{"operation":"document","citation":"CPF 220121001W","title":"DESTIN PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-01-11","effective_on":null,"summary":"CLOSED warning letter citing 192.463(a), 192.605(a), 192.707(a), 192.731(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220121001W","body":"Warning Letter involving DESTIN PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.463(a),  192.605(a),  192.707(a),  192.731(c). The case was opened on 2012-01-11 and is reported as closed as of 2012-01-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220121001W_warning letter_01112012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121001W/220121001W_warning%20letter_01112012.pdf\n\n220121001W_warning letter_01112012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121001W/220121001W_warning%20letter_01112012_text.pdf\n\n220121001W_warning letter_01112012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 11, 2012\nMr. Steve Pankhurst\nBusiness Unit Leader\nDestin Pipeline Company, LLC\n150 West Warrenville Road\nNaperville, IL 60563\nCPF 2-2012-1001W\nDear Mr. Pankhurst:\nOn September 12-16, 2011, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Destin Pipeline Company, LLC (Destin) pipelines\nand facilities at various locations in Mississippi and on platforms in the Main Pass Area in the\nGulf of Mexico pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that Destin has committed probable violations of the\nPipeline Safety Regulations codified in Title 49 of the Code of Federal Regulations. The\nitems inspected and the probable violations are as follows:\n1. §192.463 External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide a level of\ncathodic protection that complies with one or more of the applicable criteria\ncontained in Appendix D of this part. If none of these criteria is applicable, the\ncathodic protection system must provide a level of cathodic protection at least equal\nto that provided by compliance with one or more of these criteria.\nDestin’s Operations, Maintenance and Emergency Manual (OMER) written procedure\nP-192.453 Corrosion Control failed to meet the regulation because it referenced the\nwrong external corrosion control cathodic protection criteria. The procedure stated,\n“Cathodic protection required by this subpart must comply with one or more of the\napplicable criteria and other considerations for cathodic protection contained in\nparagraphs 6.2 and 6.3 of NACE Standard Practice SP0169-2007 and Standard Test\nTM0497-2002 (incorporated by reference).”\n\n\n\nAlthough NACE SP0169-2007 criteria are similar to those listed in Part 192 Appendix D,\nthey are not identical. Appendix D is the correct referenced document for the cathodic\nprotection of pipelines regulated under Part 192. NACE SP0169-2007 is not referenced in\nPart 192 and cannot be used to determine cathodic protection criteria for natural gas\npipelines.\nAdditionally, Destin’s OMER written procedure P-192.453 also stated, “The Use of\nSound Engineering Judgment: Although the potential criteria is normally used to\nestablish the level of protection in most cases, the use of sound engineering judgment may\nalso be used to determine that corrosion does not exist at the potentials being maintained.\nAn example would be where an in-line inspection revealed that no corrosion had taken\nplace for a given section of pipe. That would provide sufficient evidence that the potential\nmaintained on that section of pipe was adequate to control soil side corrosion. The\nCorrosion Technical Authority shall approve any application of Sound Engineering\nJudgment prior to its application.”\nThe above verbiage states that for certain pipelines that do not meet cathodic protection\ncriteria, Destin can use an alternative criterion that is determined based on sound\nengineering judgment. Neither §192.463(a) nor Appendix D allow for the use of sound\nengineering judgment to determine cathodic protection criteria. The only criteria allowed\nare those in Appendix D.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. . . .\n– Destin did not follow its OMER P-192.605(c) Abnormal Operations written procedure\nwhen responding to a pipeline event that occurred on August 30, 2011, because it did\nnot document the event by creating a work order for the field maintenance personnel\nto record their response to, and closure of, the event as required by the procedure.\nOn August 30, 2011, Destin’s liquids removal facility located immediately upstream\nof the Pascagoula Gas Processing Plant experienced an abnormally high level of\nliquids. As a result, the on-site Hi-Hi liquid level control system was tripped, resulting\nin the closure of valves and a cessation of all offshore gas being delivered to the\nprocessing plant. Destin’s SCADA logs indicated that at 08:10:52 on August 30, 2011,\nvalves 9021 and 9041 at the processing plant were closed and the flow rate to the\nprocessing plant went to zero.\nWhile Destin’s procedure required the pipeline controller to document this type of\nevent by “creating a work order for the field maintenance personnel to record their\nresponse and closure to the event,” the controller did not recognize this event as an\nabnormal condition and did not create a work order for the field maintenance\npersonnel to record their response to, and closure of, the event.\n2\n\n\n\n– Destin did not follow its written work order procedures as further explained below.\nDestin used these work orders for conducting certain operations and maintenance\nactivities required by §192.605(a).\n– Work order no. 1817142: Pascmpr Press Xmitr Discharge Side- performed on\n09/02/2011 at the Pascagoula Compressor Station: Destin did not properly\ndocument the station Hi Discharge PLC set point, as required by the work order.\nThe station Hi Hi Discharge PLC setpoint was documented as 1290 psig but the\nrequired set point per the Station RTU Cause and Effect Chart was 1260 psig.\n– Work order no. 809616: Pascmpr Press Xmitr Discharge Side- performed on\n09/07/2010 at the Pascagoula Compressor Station: Destin did not properly\ndocument the station Hi Discharge PLC set point, as required by the work order.\nThe station Hi-Hi Discharge PLC set point was documented as 1250 psig but the\nrequired set point per the Station RTU Cause and Effect Chart was 1260 psig.\n– Work order no. 717228 Pascmpr Press Xmitr Discharge Side- performed on\n09/06/2009 at the Pascagoula Compressor Station: Destin did not properly\ndocument the station Hi and Hi-Hi Discharge PLC set points, as required by the\nwork order.\n– Work order no. 809625 PT-9001 Sand Hill Discharge- performed on 08/31/2010\nat the Sand Hill Compressor Station: The station Hi Discharge PLC set point was\nimproperly documented as 1261 psig. The required set point per the Station RTU\nCause and Effect Chart was 1252 psig. The station Hi-Hi Discharge PLC set point\nwas improperly documented as 1312 psig. The required set point per the Station\nRTU Cause and Effect Chart was 1260 psig.\n– Work order no. 717237 PT-9001 Sand Hill Discharge - performed on 09/07/2009\nat the Sand Hill Compressor Station: Destin did not properly document the station\nHi and Hi-Hi Discharge PLC set points, as required by the work order.\n– Work order no. 830596 Sand Hill Compressor Station ESD Test - performed on\n11/09-11/2010 at the Sand Hill Compressor Station: Destin did not document the\nESD Test Location, as required by the work order.\n– Work order no. 1792331 Pascagoula Compressor Station ESD Test - performed\non 08/04/2011 at the Pascagoula Compressor Station: Destin did not document\nspecific observations of the station ESD test, as required by the work order.\n– Work order no. 792429 Pascagoula Compressor Station ESD Test - performed on\n07/23/2010 at the Pascagoula Compressor Station: Destin did not document\nspecific observations of the station ESD test, as required by the work order.\n– Destin did not follow its OMER P-192.739 Overpressure Safety Devices written\nprocedure when attempting to comply with §192.743(b), which requires an annual\nreview of relief device capacity calculations or annual documentation that the\nparameters of the relief devices had not changed since the original capacity\ncalculations. Destin did not perform the above described reviews for calendar years\n2009 and 2010 for its compressor station fuel gas relief devices located at Pascagoula3\n\n\n\n(PSV 1400 and PSV 1401) and Sand Hill (PSV 1451 and PSV 1400). It was noted\nduring the inspection that the applicable parameters of these relief valves had not\nchanged since the original construction.\n3. §192.707 Line markers for mains and transmission lines.\n(a) Buried pipelines. Except as provided in paragraph (b) of this section, a line\nmarker must be placed and maintained as close as practical over each buried main\nand transmission line . . . .\nDestin’s OMER procedure P-192.614 Section XII Pipeline Permanent Marker Program\nwas incorrect and did not meet the regulation. This procedure stated, “Marking and\nidentification of BP [includes Destin pipeline] rights of way will be marked and identified\nin accordance with BP procedures: Specification for Auxiliary Installations (Site\nTechnical Practices STP-43-119) and/or Affiliate Equivalent.” Moreover, the procedure\nprovided to the PHMSA inspector, SP-119 BP Pipelines, N.A. Specification for Auxiliary\nInstallations (SP-119) incorrectly referenced Title 49 CFR Part 195 and ASME B31.4 as\napplicable codes, and listed the line marker placement requirements of §195.410(a). Part\n195 and ASME B31.4 regulate hazardous liquid pipelines, not natural gas pipelines.\nThough the requirements in §195.410(a) are similar to those in §192.707(a), they are not\nidentical and are not interchangeable.\n4. §192.731 Compressor stations: Inspection and testing of relief devices.\n. . . (c) Each remote control shutdown device must be inspected and tested at\nintervals not exceeding 15 months, but at least once each calendar year, to determine\nthat it functions properly.\nDestin did not adequately record the inspection and testing of remote control shutdown\ndevices. That is, Destin did not document the inspection and testing of remote control\nshutdown devices (compressor station emergency shutdown devices (ESDs)) in the detail\nrequired to show the devices functioned properly. Moreover, location-specific lists of\nthese devices were not referenced or included in the following work orders:\n– Sand Hill Compressor Station Work order 830596 Sand Hill Compressor Station ESD\nTest conducted on 11/09-11/2010.\n– Pascagoula Compressor Station Work orders 1792331 Pascagoula Compressor\nStation ESD Test conducted on 08/04/2011, and 792429 Pascagoula Compressor\nStation ESD Test conducted on 07/23/2010.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Destin Pipeline Company,\nLLC being subject to additional enforcement action.\n4\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF2-2012-1001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n5","truncated":false,"body_characters":12286}