pending cases. Also be advised that nothing herein states or implies that the
above described Buckeye IMP meets the requirements of the federal pipeline safety
regulations or that the Buckeye IMP is approved. The pipeline system and Buckeye’s written
IMP remain subject to inspection by PHMSA.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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