{"operation":"document","citation":"CPF 220175002M","title":"MID - VALLEY PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-12","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220175002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220175002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220175002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220175002M","body":"Notice of Amendment involving MID - VALLEY PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2017-04-12 and is reported as closed as of 2017-11-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220175002M_Closure Letter_11142017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Closure%20Letter_11142017.pdf\n\n220175002M_Notice of Amendment_0412017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Notice%20of%20Amendment_0412017_text.pdf\n\n220175002M_Notice of Amendment_04122017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Notice%20of%20Amendment_04122017.pdf\n\n220175002M_Operator Response to Notice_05172017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220175002M/220175002M_Operator%20Response%20to%20Notice_05172017.pdf\n\n220175002M_Notice of Amendment_0412017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 12, 2017\nMr. David Chalson\nSenior Vice President, Operations\nMid-Valley Pipeline Company\n401 Market Street\nAston, PA 19014\nCPF 2-2017-5002M\nDear Mr. Chalson:\nOn September 12-15, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the\nMid-Valley Pipeline Co. (MVPL) corrosion control procedures and records at your office in\nHebron, Kentucky, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within the\nMVPL written corrosion control procedures as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by paragraph\n(a) of this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) …\n(3) Operating, maintaining, and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of this part.\nMVPL’s corrosion control procedures do not contain adequate instruction on entering\ndata into MVPL’s corrosion control database.\nMVPL Procedure OQP-011, titled Conduct Annual Survey, includes the following\nsections, as related to corrosion control data entry:\n1.10. DOCUMENT all readings on the appropriate record form OR CAPTURE\nreading with data logger.\n\n\n\n1.11. RECORD OR TRANSFER readings onto appropriate computer program AND\nREPORT all measurements to the SPLP Engineering Department.”\nPer field interviews and PHMSA record review, MVPL personnel regularly enter values\nof “999”, “-999” or “0” into the corrosion database as a means of indicating that a valid\npipe-to-soil (p/s) potential reading could not be made at a given test station. MVPL\nProcedure OQP-011 referenced above does not contain any instruction on this practice.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that MVPL maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/ revision of plans,\nprocedures) and submit the total to the Director, Southern Region – Office of Pipeline Safety,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 2-2017-5002M and, for each document you submit, please\nprovide a copy in electronic format whenever possible.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n2\n\n220175002M_Closure Letter_11142017.pdf\n\n•\nU.S. Department\n233 Peachtree Street Ste. 600\nof Transportation\nAtlanta, GA 30303\nPipeline and\nAdministration\nHazardous Materials Safety\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 14, 2017\nMr. David Chalson\nSenior Vice President, Operations\nMid-Valley Pipeline Company\n401 Market Street\nAston, PA 19014\nCPF 2-2017-5002M\nDear Mr. Chalson:\nOn September 12-15, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the\nMid-Valley Pipeline Co. (MVPL) corrosion control procedures and records at your office in\nHebron, Kentucky, pursuant to Chapter 601 of 49 United States Code. As a result of the\ninspection, PHMSA issued a Notice of Amendment (NOA) on April 12, 2017.\nThe OPS Southern Region has received and reviewed MVPL's response dated May 17, 2017.\nBased on our review of these responses we have determined that MVPL has complied with\nthe terms of the NOA. This case is now closed and no further action is necessary with respect\nto the matters involved in this case.\nPlease be advised that this letter refers only to the referenced NOA (CPF 2-2017-5002M) and\nnot to any other PHMSA cases, if any.\nSincerely,\nI-ce\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220175002M_Notice of Amendment_04122017.pdf\n\nU.S. Department\n233 Peachtree Street Ste. 600\nof Transportation\nAtlanta, GA 30303\nHazardous Materials Safety\nPipeline and\nAdministration\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 12, 2017\nMr. David Chalson\nSenior Vice President, Operations\nMid-Valley Pipeline Company\n401 Market Street\nAston, PA 19014\nCPF 2-2017-5002M\nDear Mr. Chalson:\nOn September 12-15, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the\nMid-Valley Pipeline Co. (MVPL) corrosion control procedures and records at your office in\nHebron, Kentucky, pursuant to Chapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within the\nMVPL written corrosion control procedures as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a)\n(c)\nMaintenance and normal operations. The manual required by paragraph\n(a) of this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1)\n(3) Operating, maintaining, and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of this part.\nMVPL's corrosion control procedures do not contain adequate instruction on entering\ndata into MVPL's corrosion control database.\nMVPL Procedure OQP-011, titled Conduct Annual Survey, includes the following\nsections, as related to corrosion control data entry:\n1.10.DOCUMENT all readings on the appropriate record form OR CAPTURE\nreading with data logger.\n\n\n\n1.11. RECORD OR TRANSFER readings onto appropriate computer program AND\nREPORT all measurements to the SPLP Engineering Department.\"\nPer field interviews and PHMSA record review, MVPL personnel regularly enter values\nof \"999\", \"-999\" or \"O\" into the corrosion database as a means of indicating that a valid\npipe-to-soil (p/s) potential reading could not be made at a given test station. MVPL\nProcedure OQP-011 referenced above does not contain any instruction on this practice.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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 quality 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed\nIt is requested (not mandated) that MVPL maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/ revision of plans,\nprocedures) and submit the total to the Director, Southern Region - Office of Pipeline Safety,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 2-2017-5002M and, for each document you submit, please\nprovide a copy in electronic format whenever possible.\nSincerely,\nDerick h. Turner\nFor James A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n2","truncated":false,"body_characters":11442}