{"operation":"document","citation":"CPF 220121002M","title":"DESTIN PIPELINE COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-01-12","effective_on":null,"summary":"CLOSED notice of amendment citing 192.707(d)(1), 192.731(c), 192.736(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220121002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220121002M","body":"Notice of Amendment involving DESTIN PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.707(d)(1),  192.731(c),  192.736(c). The case was opened on 2012-01-12 and is reported as closed as of 2012-03-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220121002M_closure letter_03082012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121002M/220121002M_closure%20letter_03082012.pdf\n\n220121002M_closure letter_03082012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121002M/220121002M_closure%20letter_03082012_text.pdf\n\n220121002M_notice of amendment_01122012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121002M/220121002M_notice%20of%20amendment_01122012.pdf\n\n220121002M_notice of amendment_01122012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121002M/220121002M_notice%20of%20amendment_01122012_text.pdf\n\n220121002M_Operator response_02162012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220121002M/220121002M_Operator%20response_02162012.pdf\n\n220121002M_closure letter_03082012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 8, 2012\nMr. Steve Pankhurst\nBusiness Unit Leader\nDestin Pipeline Company, LLC\nBP Pipelines (North America) Inc.\n150 West Warrenville Road\nNaperville, Illinois 60563\nCPF 2-2012-1002M\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) Operations,\nMaintenance and Emergency Manual (OMER) written procedures in Moss Point, Mississippi,\npursuant to Chapter 601 of 49 United States Code. As a result of the inspection, PHMSA\nissued a Notice of Amendment (NOA) to Destin on January 12, 2012.\nThe PHMSA Southern Region received your response to the NOA on February 17, 2012.\nUpon review of your response to the NOA, we requested, by email dated February 21, 2012,\nthat additional revisions to two Job Plan Details be made as relates to NOA Item Number 2.\nIn response to the February 21, 2012 request, we received (and have reviewed) from Destin\nby email dated February 28, 2012, two revised Job Plan Details.\nThis letter is to inform you that Destin has complied with the terms of the NOA and that no\nfurther 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 2-2012-1002M) and not to any\nother PHMSA pending cases.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220121002M_notice of amendment_01122012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 12, 2012\nMr. Steve Pankhurst\nBusiness Unit Leader\nDestin Pipeline Company, LLC\n150 West Warrenville Road\nNaperville, IL 60563\nCPF 2-2012-1002M\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) Operations,\nMaintenance and Emergency Manual (OMER) written procedures in Moss Point, Mississippi,\npursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within Destin’s\nplans or procedures as described below:\n1. §192.707 Line markers for mains and transmission lines.\n. . . (d) Marker warning. The following must be written legibly on a background of\nsharply contrasting color on each line marker:\n(1) The word \"Warning,\" \"Caution,\" or \"Danger\" followed by the words \"Gas (or\nname of gas transported) Pipeline\" all of which, except for markers in heavily\ndeveloped urban areas, must be in letters at least 1 inch (25 millimeters) high with ¼\ninch (6.4 millimeters) stroke.\nDestin’s procedures for placing and maintaining transmission line markers were\ninadequate because they did not require line markers for transmission lines to include the\nwords “Gas (or name of gas transported) Pipeline.”\nDestin’s OMER procedure P-192.614, Section XII, Pipeline Permanent Marker Program\nconveyed: Marking and identification of BP [includes Destin pipeline] rights of way will\nbe marked and identified in accordance with BP procedures: Specification for Auxiliary\nInstallations (Site Technical Practices STP-43-119 and/or Affiliate Equivalent. The\nprocedure provided to the inspector during the inspection, SP-119 BP Pipelines, N.A.\nSpecification for Auxiliary Installations (SP-119) did not require markers to be marked\nwith the words “Gas (or name of gas transported) Pipeline.”\n\n\n\n2. §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’s procedures for recording the results of the inspection and testing of relief devices\nwere inadequate because they did not require sufficient documentation to show that the\ninspections and/or tests were completed so as to ensure the relief devices functioned\nproperly.\nDestin’s Maximo work order Compressor Station ESD Test did not require that the\nperformance of all location-specific remote control shutdown devices be documented.\nMoreover, location-specific lists of these shutdown devices were not referenced or\nincluded in the work order.\n3. §192.736 Compressor stations: Gas detection.\n. . . (c) Each gas detection and alarm system required by this section must be\nmaintained to function properly. The maintenance must include performance tests.\nDestin’s procedures for maintaining each gas detection and alarm system to function\nproperly were inadequate because they did not require sufficient documentation to show\nthat gas detection and alarm system performance tests were adequately performed.\nDestin’s Maximo work order Gas Detector Functional Check did not require that the\nperformance of all location-specific alarms (i.e. audible, visual) be documented.\nMoreover, location-specific lists of these alarms were not referenced or included in the\nwork order.\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 45 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 Destin Pipeline Company, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Wayne T. Lemoi, Director,\nOffice of Pipeline Safety, PHMSA Southern Region. In correspondence concerning this\nmatter, please refer to CPF 2-2012-1002M 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":8490}