{"operation":"document","citation":"CPF 220135003M","title":"COLLINS PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-04-02","effective_on":null,"summary":"CLOSED notice of amendment citing 195.52(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220135003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220135003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220135003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220135003M","body":"Notice of Amendment involving COLLINS PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.52(c). The case was opened on 2013-04-02 and is reported as closed as of 2013-05-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220135003M_Closure letter_05202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135003M/220135003M_Closure%20letter_05202013.pdf\n\n220135003M_Closure letter_05202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135003M/220135003M_Closure%20letter_05202013_text.pdf\n\n220135003M_notice of amendment_04022013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135003M/220135003M_notice%20of%20amendment_04022013_text.pdf\n\n220135003M_notice of amendment_04022313.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135003M/220135003M_notice%20of%20amendment_04022313.pdf\n\n220135003M_Operator Response with Revised Procedures_05022013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220135003M/220135003M_Operator%20Response%20with%20Revised%20Procedures_05022013.pdf\n\n220135003M_notice of amendment_04022313.pdf\n\nU.S. Department\n233 Peachtree Street Ste. 600\nof Transportation\nAtlanta, GA 30303\nPipeline and\nAdministration\nHazardous Materials Safety\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 2, 2013\nMs. Meredith D. West\nJoint Interest Director\nCollins Pipeline Company\n800 Bell Street\nHouston, Texas 77002\nCPF 2-2013-5003M\nDear Ms. West:\nFrom November 5-8, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Southern Region inspected the Collins\nPipeline Company (Collins) pipeline system's written Operations and Maintenance (O&M)\nprocedures in Collins, Mississippi, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy within the\nCollins written O&M procedures as described below:\n1. 8195.52 Immediate notice of certain accidents.\n... (c) Calculation. A pipeline operator must have a written procedure to calculate\nand provide a reasonable initial estimate of the amount of released product.\nCollins' written O&M procedures regarding the reporting of certain accidents did not\nallow Collins to adequately calculate and provide a reasonable initial estimate of the\namount of released product for all circumstances.\nCollins' written O&M procedure DOT Liquid Manual, Part 195-Subpart B Procedure\n195.52 Immediate Notice of Certain Accidents provided a formula \"For liquid spills if the\nvolume is not otherwise easily estimated.\" The formula allows for the calculation of a\nspilled liquid volume in contaminated soil by multiplying the calculated contaminated\nsoil volume by a porosity factor to determine an initial spill volume. The procedure did\nnot, however, provide a means for the reasonable initial estimate of the amount of\nreleased product to be calculated when a release occurs in water, at night, in limited\nvisibility conditions, and/or other possible release scenarios.\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 inadequacy\nidentified herein has been addressed in your amended procedures, this enforcement action will\nbe closed.\nIt is requested (not mandated) that Collins Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/\nrevision of plans, procedures) and submit the total to Wayne T. Lemoi, Director, Southern\nRegion, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 2-2013- 5003M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nWayne Lemon ene\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n2\n\n220135003M_notice of amendment_04022013_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 2, 2013\nMs. Meredith D. West\nJoint Interest Director\nCollins Pipeline Company\n800 Bell Street\nHouston, Texas 77002\nCPF 2-2013-5003M\nDear Ms. West:\nFrom November 5-8, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Southern Region inspected the Collins\nPipeline Company (Collins) pipeline system’s written Operations and Maintenance (O&M)\nprocedures in Collins, Mississippi, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy within the\nCollins written O&M procedures as described below:\n1. §195.52 Immediate notice of certain accidents.\n... (c) Calculation. A pipeline operator must have a written procedure to calculate\nand provide a reasonable initial estimate of the amount of released product.\nCollins' written O&M procedures regarding the reporting of certain accidents did not\nallow Collins to adequately calculate and provide a reasonable initial estimate of the\namount of released product for all circumstances.\nCollins' written O&M procedure DOT Liquid Manual, Part 195-Subpart B Procedure\n195.52 Immediate Notice of Certain Accidents provided a formula “For liquid spills if the\nvolume is not otherwise easily estimated.” The formula allows for the calculation of a\nspilled liquid volume in contaminated soil by multiplying the calculated contaminated\nsoil volume by a porosity factor to determine an initial spill volume. The procedure did\nnot, however, provide a means for the reasonable initial estimate of the amount of\nreleased product to be calculated when a release occurs in water, at night, in limited\nvisibility conditions, and/or other possible release scenarios.\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 inadequacy\nidentified herein has been addressed in your amended procedures, this enforcement action will\nbe closed.\nIt is requested (not mandated) that Collins Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/\nrevision of plans, procedures) and submit the total to Wayne T. Lemoi, Director, Southern\nRegion, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 2-2013- 5003M 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\n220135003M_Closure letter_05202013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 20, 2013\nMs. Meredith D. West\nJoint Interest Director\nCollins Pipeline Company\n800 Bell Street\nHouston, Texas 77002\nCPF 2-2013-5003M\nDear Ms. West:\nFrom November 5-8, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Southern Region inspected the Collins\nPipeline Company (Collins) pipeline system’s written Operations and Maintenance (O&M)\nprocedures in Collins, Mississippi, pursuant to Chapter 601 of 49 United States Code. As a\nresult of the inspection, PHMSA issued a Notice of Amendment (NOA) on April 2, 2013.\nThe Collins Pipeline uses the ExxonMobil Pipeline Company's O&M.\nThe PHMSA Southern Region received ExxonMobil Pipeline Company's response to the\nNOA on behalf of Collins via email on May 1, 2013. After we provided feedback relating to\nthe initial response to ExxonMobil, we received a corrected response from ExxonMobil on\nMay 2, 2013, via email. Upon review of the aforementioned responses, we find Collins’\namended procedures adequate. This letter is to inform you that Collins has complied with the\nterms of the NOA and that no further action is necessary with regards to the NOA. This case\nis now closed.\nPlease be advised that this letter refers only to the NOA (CPF 2-2013-5003M) and not to any\nother PHMSA pending cases. Also be advised that nothing herein states or implies that the\nCollins O&M meets the requirements of the federal pipeline safety regulations or that the\nO&M is approved. The pipeline system and O&M remain subject to inspection by PHMSA.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":11397}