{"operation":"document","citation":"CPF 220125006M","title":"SHELL PIPELINE CO., L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-06-05","effective_on":null,"summary":"CLOSED notice of amendment citing 195.571.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220125006M","body":"Notice of Amendment involving SHELL PIPELINE CO., L.P.. PHMSA's enforcement data identifies the cited regulation as 195.571. The case was opened on 2012-06-05 and is reported as closed as of 2012-07-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220125006M_closure letter_07172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125006M/220125006M_closure%20letter_07172012.pdf\n\n220125006M_closure letter_07172012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125006M/220125006M_closure%20letter_07172012_text.pdf\n\n220125006M_notice of amendment_06052012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125006M/220125006M_notice%20of%20amendment_06052012.pdf\n\n220125006M_notice of amendment_06052012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125006M/220125006M_notice%20of%20amendment_06052012_text.pdf\n\n220125006M_Operator_Response_06212012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125006M/220125006M_Operator_Response_06212012.pdf\n\n220125006M_notice of amendment_06052012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 5, 2012\nMr. Greg Smith\nPresident\nShell Pipeline Company, L.P.\nTwo Shell Plaza\n777 Walker Street, Room 1437\nHouston, TX 77002\nCPF 2-2012-5006M\nDear Mr. Smith:\nFrom April 9-11, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety inspected the Shell\nPipeline Company, L.P. (Shell) Capline Pipeline system’s written operations and maintenance\nprocedures in Byhalia, MS, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within Shell’s\nwritten procedures, as described below:\n1. §195.571 What criteria must I use to determine the adequacy of cathodic protection?\nCathodic 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 SP 0169 (incorporated by reference, see § 195.3).\nShell's written procedures in its Corrosion Control Inspection and Maintenance Manual\n(i.e. Procedure 571) did not adequately address how Shell complied with one or more of\nthe applicable criteria and other considerations for cathodic protection contained in\nparagraphs 6.2 and 6.3 of NACE SP 0169, which is incorporated by reference in §195.3.\nShell’s written Procedure 571 - Cathodic Protection Criteria listed three different\ncathodic protection criteria to include “1. - 0.850 volts versus Copper/Copper Sulfate\nhalf-cell with IR [voltage drop] considered.” The procedure further stated that “All are\ndefined in NACE Standard Practice SP 0169. Detailed procedures for using these criteria\nare given in 27TG-001 External Corrosion Considerations from Pipeline Design and\nConstruction.\"\n\n\n\nHowever, neither Procedure 571 - Cathodic Protection Criteria or SPLC Standard\n27TG-001 External Corrosion Considerations from Pipeline Design and Construction\nprovided guidance or explanation on how Shell considered IR drop other than those across\nthe structure-to-electrolyte boundary when using the - 0.850 volt criteria beyond the\nreference to NACE SP 0169.\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.\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 Shell Pipeline Company, L.P. 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,\nSouthern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 2-2012-5006M and, for each document you\nsubmit, 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\n2\n\n220125006M_closure letter_07172012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 17, 2012\nMr. Greg Smith\nPresident\nShell Pipeline Company, L.P.\nTwo Shell Plaza\n777 Walker Street, Room 1437\nHouston, TX 77002\nCPF 2-2012-5006M\nDear Mr. Smith:\nOn June 5, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA),\nSouthern Region, Office of Pipeline Safety issued a Notice of Amendment (NOA) to Shell\nPipeline Company, L.P. (Shell) as a result of a PHMSA inspection from April 9-12, 2012, of\nthe Shell Capline Pipeline system’s written operations and maintenance procedures.\nThe PHMSA Southern Region received and reviewed your response to the NOA dated\nJune 21, 2012. This letter is to inform you that Shell has complied with the terms of the NOA\nand that no 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 2-2012-5006M) and not to any\nother PHMSA pending cases. Also be advised that nothing herein states or implies that the\nabove described written operations and maintenance procedures meet the requirements of the\nfederal pipeline safety regulations or that they are approved. The Shell Capline Pipeline\nsystem remains subject to inspection by PHMSA. In future inspections, we will be looking\nclosely at how Shell considered IR drop, other than those across the structure-to-electrolyte\nboundary when using the - 0.850 volt criteria, according to its amended “Consideration of IR\nDrop in Structure to Soil Potential Readings” procedures.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":7307}