{"operation":"document","citation":"CPF 220126018M","title":"TAMPA AIRPORT PIPELINE CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-10-02","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(c)(1)(i)(a), 195.452(c)(1)(i)(b), 195.452(f), 195.452(f)(3), 195.452(f)(8), 195.452(h)(1), 195.452(h)(2), 195.452(h)(3), 195.452(h)(4)(iv), 195.452(i), 195.452(i)(3), 195.452(i)(4), 195.452(j)(3), 195.452(j)(5)(i), 195.452(j)(5)(ii), 195.452(k), 195.50.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126018m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126018m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126018m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220126018M","body":"Notice of Amendment involving TAMPA AIRPORT PIPELINE CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.452(c)(1)(i)(a),  195.452(c)(1)(i)(b),  195.452(f),  195.452(f)(3),  195.452(f)(8),  195.452(h)(1),  195.452(h)(2),  195.452(h)(3),  195.452(h)(4)(iv),  195.452(i),  195.452(i)(3),  195.452(i)(4),  195.452(j)(3),  195.452(j)(5)(i),  195.452(j)(5)(ii),  195.452(k),  195.50. The case was opened on 2012-10-02 and is reported as closed as of 2013-10-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220126018M_Closure letter_10032013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126018M/220126018M_Closure%20letter_10032013.pdf\n\n220126018M_Closure letter_10032013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126018M/220126018M_Closure%20letter_10032013_text.pdf\n\n220126018M_notice of amendment_10022012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126018M/220126018M_notice%20of%20amendment_10022012.pdf\n\n220126018M_notice of amendment_10022012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126018M/220126018M_notice%20of%20amendment_10022012_text.pdf\n\n220126018M_notice of amendment_10022012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 2, 2012\nMr. Robert L. Rose\nPresident\nTampa Airport Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2012-6018M\nDear Mr. Rose:\nFrom November 8-10, 2011, and March 22, 2012, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Southern Region, inspected the Tampa\nAirport Pipeline Corporation (TAPC) Pipeline Integrity Management Plan (IMP) in\nTampa, Florida, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA identified apparent inadequacies within TAPC’s\nwritten IMP procedures as follows:\n1. §195.50 Reporting accidents. An accident report is required for each failure in a\npipeline system subject to this part in which there is a release of the hazardous liquid\nor carbon dioxide transported resulting in any of the following:\n(a) Explosion or fire not intentionally set by the operator.\n(b) Release of 5 gallons (19 liters) or more of hazardous liquid or carbon dioxide,\nexcept that no report is required for a release of less than 5 barrels (0.8 cubic meters)\nresulting from a pipeline maintenance activity if the release is:\n(1) Not otherwise reportable under this section;\n(2) Not one described in §195.52(a)(4);\n(3) Confined to company property or pipeline right-of-way; and\n(4) Cleaned up promptly;\n(c) Death of any person;\n(d) Personal injury necessitating hospitalization;\n(e) Estimated property damage, including cost of clean-up and recovery, value of\nlost product, and damage to the property of the operator or others, or both,\nexceeding $50,000.\n\n\n\nTAPC’s IMP incorrectly addressed reporting accidents in Section 2.18 Communications\nPlan, subsection Reporting Accidents or Safety Related Conditions.\n− TAPC’s procedures required TAPC to submit a leak report and to make a telephonic\nnotice if leak conditions met the criteria in §191.5. However, §191.5 pertains to gas\npipelines, not to hazardous liquid pipelines. Moreover, the procedure incorrectly\nlisted the reporting criteria based on the gas pipeline regulations in 49 CFR Part 191,\nnot on hazardous liquid pipeline regulations in 49 CFR Part 195.\n− Similarly, TAPC’s IMP Section 1.01 Glossary defined the term “incident.” But an\n“incident” is an event on a gas pipeline. The correct term for a hazardous liquid\npipeline is an “accident” and the reporting criteria for accidents are listed in §195.50.\n2. §195.452 Pipeline integrity management in high consequence areas.\n…. (c) What must be in the baseline assessment plan?\n(1) An operator must include each of the following elements in its written\nbaseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An operator must\nassess the integrity of the line pipe by any of the following methods. The methods an\noperator selects to assess low frequency electric resistance welded pipe or lap welded\npipe susceptible to longitudinal seam failure must be capable of assessing seam\nintegrity and of detecting corrosion and deformation anomalies.\n(A) Internal inspection tool or tools capable of detecting corrosion and\ndeformation anomalies including dents, gouges and grooves; …\nTAPC’s IMP did not properly address the methods TAPC selected to complete the\nbaseline assessment of the integrity of its line pipe. Moreover, while the IMP provided for\nassessment tools capable of detecting corrosion, it did not provide for inspection tools\ncapable of detecting deformation anomalies including dents, gouges and grooves.\nIn 2008, TAPC ran an Enduro caliper in-line inspection (ILI) tool capable of detecting\ndeformation anomalies; yet, TAPC’s IMP did not address the use of this tool or any other\nILI tool capable of detecting such anomalies. The IMP merely addressed ILI tools\ncapable of detecting corrosion as follows:\n− Section 3.01 Introduction - addressed “corrosion activity, metal loss, crack\nformations and third party damage” but it did not address deformation anomalies.\n− Section 3.02 In-Line Inspection Procedures - covered ILI tools and the threats the\ntools addressed. This section stated, “Generally, the goal and objective of the\ninspection should be to analyze and match significant factors known about the\npipeline and expected anomalies with the capabilities and performances of the tool.\nChoice of the tool will depend on the specifics of the pipeline section and the goal\nset for the inspection.” This generic statement did not address either corrosion or\ndeformation anomalies.\n− Section 3.03 ILI Tool Selection - limited the selection of the primary ILI tool to a\nHigh-Resolution Magnetic Flux Leakage (Hi-Res MFL) tool capable of detecting\ncorrosion. It further restricted tool selection by stating, “Other secondary tools\nrecommended by the provider will be considered for evaluation methods.” That is,\n2\n\n\n\nother tools that could possibly detect deformation anomalies would be considered\nbut not necessarily selected for use, as required by the regulation.\n− Section 3.10 Data Analysis - stated, “The PM/PE shall select tools based on their\nability to reliably detect corrosion activity both internal and external.” As\npreviously noted, nothing in this section addressed the required selection of ILI tools\ncapable of detecting deformation anomalies such as dents, gouges and grooves.\nSubsequent to the PHMSA inspection, TAPC made minor wording changes to its IMP to\nrequire that an MFL tool be able to detect third party damage, but TAPC’s IMP continued\nto restrict ILI tool selection to MFL tools with other tools being considered only if\nrecommended by the vendor. This wording change was inadequate.\n3. §195.452 Pipeline integrity management in high consequence areas.\n…. (c) What must be in the baseline assessment plan?\n(1) An operator must include each of the following elements in its written\nbaseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An operator must\nassess the integrity of the line pipe by any of the following methods. The methods an\noperator selects to assess low frequency electric resistance welded pipe or lap welded\npipe susceptible to longitudinal seam failure must be capable of assessing seam\nintegrity and of detecting corrosion and deformation anomalies.\n… (B) Pressure test conducted in accordance with subpart E of this part; …\nTAPC’s IMP did not properly address all the assessment methods it selected to complete\nthe baseline assessment of the integrity of its line pipe. That is, TAPC used pressure\ntesting as an assessment method on its pipeline in March 2010, but its IMP only addressed\nILI tools.\n− Section 2.07 Baseline Assessment Method - stated,\n•\n“TPC is using the pressure test performed in December of 2004 as a prior\nassessment. TPC elects not to use this pressure test as its baseline assessment,\nbecause it does not give any indication of future integrity of the pipeline.\n• “The integrity assessment method to be employed by TPC in the development and\ncontinued assessment of pipeline integrity is Inline Inspection (ILI).”\n− Section 3.0 Assessment Procedure - stated, “The TPC pipeline will rely on In-Line\nInspection (ILI) Assessment technique.”\nSubsequent to the inspection, TAPC made minor wording changes to its IMP to explain\nthat pressure testing could be used as an assessment method. In making the change,\nhowever, TAPC did not develop procedures in the IMP for pressure testing nor did it\nchange the Section 3.0 Assessment Procedure to address the use of pressure testing as an\nassessment method beyond the wording change in the lead paragraph. This wording\nchange was inadequate.\n3\n\n\n\n4. §195.452 Pipeline integrity management in high consequence areas.\n.... (f) What are the elements of an integrity management program?\nAn integrity management program begins with the initial framework. An operator\nmust continually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area;\n(2) A baseline assessment plan meeting the requirements of paragraph (c) of this\nsection;\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\n(4) Criteria for remedial actions to address integrity issues raised by the\nassessment methods and information analysis (see paragraph (h) of this section);\n(5) A continual process of assessment and evaluation to maintain a pipeline's\nintegrity (see paragraph (j) of this section);\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n(8) A process for review of integrity assessment results and information analysis\nby a person qualified to evaluate the results and information (see paragraph (h)(2) of\nthis section).\nMany portions of TAPC’s IMP contained written procedures, references, and\nrequirements appropriate for Direct Assessment (DA) and External Control Direct\nAssessment (ECDA), but the IMP does not include DA or ECDA as assessment methods\nnor has TAPC used DA or ECDA as assessment methods. In fact, TAPC’s IMP\nspecifically required the use of ILI for pipeline integrity assessments.\nSpecific examples where TAPC’s IMP discussed DA and ECDA include, but are not\nlimited to,\n− Section 1.01 Glossary\n− Section 2.10 Direct Assessment Plan\n− Section 2.11 Remediating Conditions Found During Direct Assessment\n− Section 4.0 Direct Examination\n− Section 5.0 Post Assessment\n5. §195.452 Pipeline integrity management in high consequence areas.\n…. (f) What are the elements of an integrity management program?\nAn integrity management program begins with the initial framework. An operator\nmust continually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\n4\n\n\n\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n…. (3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nTAPC’s IMP did not include a process for performing an analysis that integrates all the\navailable information about the integrity of its entire pipeline and the consequences of a\nfailure anywhere along its pipeline system.\nTAPC’s IMP did not contain a process for a risk analysis of its pipeline facilities. Section\n2.05 Risk Analysis stated, “Risk assessments will be conducted for the transmission\npipeline and related facilities.” But, an adequate process for performing the risk\nassessment of the pipeline facilities was not included in the IMP.\n6. §195.452 Pipeline integrity management in high consequence areas.\n…. (f) What are the elements of an integrity management program?\nAn integrity management program begins with the initial framework. An operator\nmust continually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n…. (8) A process for review of integrity assessment results and information analysis\nby a person qualified to evaluate the results and information (see paragraph (h)(2) of\nthis section).\nTAPC’s IMP did not include a detailed process for the review of ILI and other integrity\nassessment results. For ILI assessments, TAPC’s IMP\n− did not address or include the consideration of tool tolerances in the evaluation of ILI\ndata or procedures for determining that an ILI run was acceptable.\n− did not adequately address procedures for integrating the results of different types of\nILI tools used to assess the pipeline.\n• Sections 3.03 ILI Tool Selection, 3.10 Data Analysis, and 4.14 Prioritization of\nIndications addressed integrating ILI information in general terms but did not\ninclude detailed procedures to address how TAPC would actually integrate the\ndata.\n• Section 4.14 was written to address prioritization for ECDA, an assessment\nmethod, but TAPC does not allow the use ECDA as an assessment method.\n− did not adequately address procedures for comparing the ILI information with the\nresults of the evaluations of anomalies on the pipeline or the acceptability standards\nfor the comparison.\n− did not adequately address procedures for the re-evaluation of the ILI information\nwhen the results comparing the ILI information to the evaluations of the anomalies on\nthe pipeline did not meet the acceptability standards.\n5\n\n\n\n• Sections 4.24 In Process Evaluation, 4.25 Reclassification And Reprioritization of\nIndications, 4.26 Reprioritization Criteria, and 4.28 Reprioritization Requirements\naddressed reprioritization but the procedures were written for ECDA, which is not\nan assessment method in TAPC’s IMP.\n• The procedures addressed the evaluation of corrosion activity, established\nreprioritization criteria for corrosion activity in Table 3.3.8.1 Reprioritization\nCriteria, and addressed indications based on indirect inspection - ECDA. But the\nprocedures did not address the evaluation of anomalies other than corrosion,\ndespite the fact that TAPC’s ILI assessment tool identified other anomalies such as\ndeformations and dents.\nAlso, TAPC’s IMP addressed the evaluation of the actual pipe in Section 4.0 Direct\nExamination, but this section was written for ECDA. Moreover, Section 4.01 Objectives\nstated that the section was to prioritize pipeline sections which do not have IM repair\nconditions.\nLastly, the direct examination process in Section 4.0 is the process TAPC used to confirm\nIM repair conditions identified during its integrity assessments and information analysis,\nbut the procedure was not written for the assessment methods TAPC used or for the\nintegrity issues that have been identified on TAPC’s pipeline.\n7. §195.452 Pipeline integrity management in high consequence areas.\n…. (h) What actions must an operator take to address integrity issues?\n(1) General requirements. An operator must take prompt action to address all\nanomalous conditions the operator discovers through the integrity assessment or\ninformation analysis. In addressing all conditions, an operator must evaluate all\nanomalous conditions and remediate those that could reduce a pipeline’s integrity.\nAn operator must be able to demonstrate that the remediation of the condition will\nensure the condition is unlikely to pose a threat to the long-term integrity of the\npipeline. An operator must comply with § 195.422 when making a repair.\n(i) Temporary pressure reduction. An operator must notify PHMSA, in\naccordance with paragraph (m) of this section, if the operator cannot meet the\nschedule for evaluation and remediation required under paragraph (h)(3) of this\nsection and cannot provide safety through a temporary reduction in operating\npressure.\n(ii) Long-term pressure reduction. When a pressure reduction exceeds 365 days,\nthe operator must notify PHMSA in accordance with paragraph (m) of this section\nand explain the reasons for the delay. An operator must also take further remedial\naction to ensure the safety of the pipeline.\nWhile TAPC’s IMP addressed taking action for anomalous conditions discovered during\nthe ILI processes, the IMP did not provide clear, consistent, sufficient, and correct\nguidance for taking prompt action to address all anomalous conditions discovered through\nthe integrity assessment or through information analysis.\nFor example,\n− Section 2.11 - incorrectly limited the “prompt action” to those “anomalies and defects\ndiscovered during the In-Line Inspection process.”\n6\n\n\n\n− Section 5.05 - incorrectly stated, “\n… any condition that is likely to pose a threat will\nbe evaluated and any anomalous conditions resulting from integrity assessment will\nbe scheduled for repair within 180 days of its discovery.” The regulations are much\nmore prescriptive as to when anomalies must be repaired - they do not simply default\nto180 days.\n− Section 5.05 - stated “A schedule that prioritizes evaluation and remediation of\nanomalous conditions in accordance with table 3.2.6. Anomalous conditions will be\nclassified as IMMEDIATE (Severe), ONE YEAR (Moderate) or MONITORED (Minor)\nconditions, or Other conditions as specified in ASME/ANSI B31.4, Section 7.” But\n• TAPC’s IMP did not contain a table 3.2.6,\n• The anomalous conditions noted are not per §195.452(h)(4); and,\n• The ASME/ANSI B31.4 reference to Section 7 is not valid.\n8. §195.452 Pipeline integrity management in high consequence areas.\n…. (h) What actions must an operator take to address integrity issues?\n…. (2) Discovery of condition. Discovery of a condition occurs when an operator\nhas adequate information about the condition to determine that the condition\npresents a potential threat to the integrity of the pipeline. An operator must\npromptly, but no later than 180 days after an integrity assessment, obtain sufficient\ninformation about a condition to make that determination, unless the operator can\ndemonstrate that the 180-day period is impracticable.\nTAPC’s IMP did not properly address the discovery of a condition in that it did not\nadequately define when the discovery of a condition occurs, or the requirement to\npromptly obtain sufficient information about a condition to make the determination that it\npresents (or does not present) a potential threat to the integrity of the pipeline.\n− TAPC’s IMP incorrectly established discovery of a condition in its Section 1.01\ndefinition where it stated that discovery occurs at the end of the direct examination\nphase, and in Section 4.15 where discovery is determined to be when proposed\nexcavations for direct examination are determined.\n− The dates established by TAPC’s IMP are not when TAPC has adequate information\nabout the condition to determine that the condition presents a potential threat to the\nintegrity of the pipeline as required by the regulation. Depending on circumstances,\nan operator may have adequate information when the operator receives a preliminary\ninternal inspection report, gathers and integrates information from other inspections,\nor when an operator receives a final internal inspection report.\n− TAPC’s IMP did not adequately address obtaining sufficient information about a\ncondition promptly, but no later than 180 days, after an integrity assessment. Neither\nTAPC’s IMP definition of “Discovery of a Condition” in Section 1.01, Section 2.11,\nits requirement for the Program Manager to meet time requirements in Section 3.09\nQualifications, or its “Repair and Mitigation” requirements in Section 5.05 Exception\nProcess established the requirement to promptly obtain sufficient information about a\ncondition.\n7\n\n\n\n9. §195.452 Pipeline integrity management in high consequence areas.\n…. (h) What actions must an operator take to address integrity issues?\n…. (3) Schedule for evaluation and remediation. An operator must complete\nremediation of a condition according to a schedule prioritizing the conditions for\nevaluation and remediation. If an operator cannot meet the schedule for any\ncondition, the operator must explain the reasons why it cannot meet the schedule and\nhow the changed schedule will not jeopardize public safety or environmental\nprotection.\nTAPC’s IMP did not establish detailed and adequate procedures requiring conditions to be\nevaluated and remediated within the required timelines subsequent to discovery or to\nensure the scheduling of the evaluation and remediation of the conditions was within the\nrequired time frames specified in §195.452(h)(4).\nTAPC’s IMP was not clear where it addressed conditions on a timeline. Various sections\nthe IMP defined repair conditions, stated they will be prioritized to a timeline, covered\nscheduling as it referred to the condition by name (i.e. Immediate, 60 day, 180 day),\ncovered repairing within 180 days of “discovery,” and had requirements for a pressure\nreduction for an “immediate” condition. However, the IMP incorrectly defined\n“discovery” and it did not tie the start of the clock to “discovery” for “60 day”\nconditions.\n10. §195.452 Pipeline integrity management in high consequence areas.\n…. (h) What actions must an operator take to address integrity issues?\n…. (4) Special requirements for scheduling remediation.\n…. (iv) Other conditions. In addition to the conditions listed in paragraphs (h)(4)(i) -\n(iii) of this section, an operator must evaluate any condition identified by an integrity\nassessment or information analysis that could impair the integrity of the pipeline,\nand as appropriate, schedule the condition for remediation. Appendix C contains\nguidance concerning other conditions that an operator should evaluate.\nTAPC’s IMP did not identify “other conditions” that could impair the integrity of the\npipeline or address how TAPC would evaluate and remediate the conditions.\n11. §195.452 Pipeline integrity management in high consequence areas.\n…. (i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(1) General requirements. An operator must take measures to prevent and mitigate\nthe consequences of a pipeline failure that could affect a high consequence area.\nThese measures include conducting a risk analysis of the pipeline segment to identify\nadditional actions to enhance public safety or environmental protection. Such actions\nmay include, but are not limited to, implementing damage prevention best practices,\nbetter monitoring of cathodic protection where corrosion is a concern, establishing\nshorter inspection intervals, installing EFRDs on the pipeline segment, modifying the\nsystems that monitor pressure and detect leaks, providing additional training to\npersonnel on response procedures, conducting drills with local emergency\nresponders and adopting other management controls.\n8\n\n\n\nTAPC’s IMP did not include a systematic decision making process with prioritization and\nfollow-through for evaluating and implementing preventative and mitigative measures\n(PMM). Moreover, TAPC’s IMP did not have fully-developed written procedures for\nevaluating, prioritizing, and implementing PMM. While Section 2.13 Preventative and\nMitigative Measures addressed PMM evaluation in general terms and covered the PMM\nthat TAPC would use, it did not establish a detailed process nor did it include the one\nPMM process TAPC did use.\n12. §195.452 Pipeline integrity management in high consequence areas.\n…. (i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n…. (3) Leak detection. An operator must have a means to detect leaks on its pipeline\nsystem. An operator must evaluate the capability of its leak detection means and\nmodify, as necessary, to protect the high consequence area. An operator's evaluation\nmust, at least, consider, the following factors--length and size of the pipeline, type of\nproduct carried, the pipeline's proximity to the high consequence area, the swiftness\nof leak detection, location of nearest response personnel, leak history, and risk\nassessment results.\nTAPC’s IMP did not include a process to evaluate the capability of its leak detection\nmeans or to modify its leak detection to protect high consequence areas.\n13. §195.452 Pipeline integrity management in high consequence areas.\n…. (i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n…. (4) Emergency Flow Restricting Devices (EFRD). If an operator determines that\nan EFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following factors-\n-the swiftness of leak detection and pipeline shutdown capabilities, the type of\ncommodity carried, the rate of potential leakage, the volume that can be released,\ntopography or pipeline profile, the potential for ignition, proximity to power sources,\nlocation of nearest response personnel, specific terrain between the pipeline segment\nand the high consequence area, and benefits expected by reducing the spill size.\nTAPC’s IMP did not include a process to determine if an emergency flow restricting\ndevice (EFRD) is needed on a pipeline segment to protect a high consequence area in the\nevent of a release, and to install an EFRD if a need for one is determined.\n14. §195.452 Pipeline integrity management in high consequence areas.\n…. (j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n…. (3) Assessment intervals. An operator must establish five-year intervals, not to\nexceed 68 months, for continually assessing the line pipe’s integrity. An operator\nmust base the assessment intervals on the risk the line pipe poses to the high\nconsequence area to determine the priority for assessing the pipeline segments. An\noperator must establish the assessment intervals based on the factors specified in\n9\n\n\n\nparagraph (e) of this section, the analysis of the results from the last integrity\nassessment, and the information analysis required by paragraph (g) of this section.\n− TAPC’s IMP established conflicting requirements for the maximum interval for\ncontinually assessing the line pipe’s integrity. Section 2.12 established the maximum\nreassessment interval as a minimum of 5 years while Section 5.03 required the\nreassessment interval be no longer than 5 years.\n− TAPC’s IMP did not establish the interval for assessing the line pipe’s integrity based\non the factors in §195.452(e), the information analysis required by §19.452(g), and the\nanalysis of the results of the last integrity assessment.\n− TAPC’s IMP only considered the corrosion rate for corrosion defects found during\ndirect examinations when determining the reassessment interval. Section 2.12\nReassessment and Evaluation stated, “After completing the baseline integrity\nassessment, the TPC will continue to assess the pipeline as frequently as needed to\nassure its integrity. The reassessment will be performed by February 17, 2009. A\nmaximum reassessment interval will be established at a minimum of 5 years. Section\n3.0 identifies the continual integrity assessment plan and procedures to be followed by\nTPC.” But TAPC’s IMP did not address determination of the reassessment interval in\nSection 3.0.\n− TAPC’s IMP addressed the determination of the reassessment interval in Section 5.0\nPost Assessment but this section was written for corrosion anomalies and ECDA.\nMoreover, only the corrosion rate established during direct examination of the pipe\nwas considered. It should also be noted that while the procedure covered establishing\nreassessment intervals based on external corrosion, the section was primarily written\nfor an assessment method that TAPC did not use; and, it did not address integrity\nissues that had been identified on TAPC’s pipeline.\n15. §195.452 Pipeline integrity management in high consequence areas.\n…. (j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n…. (5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n(i) Internal inspection tool or tools capable of detecting corrosion and\ndeformation anomalies including dents, gouges and grooves;\nTAPC’s IMP did not properly address the methods TAPC selected to complete the\ncontinual process of assessing the integrity of its line pipe. Also, while the IMP provided\nfor assessment tools capable of detecting corrosion, it did not provide for inspection tools\ncapable of detecting deformation anomalies including dents, gouges and grooves.1\n1 This finding is for the process of continual assessments and is similar to the finding in Item 1 for the baseline assessment.\nFor brevity, the write-up for this item was shortened. However, the operator must amend its IMP to address proper methods\nand tool selection for both the baseline assessment and for the continual assessments.\n10\n\n\n\n16. §195.452 Pipeline integrity management in high consequence areas.\n…. (j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n…. (5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n….. (ii) Pressure test conducted in accordance with subpart E of this part;\nTAPC’s IMP did not include all the assessment methods that TAPC has used to assess its\npipeline. TAPC used pressure testing to assess its pipeline in March 2010, but TAPC’s\nIMP did not include the use of pressure testing as an assessment method for its pipeline.\nTAPC’s IMP states in:\n− Section 2.07 Baseline Assessment Method -“The integrity assessment method to be\nemployed by TPC in the development and continued assessment of pipeline integrity is\nInline Inspection (ILI).”\n− Section 3.0 Assessment Procedure - “The TPC pipeline will rely on In-Line Inspection\n(ILI) Assessment technique.”\nSubsequent to the inspection TAPC made minor wording changes to its IMP to cover\npressure testing as an assessment method. In making the change, however, TAPC did not\ndevelop procedures in the IMP for pressure testing. That is, TAPC’s IMP Section 3.0\nAssessment Procedure has not been modified to address using pressure testing as an\nassessment method beyond the minor wording change in the lead paragraph. This\nwording change was inadequate.\n17. §195.452 Pipeline integrity management in high consequence areas.\n…. (k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting the\nhigh consequence areas. see Appendix C of this part for guidance on methods that\ncan be used to evaluate a program's effectiveness.\nTAPC’s IMP did not establish a procedure for TAPC to use to measure the program\neffectiveness of its IMP beyond a framework. TAPC’s IMP in Section 2.14 Performance\nPlan states the overall requirements for its performance plan evaluation, but it does not\nestablish a detailed procedure which can be used to perform the evaluation.\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\n11\n\n\n\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 60 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 Tampa Airport Pipeline Corporation maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/ revision of plans, procedures) and submit the total to\nWayne T. Lemoi, Director, Southern Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to\nCPF 2-2012-6018M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n12\n\n220126018M_Closure letter_10032013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 3, 2013\nMr. Robert L. Rose\nPresident\nTampa Airport Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2012-6018M\nDear Mr. Rose:\nOn November 8-10, 2011, and March 22, 2012, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Southern Region, Office of Pipeline\nSafety inspected the Tampa Airport Pipeline Corporation (TAPC) Pipeline Integrity\nManagement Plan (IMP) in Tampa, Florida, pursuant to Chapter 601 of 49 United States\nCode. As a result of the inspection, the Southern Region issued a Notice of Amendment\n(NOA) to TAPC on October 2, 2012.\nThe Southern Region granted one 53-day extension on December 18, 2012, for TAPC to\nprovide revised procedures. Subsequent to that grant of extension, we received and reviewed\nthree responses to the NOA dated January 23, 2013, April 12, 2013, and August 9, 2013. In\neach case we identified additional deficiencies.\nWe received and reviewed your latest response to the NOA dated September 23, 2013. This\nletter is to inform you that TAPC has complied with the terms of the NOA and that no further\naction is necessary with regards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2012-6018M) and not to any\nother PHMSA pending cases.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":36439}