GENESIS PIPELINE ALABAMA, LLC — Notice of Amendment

party submissionOfficial PDF220126007M_Operator response_04052012.pdf#

220126007M_closure letter_04172012_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED April 17, 2012 Mr. Jeffrey W. Gifford Vice President, HSSE Genesis Energy 919 Milam, Suite 2100 Houston, Texas 77002 CPF 2-2012-6007M Dear Mr. Gifford: On February 13-16, 2012, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the Genesis Pipeline Alabama, LLC (Genesis-AL) Castleberry Pipeline’s written operations and maintenance procedures contained in the Genesis Energy Liquid & CO2 Operations, Maintenance and Emergency Procedures Manual (LOM&E). The LOM&E is used by all Genesis Energy, L.P companies operating hazardous liquid pipelines regulated by 49 CFR Part 195. The inspection took place in Brewton, Alabama, pursuant to Chapter 601 of 49 United States Code. As a result of the inspection, PHMSA issued a Notice of Amendment (NOA) on March 20, 2012. The PHMSA Southern Region received your response to the NOA on April 9, 2012. We have reviewed your response, and find Genesis-AL’s response adequate. This letter is to inform you that Genesis-AL has complied with the terms of the NOA and that no further action is necessary with regards to the NOA. This case is now closed. Please be advised that this letter refers only to the NOA (CPF 2-2012-6007M) and not to any other PHMSA pending cases. Also be advised that nothing herein states or implies that the LOM&E meets the requirements of the federal pipeline safety regulations or that the LOM&E is approved. The pipeline system and LOM&E remain subject to inspection by PHMSA. Sincerely, Wayne T. Lemoi Director, Office of Pipeline Safety PHMSA Southern Region#

220126007M_notice of amendment_03202012_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 20, 2012 Mr. Mike Moore Vice President, Pipelines and Trucking Operations Genesis Pipeline Alabama, LLC 919 Milam, Suite 2100 Houston, Texas 77002-5417 CPF 2-2012-6007M Dear Mr. Moore: From February 13-16, 2012, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the Genesis Pipeline Alabama, LLC (Genesis-AL) Castleberry Pipeline’s written operations and maintenance (O&M) procedures in Alabama pursuant to Chapter 601 of 49 United States Code. On the basis of the inspection, PHMSA has identified apparent inadequacies within Genesis-AL’s written procedures, as described below: 1. §195.422 Pipeline repairs. . . . (b) No operator may use any pipe, valve, or fitting, for replacement in repairing pipeline facilities, unless it is designed and constructed as required by this part. Genesis-AL’s written procedures were inadequate because they did not require certain components to be designed and constructed in accordance with Part 195. The Genesis Energy Liquid & CO2 Operations, Maintenance and Emergency Procedures Manual (LOM&E) is used by all Genesis Energy, L.P. companies operating hazardous liquid pipelines regulated under 49 CFR Part 195. LOM&E Section 2.14 Pipeline Repair and Maintenance did not require that any pipe, valve, or fitting, used for replacement in repairing pipeline facilities, be designed and constructed in accordance with Part 195. The referenced procedure stated “All repairs made must comply with 195.422…”; however, it did not address how Genesis-AL would meet the requirements.#

220126007M_notice of amendment_03202012_text.pdf, page 2Response 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. 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 30 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. It is requested (not mandated) that Genesis Pipeline Alabama, LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Wayne T. Lemoi, Director, Southern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 2-2012-6007M 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 2#