{"operation":"document","citation":"CPF 220120005M","title":"ECOELECTRICA L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-10-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.453, 192.459, 192.467(a), 192.475(b), 192.485(a), 192.485(b), 192.485(c), 192.605(b)(11), 192.605(c)(1), 192.605(c)(2), 192.605(c)(3), 192.619(a)(1), 192.719(a), 192.805(a), 192.805(b), 192.805(c), 192.805(d), 192.805(e), 192.805(f), 192.805(g), 192.805(h), 192.805(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220120005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220120005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220120005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220120005M","body":"Notice of Amendment involving ECOELECTRICA L.P.. PHMSA's enforcement data identifies the cited regulations as 192.453,  192.459,  192.467(a),  192.475(b),  192.485(a),  192.485(b),  192.485(c),  192.605(b)(11),  192.605(c)(1),  192.605(c)(2),  192.605(c)(3),  192.619(a)(1),  192.719(a),  192.805(a),  192.805(b),  192.805(c),  192.805(d),  192.805(e),  192.805(f),  192.805(g),  192.805(h),  192.805(i). The case was opened on 2012-10-17 and is reported as closed as of 2013-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220120005M_Closure letter_05202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120005M/220120005M_Closure%20letter_05202013.pdf\n\n220120005M_Closure letter_05202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120005M/220120005M_Closure%20letter_05202013_text.pdf\n\n220120005M_notice of amendment_10172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120005M/220120005M_notice%20of%20amendment_10172012.pdf\n\n220120005M_notice of amendment_10172012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120005M/220120005M_notice%20of%20amendment_10172012_text.pdf\n\n220120005M_Operator Response_11162012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120005M/220120005M_Operator%20Response_11162012.pdf\n\n220120005M_notice of amendment_10172012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 17, 2012\nMr. Carlos Reyes\nCo-President & General Manager Operations\nEcoElectrica L.P.\nStreet 337, KM 3.7 Bo Tallaboa Poniente\nPenuelas, PR 00624\nCPF 2-2012-0005M\nDear Mr. Reyes:\nBetween April 23 and 27, 2012, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Southern Region, Office of Pipeline Safety inspected\nthe EcoElectrica, L.P. (EcoElectrica) operations, maintenance, and emergency response\n(OMER) manual of written procedures for the Costa Sur Pipeline in Penuelas,\nPuerto Rico, pursuant to Chapter 601 of 49 United States Code. The representative\ninitiated the inspection on site during the above described dates and completed the\ninspection of the OMER in the PHMSA Southern Region office subsequent to the on-site\nvisit.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within\nEcoElectrica’s OMER manual of written procedures, as described below:\n1. §192.453 General.\nThe corrosion control procedures required by §192.605(b)(2), including those for the\ndesign, installation, operation, and maintenance of cathodic protection systems, must\nbe carried out by, or under the direction of, a person qualified in pipeline corrosion\ncontrol methods.\nEcoElectrica’s OMER procedures did not describe, in the detail required, the\nqualifications of the person(s) responsible for the design, installation, operation, and\nmaintenance of cathodic protection systems.\n\n\n\nEcoElectrica’s OMER Manual Section III n) Corrosion Protection stated, “Regulations\nrequire corrosion control procedures for the design, installation, operation, and\nmaintenance of cathodic protection systems, be under the direction of a person qualified\nin pipeline corrosion control methods.” However, the procedures did not convey a) the\nspecific required qualifications of the person(s) (i.e. skills, education, training, and\nexperience) that are commensurate with the difficulty and importance for control of\nexternal, internal, and atmospheric corrosion; and, b) the documentation required to\nsubstantiate such qualifications, including maintaining the documentation (records).\n2. §192.459 External corrosion control: Examination of buried pipeline when exposed.\nWhenever an operator has knowledge that any portion of a buried pipeline is\nexposed, the exposed portion must be examined for evidence of external corrosion if\nthe pipe is bare, or if the coating is deteriorated. If external corrosion requiring\nremedial action under §§192.483 through 192.489 is found, the operator shall\ninvestigate circumferentially and longitudinally beyond the exposed portion (by\nvisual examination, indirect method, or both) to determine whether additional\ncorrosion requiring remedial action exists in the vicinity of the exposed portion.\nEcoElectrica’s OMER did not contain written procedures requiring EcoElectrica, when it\nhas knowledge that any portion of its buried pipeline is exposed, to examine the exposed\nportion for evidence of external corrosion if the pipe is bare, or for coating deterioration if\nit is coated. Moreover, there were no procedures requiring EcoElectrica to take remedial\naction(s) under §§192.483 through 192.489 if external corrosion is found. Also, there\nwere no procedures requiring EcoElectrica to investigate circumferentially and\nlongitudinally beyond the exposed portion of the buried pipeline (by visual examination,\nindirect method, or both) to determine whether additional corrosion requiring remedial\naction exists in the vicinity of the exposed portion.\n3. §192.467 External corrosion control: Electrical isolation.\n(a) Each buried or submerged pipeline must be electrically isolated from other\nunderground metallic structures, unless the pipeline and the other structures are\nelectrically interconnected and cathodically protected as a single unit.\nEcoElectrica’s OMER did not contain written procedures to ensure that each buried or\nsubmerged pipeline be electrically isolated from other underground metallic structures,\nunless the pipeline and the other structures are electrically inter-connected and\ncathodically protected as a single unit.\n4. §192.475 Internal corrosion control: General.\n. . . (b) Whenever any pipe is removed from a pipeline for any reason, the internal\nsurface must be inspected for evidence of corrosion. If internal corrosion is found–\n(1) The adjacent pipe must be investigated to determine the extent of internal\ncorrosion:\n(2) Replacement must be made to the extent required by the applicable paragraphs\nof §§192.485, 192.487, or 192,489; and,\n(3) Steps must be taken to minimize the internal corrosion.\nEcoElectrica’s OMER procedures did not require EcoElectrica to inspect for evidence of\ninternal corrosion whenever any pipe is removed from its pipeline for any reason. The\n2\n\n\n\nprocedures also did not require EcoElectrica to investigate the adjacent pipe to determine\nthe extent of internal corrosion, to replace the pipe to the extent required by the applicable\nparagraphs of §§192.485, 192.487, or 192,489; and, to take steps to minimize the internal\ncorrosion if internal corrosion is found.\n5. §192.485 Remedial measures: Transmission lines.\n(a) General corrosion. Each segment of transmission line with general corrosion and\nwith a remaining wall thickness less than that required for the MAOP of the pipeline\nmust be replaced or the operating pressure reduced commensurate with the strength\nof the pipe based on actual remaining wall thickness. However, corroded pipe may\nbe repaired by a method that reliable engineering tests and analyses show can\npermanently restore the serviceability of the pipe. Corrosion pitting so closely\ngrouped as to affect the overall strength of the pipe is considered general corrosion\nfor the purpose of this paragraph.\nEcoElectrica’s OMER procedures did not adequately require that a segment of\ntransmission line with general corrosion, and with a remaining wall thickness less than\nthat required for the MAOP of the pipeline, be replaced or the operating pressure reduced\ncommensurate with the strength of the pipe based on actual remaining wall thickness. The\nprocedures also did not convey what is considered to be general corrosion.\nMoreover, the OMER stated in the atmospheric corrosion paragraph of Section III n)\nCorrosion Protection, “Procedures will be developed to replace pipe or reduce the\nMAOP if localized or general corrosion reduced the wall thickness. The method to\ndetermine remaining wall strength will use R Streng or ASME B-31G.” The placement of\nthis statement in this paragraph of the manual incorrectly implies that this regulatory\nrequirement only applies to atmospheric corrosion when, in fact, it also applies to internal\ncorrosion and to non-atmospheric external general corrosion as well.\n6. §192.485 Remedial measures: Transmission lines.\n. . . (b) Localized corrosion pitting. Each segment of transmission line pipe with\nlocalized corrosion pitting to a degree where leakage might result must be replaced\nor repaired, or the operating pressure must be reduced commensurate with the\nstrength of the pipe, based on the actual remaining wall thickness in the pits.\nEcoElectrica’s OMER procedures were not in the detail required to assure that\nEcoElectrica would replace, repair, or reduce the operating pressure commensurate with\nthe strength of the pipe, based on the actual remaining wall thickness in the corrosion pits,\nany transmission line pipe with localized corrosion pitting to a degree where leakage\nmight result.\nFor example, EcoElectrica’s OMER procedures stated in the atmospheric corrosion\nparagraph of Section III n) Corrosion Protection, that “Procedures will be developed to\nreplace pipe or reduce the MAOP if localized or general corrosion reduced the wall\nthickness. The method to determine remaining wall strength will use R Streng or\nASME B-31G.” However, use of ASME/ANSI B31G and RSTRENG are not applicable\nwhen the corrosion depth is more than 80 percent of the of the pipe wall thickness.\nDefects deeper than 80 percent of the wall thickness should be repaired or removed to\nprevent leakage.\n3\n\n\n\n7. §192.485 Remedial measures: Transmission lines.\n. . . (c) Under paragraphs (a) and (b) of this section, the strength of pipe based on\nactual remaining wall thickness may be determined by the procedure in\nASME/ANSI B31G or the procedure in AGA Pipeline Research Committee Project\nPR 3-805 (with RSTRENG disk). Both procedures apply to corroded regions that do\nnot penetrate the pipe wall, subject to the limitations prescribed in the procedures.\nWhile EcoElectrica’s OMER procedures stated that EcoElectrica will use RSTRENG or\nASME B-31G to determine remaining wall strength, the procedures were not in the detail\nrequired to explain that the procedures in ASME/ANSI B31G or the procedure in AGA\nPipeline Research Committee Project PR 3-805 (with RSTRENG disk) only apply to\ncorroded regions that do not penetrate the pipe wall and are subject to the limitations\nprescribed in the procedures.\n8. 9. §192.605 Procedural manual for operations, maintenance, and emergencies.\n. . . (b) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n. . . (11) Responding promptly to a report of a gas odor inside or near a building,\nunless the operator's emergency procedures under § 192.615(a)(3) specifically apply\nto these reports.\nEcoElectrica’s OMER procedures did not require EcoElectrica to respond promptly to a\nreport of a gas odor inside or near a building. That is, OMER Manual procedure\nLNGT-051 Emergency Plan – Natural Gas Export Pipeline did not convey that a report of\na gas odor inside or near a building was a condition requiring a prompt response.\n§192.605 Procedural manual for operations, maintenance, and emergencies.\n. . . (c) Abnormal operation. For transmission lines, the manual required by\nparagraph (a) of this section must include procedures for the following to provide\nsafety when operating design limits have been exceeded:\n(1) Responding to, investigating, and correcting the cause of:\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating limits;\n(iii) Loss of communications;\n(iv) Operation of any safety device; and,\n(v) Any other foreseeable malfunction of a component, deviation from normal\noperation, or personnel error, which may result in a hazard to persons or property.\nEcoElectrica’s OMER procedures did not address the items in §§192.605(c)(1)(i) - (v).\nWhile EcoElectrica’s OMER Manual Section III c) Investigation of Failures described\nabnormal operations and referenced a “Standard Operating Procedure titled Accident\nNotification and Investigation,” the referenced procedure was not available at the time of\nthe inspection nor was it in the OMER Manual. Moreover, there were no procedures to\nexplain how EcoElectrica would respond to, investigate, and correct the cause of an\nabnormal operation on the Costa Sur Pipeline.\n4\n\n\n\n10. §192.605 Procedural manual for operations, maintenance, and emergencies.\n. . . (c) Abnormal operation. For transmission lines, the manual required by\nparagraph (a) of this section must include procedures for the following to provide\nsafety when operating design limits have been exceeded:\n. . . (2) Checking variations from normal operation after abnormal operation has\nended at sufficient critical locations in the system to determine continued integrity\nand safe operation.\nEcoElectrica’s OMER procedures did not explain how EcoElectrica would check\nvariations from normal operations at sufficient critical locations in the system after an\nabnormal operation has ended so as to determine the continued integrity and safe\noperation of the Costa Sur Pipeline.\n11. §192.605 Procedural manual for operations, maintenance, and emergencies.\n. . . (c) Abnormal operation. For transmission lines, the manual required by\nparagraph (a) of this section must include procedures for the following to provide\nsafety when operating design limits have been exceeded:\n. . . (3) Notifying responsible operator personnel when notice of an abnormal\noperation is received.\nAlthough EcoElectrica’s OMER Manual Section III c) Investigation of Failures described\nabnormal operations, the OMER procedures did not explain how EcoElectrica would\ncomply with the requirements to notify responsible operator personnel when notice of an\nabnormal operation on the Costa Sur Pipeline is received.\n12. §192.619 What is the maximum allowable operating pressure for steel or plastic\npipelines?\n(a) No person may operate a segment of steel or plastic pipeline at a pressure that\nexceeds a maximum allowable operating pressure determined under paragraph (c)\nor (d) of this section, or the lowest of the following:\n. . . (1) The design pressure of the weakest element in the segment, determined in\naccordance with Subparts C and D of this part. However, for steel pipe in pipelines\nbeing converted under §192.14 or uprated under subpart K of this part, if any\nvariable necessary to determine the design pressure under the design formula\n(§192.105) is unknown, one of the following pressures is to be used as design pressure\n. . . .\nEcoElectrica’s OMER procedures for determining the maximum allowable operating\npressure (MAOP) of the Costa Sur Pipeline did not require the MAOP be determined for\nthe recently installed meter station (a segment of the Costa Sur Pipeline) that is located at\nthe beginning of the line.\n13. §192.719 Transmission lines: Testing of repairs.\n(a) Testing of replacement pipe. If a segment of transmission line is repaired by\ncutting out the damaged portion of the pipe as a cylinder, the replacement pipe must\nbe tested to the pressure required for a new line installed in the same location. This\ntest may be made on the pipe before it is installed.\n5\n\n\n\nAlthough EcoElectrica’s OMER Manual Section III o) Field Repairs of Leaks required the\ntesting of replacement pipe that is installed to repair a leak, the procedures did not require\nthe testing of replacement pipe that is installed due to a non-leaking repair.\n14. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) Identify covered tasks;\nEcoElectrica’s written qualification program Procedure LNGT-060 Transmission Pipeline\nOperator Qualification (OQ) Program Revision #0 dated March 13, 2012 (Procedure\nLNGT-060) did not include provisions to allow EcoElectrica to adequately identify\ncovered tasks. This inadequacy was evidenced by the list of covered tasks in the program\nthat were broad in nature such as tasks “… 5.1-Line Operation … 5.4-Cathodic Protection\nTesting … 5.5-Corrosion Control.”\n15. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (b) Ensure through evaluation that individuals performing covered tasks are\nqualified;\nEcoElectrica’s written qualification program Procedure LNGT-060 was not in the detail\nrequired to ensure through evaluation that individuals performing covered tasks were\nqualified. Procedure LNGT-060 did not\n− Convey that “Qualified” means an individual has been evaluated and can: (a)\nPerform assigned covered tasks and (b) Recognize and react to abnormal operating\nconditions (see §192.803).\n− Convey that an abnormal operating condition (AOC) means a condition identified\nby EcoElectrica that may indicate a malfunction of a component or deviation from\nnormal operations that may: (a) Indicate a condition exceeding design limits; or (b)\nResult in a hazard(s) to persons, property, or the environment (see §192.803).\n− Identify AOCs that are applicable to the Operator Qualification (OQ) rule.\n− Identify specific AOCs or require training of individuals performing covered tasks\nto recognize and react to AOCs where a component malfunction or deviation from\nnormal operations may result in exceeding design limits or in a hazardous\ncondition. Operators must demonstrate that the ability to recognize and react to\nAOCs is a part of each individual's evaluation for qualification.\n− Address whether or not EcoElectrica employs contractors or other entities, such as\nthrough mutual assistance agreements, to provide individuals to perform covered\ntasks.\n− Explain how it would verify that appropriate methods were used to qualify\ncontractors or other entities or how EcoElectrica would ensure these individuals\nwere qualified.\n16. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n6\n\n\n\n. . . (c) Allow individuals that are not qualified pursuant to this subpart to perform a\ncovered task if directed and observed by an individual that is qualified;\nEcoElectrica’s written qualification program Procedure LNGT-060 did not include the\nprovision to allow individuals who are not qualified in accordance with Part 192,\nSubpart N to perform a covered task if directed and observed by an individual that is\nqualified.\n17. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (d) Evaluate an individual if the operator has reason to believe that the\nindividual’s performance of a covered task contributed to an incident as defined in\nPart 191;\nEcoElectrica’s written qualification program Procedure LNGT-060 did not include the\nprovision to evaluate an individual if EcoElectrica has reason to believe the individual’s\nperformance of a covered task contributed to an incident as defined in Part 191.\n18. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (e) Evaluate an individual if the operator has reason to believe that the individual\nis no longer qualified to perform a covered task;\nEcoElectrica’s written qualification program Procedure LNGT-060 did not include the\nprovision to evaluate an individual if EcoElectrica has reason to believe that the individual\nis no longer qualified to perform a covered task.\n19. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (f) Communicate changes that affect covered tasks to individuals performing\nthose covered tasks;\nEcoElectrica’s written qualification program Procedure LNGT-060 did not include the\nprovision to communicate changes that affect covered tasks to individuals performing\nthose covered tasks.\nProcedure LNGT-060 did not require EcoElectrica to communicate the following:\n− OQ Plan information for employee and/or contract individuals performing covered\ntasks.\n− The process for a non-qualified contracted individual to perform a covered task.\n− The process for contracted individual disqualification and requalification.\n− The process for communicating any OQ Plan changes to contractors.\nProcedure LNGT-060 did not identify how changes to procedures, tools, standards and\nother elements used by individuals in performing covered tasks are to be communicated to\nthe individuals, including contractor individuals, and how these changes are implemented\nin the evaluation method(s).\n7\n\n\n\n20. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (g) Identify those covered tasks and the intervals at which evaluation of the\nindividual’s qualifications is needed;\nEcoElectrica’s written qualification program Procedure LNGT-060 did not include\nprovisions to identify the intervals at which the evaluation of an individual’s qualifications\nis needed.\n21. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (h) After December 16, 2004, provide training, as appropriate, to ensure that\nindividuals performing covered tasks have the necessary knowledge and skills to\nperform the tasks in a manner that ensures the safe operation of pipeline facilities;\nEcoElectrica’s written qualification program Procedure LNGT-060 was not in the detail\nrequired to ensure that individuals performing covered tasks have the necessary\nknowledge and skills to perform the tasks in a manner that ensures the safe operation of\npipeline facilities. Moreover, Procedure LNGT-060 did not contain specific criteria for\nthe initial training qualification of individuals performing covered tasks; and, it did not\ncontain criteria for the retraining and reevaluation of individuals if their qualifications are\nquestioned.\n22. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n. . . (i) After December 16, 2004, notify the Administrator or a state agency\nparticipating under 49 U.S.C. Chapter 601 if the operator significantly modifies the\nprogram after the Administrator or state agency has verified that it complies with\nthis section.\nEcoElectrica’s written qualification program Procedure LNGT-060 did not include the\nprovision to notify the Administrator or a state agency participating under 49 U.S.C.\nChapter 601 if EcoElectrica significantly modifies the program after the Administrator or\nstate agency has verified (i.e., after acceptance by PHMSA of program corrections\nsubsequent to the first PHMSA inspection of the program) that it complies with §192.805.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237.\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Compliance Proceedings. Please refer to this document and note the\nresponse options. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with\nthe complete original document you must provide a second copy of the document with the\n8\n\n\n\nportions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a\nwaiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as\nalleged in this Notice, you may be ordered to amend your plans or procedures to correct\nthe inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose\nthat you submit your amended procedures to my office within 30 days of receipt of this\nNotice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that EcoElectrica, L.P. maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/ revision of plans, procedures) and submit the total to Wayne T. Lemoi,\nDirector, Southern Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 2-2012-0005M and, for each\ndocument you submit, please provide 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\n9\n\n220120005M_Closure letter_05202013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2013\nMr. Carlos Reyes\nCo-President & General Manager Operations\nEcoElectrica L.P.\nStreet 337, KM 3.7 Bo Tallaboa Poniente\nPenuelas, PR 00624\nCPF 2-2012-0005M\nDear Mr. Reyes:\nBetween April 23 and 27, 2012, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Southern Region, Office of Pipeline Safety inspected the\nEcoElectrica, L.P. (EcoElectrica) operations, maintenance, and emergency response (OMER)\nmanual of written procedures for the Costa Sur Pipeline in Penuelas, Puerto Rico, pursuant to\nChapter 601 of 49 United States Code. As a result of the inspection, PHMSA issued\nEcoElectrica a Notice of Amendment (NOA) on October 17, 2012.\nThe PHMSA Southern Region received and reviewed the amended procedures EcoElectrica\nsubmitted in correspondences dated November 16, 2012, March 22, 2013, and May 3, 2013,\nand we find them adequate. This letter is to inform you that EcoElectrica has complied with\nthe terms of the NOA and that no further actions are necessary with regards to the NOA. This\ncase is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2012-0005M) and not to any\nother PHMSA pending cases, if any. Also be advised that nothing herein states or implies\nthat the above described OMER procedures meet the requirements of the federal pipeline\nsafety regulations or that the OMER procedures are approved. The pipeline system and\nOMER procedures remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":27082}