{"operation":"document","citation":"CPF 220126007M","title":"GENESIS PIPELINE ALABAMA, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-03-20","effective_on":null,"summary":"CLOSED notice of amendment citing 195.422(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220126007M","body":"Notice of Amendment involving GENESIS PIPELINE ALABAMA, LLC. PHMSA's enforcement data identifies the cited regulation as 195.422(b). The case was opened on 2012-03-20 and is reported as closed as of 2012-04-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220126007M_closure letter_04172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126007M/220126007M_closure%20letter_04172012.pdf\n\n220126007M_closure letter_04172012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126007M/220126007M_closure%20letter_04172012_text.pdf\n\n220126007M_notice of amendment_03202012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126007M/220126007M_notice%20of%20amendment_03202012.pdf\n\n220126007M_notice of amendment_03202012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126007M/220126007M_notice%20of%20amendment_03202012_text.pdf\n\n220126007M_Operator response_04052012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126007M/220126007M_Operator%20response_04052012.pdf\n\n220126007M_closure letter_04172012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 17, 2012\nMr. Jeffrey W. Gifford\nVice President, HSSE\nGenesis Energy\n919 Milam, Suite 2100\nHouston, Texas 77002\nCPF 2-2012-6007M\nDear Mr. Gifford:\nOn February 13-16, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Genesis Pipeline Alabama, LLC (Genesis-AL)\nCastleberry Pipeline’s written operations and maintenance procedures contained in the\nGenesis Energy Liquid & CO2 Operations, Maintenance and Emergency Procedures Manual\n(LOM&E). The LOM&E is used by all Genesis Energy, L.P companies operating hazardous\nliquid pipelines regulated by 49 CFR Part 195. The inspection took place in Brewton,\nAlabama, pursuant to Chapter 601 of 49 United States Code. As a result of the inspection,\nPHMSA issued a Notice of Amendment (NOA) on March 20, 2012.\nThe PHMSA Southern Region received your response to the NOA on April 9, 2012. We have\nreviewed your response, and find Genesis-AL’s response adequate. This letter is to inform\nyou that Genesis-AL has complied with the terms of the NOA and that no further action is\nnecessary with regards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2012-6007M) and not to any\nother PHMSA pending cases. Also be advised that nothing herein states or implies that the\nLOM&E meets the requirements of the federal pipeline safety regulations or that the LOM&E\nis approved. The pipeline system and LOM&E remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220126007M_notice of amendment_03202012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 20, 2012\nMr. Mike Moore\nVice President, Pipelines and Trucking Operations\nGenesis Pipeline Alabama, LLC\n919 Milam, Suite 2100\nHouston, Texas 77002-5417\nCPF 2-2012-6007M\nDear Mr. Moore:\nFrom February 13-16, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Genesis Pipeline Alabama, LLC (Genesis-AL)\nCastleberry Pipeline’s written operations and maintenance (O&M) procedures in Alabama\npursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within\nGenesis-AL’s written procedures, as described below:\n1. §195.422 Pipeline repairs.\n. . . (b) No operator may use any pipe, valve, or fitting, for replacement in repairing\npipeline facilities, unless it is designed and constructed as required by this part.\nGenesis-AL’s written procedures were inadequate because they did not require certain\ncomponents to be designed and constructed in accordance with Part 195.\nThe Genesis Energy Liquid & CO2 Operations, Maintenance and Emergency Procedures\nManual (LOM&E) is used by all Genesis Energy, L.P. companies operating hazardous\nliquid pipelines regulated under 49 CFR Part 195. LOM&E Section 2.14 Pipeline Repair\nand Maintenance did not require that any pipe, valve, or fitting, used for replacement in\nrepairing pipeline facilities, be designed and constructed in accordance with Part 195. The\nreferenced procedure stated “All repairs made must comply with 195.422…”; however, it\ndid not address how Genesis-AL would meet the requirements.\n\n\n\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 Genesis Pipeline Alabama, LLC maintain documentation\nof the 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 2-2012-6007M 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","truncated":false,"body_characters":6786}