{"operation":"document","citation":"CPF 220135001M","title":"TRI-STATES NGL PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-01-29","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(d)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220135001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220135001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220135001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220135001M","body":"Notice of Amendment involving TRI-STATES NGL PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(d)(1). The case was opened on 2013-01-29 and is reported as closed as of 2013-04-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220135001M_closure letter_04022013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135001M/220135001M_closure%20letter_04022013.pdf\n\n220135001M_closure letter_04022013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135001M/220135001M_closure%20letter_04022013_text.pdf\n\n220135001M_notice of amendment_01292013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135001M/220135001M_notice%20of%20amendment_01292013.pdf\n\n220135001M_notice of amendment_01292013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135001M/220135001M_notice%20of%20amendment_01292013_text.pdf\n\n220135001M_Operator Response to Notice_03222013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135001M/220135001M_Operator%20Response%20to%20Notice_03222013.pdf\n\n220135001M_closure letter_04022013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 2, 2013\nMr. Steve Pankhurst\nBusiness Unit Leader\nTri-States NGL Pipeline LLC\n150 West Warrenville Road\nNaperville, IL 60563\nCPF 2-2013-5001M\nDear Mr. Pankhurst:\nOn June 18-22, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety conducted an on-site\npipeline safety inspection of the Tri-States NGL Pipeline, LLC (Tri-States) written\nOperations, Maintenance, and Emergency Response Manual (OMER) in Moss Point,\nMississippi, pursuant to Chapter 601 of 49 United States Code. As a result of the inspection,\nPHMSA issued Tri-States a Notice of Amendment (NOA) on January 29, 2013.\nThe PHMSA Southern Region reviewed the amended procedures Tri-States submitted to us\non March 22, 2013, and find them adequate. This letter is to inform you that Tri-States has\ncomplied with the terms of the NOA and that no further actions are necessary with regards to\nthe NOA. This case is now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2013-5001M) and not to any\nother PHMSA pending cases, if any. Also be advised that nothing herein states or implies that\nthe above described OMER procedures meet the requirements of the federal pipeline safety\nregulations or that the OMER procedures are approved. The pipeline system and OMER\nprocedures remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220135001M_notice of amendment_01292013_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nCPF 2-2013-5001M\nJanuary 29, 2013\nMr. Steve Pankhurst\nBusiness Unit Leader\nTri-States NGL Pipeline LLC\n150 West Warrenville Road\nNaperville, IL 60563\nDear Mr. Pankhurst:\nOn June 18-22, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety inspected the\nTri-States NGL Pipeline, LLC (Tri-States) written Operations, Maintenance, and Emergency\nResponse Manual (OMER) at your Moss Point, Mississippi office pursuant to Chapter 601 of\n49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within Tri-States\nwritten OMER procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n... (d) Abnormal operation. The manual required by paragraph (a) of this section must\ninclude procedures for the following to provide safety when operating design limits have\nbeen exceeded:\n(1) Responding to, investigating, and correcting the cause of:\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating limits;\n(iii) Loss of communications;\n(iv) Operation of any safety device;\n(v) Any other malfunction of a component, deviation from normal operation, or\npersonnel error which could cause a hazard to persons or property.\nTri-State’s procedures for abnormal operation did not require Tri-States to investigate and\ndetermine the cause of all abnormal operations and did not clearly explain how Tri-States\nwould investigate abnormal operations.\nTri-States OMER procedure P-195.402(d) Abnormal Operations, Section A, General\nconveyed: “Those events potentially involving equipment failure or those, which cannot be\ncleared from the Control Center, will be referred to the appropriate field maintenance\npersonnel for further investigation and resolution.” This was inadequate as highlighted in\n\n\n\n− Section B.1. Unintended/Unexplained Valve Closure where an unintended or unexplained\nvalve closure would only be investigated and documented by creating a MAXIMO Work\nRequest using Job Plan UG 1976 if the control center was unable to re-open the valve; and,\n− Section B.2. Unintended/Unexplained Station Shutdown where an unintended or unexplained\nstation shutdown would only be investigated and documented by creating a work request if\nthe fault condition cannot be cleared [AND] the station is needed for current operations.\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 Tri-States NGL Pipeline 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,\nSouthern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 2-2013-5001M 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":7577}