{"operation":"document","citation":"CPF 320025001H","title":"WOLVERINE PIPELINE COMPANY — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2002-02-25","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320025001h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320025001h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320025001h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320025001H","body":"Corrective Action Order involving WOLVERINE PIPELINE COMPANY. The dataset does not identify a cited regulation for this case. The case was opened on 2002-02-25 and is reported as closed as of 2011-01-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320025001H_CAO_02252002.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320025001H/320025001H_CAO_02252002.pdf\n\n320025001H_Closure Letter_01262011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320025001H/320025001H_Closure%20Letter_01262011.pdf\n\n320025001H_Closure Letter_01262011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320025001H/320025001H_Closure%20Letter_01262011_text.pdf\n\ncpf 320025001h wolv cao .pdf: https://primis.phmsa.dot.gov/enforcement-documents/320025001H/cpf%20320025001h%20wolv%20cao%20.pdf\n\n320025001H_Closure Letter_01262011_text.pdf\n\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nJanuary 26, 2011\nMr. John Gurrola\nVice President and Manager\nWolverine Pipe Line Company\n8075 Creekside Drive, Suite 210\nPortage, MI 49024-5251\nCPF 3-2002-5001H\nDear Mr. Gurrola:\nOn February 25, 2002, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued a Corrective Action Order (Order) to Wolverine Pipe Line Company in the above-\nreferenced case. This Order included requirements to take corrective actions on your pipeline.\nBased upon our field monitoring of the corrective actions taken and a review of the\ndocumentation you provided, it has been determined that you complied with the terms of the\nOrder.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n\ncpf 320025001h wolv cao .pdf\n\nMr. Robert C. Luckner, President\nWolverine Pipe Line Company\nExxonMobil\nBox 2220\nHouston, TX 77252-2220\nRe: Wolverine/ExxonMobil CPF No. 3-2002-5001-H\nDear Mr. Luckner:\nEnclosed is a Corrective Action Order and Notice Proposing to Amend the Order following an\nOpportunity for a Hearing issued by the Associate Administrator for Pipeline Safety in the above-\nreferenced case. The Order portion of the document places a pressure restriction on the line segment\nfrom Kennedy Avenue to Freedom Junction. The Notice portion of the document proposes to amend\nthe Order to address the internal inspection of the Kennedy Avenue to Niles loop line and the\nKennedy Avenue to Vicksburg mainline.\nService is being made by certified mail and facsimile. Your receipt of the enclosed document\nconstitutes service of that document. The terms and conditions of this Corrective Action Order are\neffective upon receipt.\nSincerely,\nGwendolyn M. Hill\nPipeline Compliance Registry\nOffice of Pipeline Safety\ncc: Leslie Cole, Vice-President of Wolverine\nEnclosure\nVIA CERTIFIED MAIL (RETURN RECEIPT REQUESTED) AND TELECOPY\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nWASHINGTON, DC 20590\n------------------------------------------------------\n)\nIn the Matter of )\nWolverine Pipe Line Company/ ) CPF No. 3-2002-5001-H\nExxonMobil )\nRespondent. )\n-------------------------------------------------------\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order is being issued, under authority of 49 U.S.C. § 60112, to require\nWolverine Pipe Line Company/ExxonMobil (Respondent) to take the necessary corrective action\nto protect the public and environment from potential hazards associated with Respondent’s 16-inch\nmainline which extends from the Kennedy Avenue pump station in Indiana to the Freedom Junction\npump and metering station in Michigan. On January 8, 2002, Wolverine reported that, due to safety-\nrelated conditions, it lowered the maximum operating pressure of the Vicksburg to Freedom\nJunction segment of the pipeline in Michigan, lowered the maximum discharge pressure of the\nupstream Kennedy Avenue Pump Station in Indiana, and adjusted the discharge pressure shutdown\nat all the pump stations.\nOn January 2, 2002, Respondent received the results of an internal inspection that was conducted\nusing an ultrasonic internal inspection tool on August 14, 2001. The internal inspection revealed\napproximately 715 anomalies on the pipeline that were pressure rated less than the maximum\noperating pressure (MOP) of 1250 psig, with the most critical location as calculated to have a\nremaining strength of 561 psig. On January 8, 2002, Respondent filed Safety-Related Condition\nReport No. 2002-0001 with the Office of Pipeline Safety(OPS).\nPursuant to 49 U.S.C. § 60117, the Central Region, OPS, initiated an investigation of the safety-\nrelated conditions.\nPreliminary Findings\nOn August 14, 2001, an internal inspection was performed on Respondent’s 16-inch mainline\nbetween Vicksburg, MI pump station (MP 117.1) and the Freedom Junction pump and meter\nstation (198.5) near Manchester, MI.\n1.\n\n\n\n2\n2. On January 2, 2002, Respondent received the results of the internal inspection, which revealed\napproximately 715 anomalies that required a maximum operating pressure (MOP) reduction.\n3. On January 3, 2002, Respondent’s personnel reduced the maximum discharge pressure to 560\npsig at the Michigan City (MP 38.1) and Dailey (MP 79.4) pump stations, upstream of the\naffected pipeline segment. The discharge pressure of the two pump stations in the affected\npipeline segment, Vicksburg (MP 117.1) and Albion (MP 156.9) pump stations, was lowered\nto 560 psig, and the discharge shutdown pressure at all the pump stations was lowered to 600\npsig.\n4. On January 8, 2002, Respondent filed Safety-Related Condition Report #2002-0001. The\nreport provided information about the unsafe condition and the lowering of the MOP of the\nVicksburg to Freedom Junction segment in Michigan from 1250 psig to 560 psig, the lowering\nof the maximum discharge pressure of the upstream Kennedy Avenue Pump Station in Indiana\nto 660 psig, and the adjustment of the discharge pressure shutdown to 600 psig at Michigan\nCity, Dailey, Vicksburg, and Albion pump stations, and to 700 psig at Kennedy Avenue.\n5. On January 25, 2002, Respondent adjusted the maximum discharge pressure at the Kennedy\nAvenue Station and Michigan City Station to 750 psig and adjusted the discharge pressure\nshutdown to 800 psig.\n6. The length of the affected segment of the pipeline, Vicksburg to Freedom Junction, is\napproximately 81 miles.\n7. The 715 anomalies on the pipeline were pressure rated less than the MOP of 1250 psig, with\nthe most critical location as calculated to have a remaining strength of 561 psig.\n8. Calculations for remaining pipe strength were made using ASME/ANSI B31G. As a result of\nthese calculations, the following table shows the number of anomalies associated with specific\nmaximum operating pressure ranges.\nNumber of anomalies New MOP range (psig)\n14 561 - 750\n17 751 - 850\n78 851 - 960\n171 961 - 1050\n186 1051 - 1150\n249 1151 - 1250\nTotal number of anomalies 715\n9. Respondent plans to recalculate remaining pipe strength using RSTRENG, (AGA Pipeline\nResearch Committee Project PR-3-805). RSTRENG calculations are considered to be an\naccurate but less conservative means of determining pipe remaining strength. The 100 most\nsevere anomalies are to be recalculated using RSTRENG by January 21, 2002, with the\nremaining anomalies to be recalculated by February 4, 2002.\n\n\n\n3\n10. Wolverine is headquartered in Houston, TX and operates 1,100 miles of petroleum products\npipeline in the Midwest.\n11. The mainline originates in Joliet, IL moves east into northwest Indiana at the Kennedy Avenue\npump station and enters southwest Michigan. The line moves in a northeasterly direction to\nJackson, MI then continues east to Detroit. The affected segment lies between the Vicksburg\nstation and the Freedom Junction station.\n12. The 16-inch mainline transports gasoline, diesel fuel and jet fuel.\n13. The 16-inch mainline is routed through both rural and urban areas. The affected line segment\npasses through several small communities, as well as crossing numerous state and interstate\nhighways, rivers, streams, and a railroad line.\n14. The pipeline was installed in 1953 and is constructed of 16-inch x 0.312-inch w.t., X-48,\nprimarily seamless pipe manufactured by U.S. Steel Corporation. Original construction records\nindicate that both ERW (electric resistance welded) and seamless pipes were installed. The\noriginal line was installed bare with no protective coating. Somastic coating and concrete\ncoating were applied to pipe that was installed in wetlands.\n15. Since 1953, numerous segments of the line have been replaced by ERW pipe due to reroute and\nrefurbishment. The replacement pipe consisted of 0.312-inch and 0.375-inch w.t., X-52 coated\npipe.\n16. Cathodic protection of the 16-inch mainline is provided by rectifiers and anodes.\n17. For cathodic protection purposes, this line section is essentially bare. In 1992, a close interval\nsurvey was conducted, and Respondent reported that pipe-to-soil potentials were considered\nadequate at that time.\n18. In 1992, Respondent internally inspected this pipeline with a low resolution, magnetic flux\nleakage (MFL) internal inspection tool. The Vicksburg to Freedom Junction line segment was\ngraded by joints, based on anomaly severity. Fifteen (15) pipe joints were graded as severe and\nfive-hundred and thirty (530) pipe joints were graded as moderate. The grading criteria used\nwas light corrosion (15 to 29% wall loss), moderate corrosion (30 to 49% wall loss) and severe\ncorrosion (50% and greater wall loss). Full sole repairs were made on all fifteen (15) pipe\njoints graded as severe and two (2) of the pipe joints graded as moderate.\n19. In 1990, Respondent internally inspected the Kennedy Station to Niles Station loop line (1953\npipe) with a low resolution, magnetic flux leakage (MFL) internal inspection tool and\nreconditioning was done with plans to run an ultrasonic and caliper internal inspection tool in\n2002.\n\n\n\n4\n20. 21. 22. 23. In 1992, Respondent internally inspected the Kennedy Station to Vicksburg mainline with a low\nresolution, MFL internal inspection tool and reconditioning was done with plans to run an\nultrasonic and caliper internal inspection tool in 2002.\nIn 1992, Respondent internally inspected the Freedom Junction to Detroit mainline with a low\nresolution, MFL internal inspection tool. As a result of this survey, several miles of pipeline\nwas replaced in the mid-1990's. In 1999, an ultrasonic and caliper internal inspection tool was\nrun and repairs were made in 2000 and 2001. Although a pressure reduction was taken as a\nresult of this survey, no Safety-Related Condition Reports were filed.\nNo non-reportable leaks have resulted due to corrosion, mill defects or mechanical damage.\nTwo reportable leaks have occurred on the Vicksburg to Freedom Junction line segment:\n< On January 20, 1994, a densitometer leaked at the Jackson meter station, causing a\n52-barrel leak.\n< On June 7, 2000, a stopple fitting weld failed at the Jackson meter station causing\na rupture releasing 75,000 gallons of gasoline into the environment and causing the\nevacuation of more than 500 homes in Blackman Township, Michigan. The failure\ncaused the shutdown of 30% of Michigan’s gasoline supplies for nine days,\ncontaminated a creek which flows into the Grand River, and a railroad track near the\nfailure site was shut down for a week.\n24. Respondent is currently developing a short-term and long-term reconditioning program to\nbring the line back to the original MOP of 1250 psig, with plans to increase the operating\npressure in several stages.\nRespondent is currently maintaining a pressure reduction on the segment.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action, which\nmay include the suspended or restricted use of a pipeline facility, physical inspection, testing, repair,\nreplacement, or other action as appropriate. The basis for making the determination that a pipeline\nfacility is hazardous, requiring corrective action, is set forth both in the above referenced statute and\n49 C.F.R. §190.233, a copy of which is enclosed.\nSection 60112, and the regulations promulgated thereunder, provides for the issuance of a Corrective\nAction Order without prior opportunity for notice and hearing upon a finding that failure to issue\nthe Order expeditiously will result in likely serious harm to life, property or the environment. In such\ncases, an opportunity for a hearing will be provided as soon as practicable after the issuance of the\nOrder.\n25.\n\n\n\n5\nAfter evaluating the foregoing preliminary findings of fact, I find that the continued operation of this\npipeline without corrective measures would be hazardous to life, property and the environment.\nAdditionally, after considering the circumstances surrounding the 715 anomalies found by internal\ninspection, the proximity of the pipeline to populated areas, the line’s proximity to public highways\nand railway, the proximity of the pipeline to rivers and streams and areas in which people may\ngather, the highly combustible product the pipeline transports, the pressure required for transporting\nthe material, and the uncertainties as to the cause of the anomalies, I find that a failure to issue\nexpeditiously this Order, requiring immediate corrective action, would result in likely serious harm\nto life, property, and the environment.\nAccordingly, this Corrective Action Order mandating needed immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Wolverine may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by telecopy at (202) 366-4566. The hearing will be held in Kansas City,\nMissouri or Washington, DC on a date that is mutually convenient to OPS and Respondent.\nAfter receiving and analyzing additional data in the course of this investigation, OPS may identify\nother longer term measures that need to be taken. Wolverine will be notified of any additional\nmeasures required and amendment of this Order will be considered. To the extent consistent with\nsafety, Wolverine will be afforded notice and an opportunity for a hearing prior to the imposition\nof any additional corrective measures.\nRequired Corrective Action\nPursuant to 49 U.S.C. § 60112, I hereby order Wolverine to immediately take the following\ncorrective actions with respect to its 16-inch mainline pipeline, between the Vicksburg pump station\n(Vicksburg) and Freedom Junction pump and metering station ( Freedom Junction) in Michigan:\n1. Maintain the pressure reduction on the line segment, between Vicksburg and Freedom Junction.\nMaximum operating pressure from Vicksburg to Freedom Junction is not to exceed 560 psig\nand the maximum discharge pressure at the Kennedy Pump Station and the Michigan City Pump\nStation is not to exceed 750 psig. This restriction shall remain in place until written approval is\nobtained from the Director, Central Region.\n2. Develop a written repair plan to ensure the integrity of the line segment which includes\nprovisions for:\na) Identification and evaluation of anomalies that could threaten pipeline integrity and require\nrepair.\nb) Criteria and method for evaluation of anomalies detected by the internal inspection tool;\n\n\n\n6\n3. 4. 5. 6. 7. c) Criteria and method for repair and removal of anomalies;\nd) Testing to be conducted to confirm the soundness of repairs, and\ne) Provisions for evaluation and remediation in High Consequence Areas (HCA’s), as identified\nin Section 195.450, in accordance with the provisions of Section 195.452.\nDevelop a written plan for remedial action to mitigate the continuing growth and occurrence of\nanomalies identified by the internal inspection tool and by any other means during execution of\nthe repair program. The written plan should include provisions for:\na) Determination of the cause and contributing factors to the occurrence and continuing growth\nof anomalies.\nb) Determination of the cause and contributing factors for any additional anomalies detected by\nmeans other than the internal inspection tool, i.e. visual observation.\nc) Performance of appropriate survey and/or testing programs to be used in regard to Items 3(a)\nand 3(b) above.\nd) Performance of close-interval, current interrupted, pipe-to-soil potential surveys and other\nappropriate testing to determine the adequacy of the corrosion control applied to the pipeline\nafter repairs have been made.\nSubmit the written plans for Items 2 & 3, addressing repair and remedial action, to the Director,\nCentral Region, for review.\nEach element of the plan must be approved by the Director, Central Region, who may provide\napprovals incrementally. Implement the plan as approved.\nProvide detailed reports to the Director, Central Region, of findings and actions taken to repair\nthe pipeline identifying the anomalies detected and evaluated, their location circumferentially\non the pipe, the coating status of the pipe, the characterization of the anomalies (type and size\nof defect), the severity of the anomaly, and the repair action taken, including the size predicted\nby the internal inspection tool and the actual size. Additionally, provide a summary by type of\ndefect of the number of anomalies identified by the tool, the number of actual anomalies found,\nand number repaired.\nRespondent may request approval from the Director, Central Region to remove or modify the\npressure restriction of the line segment between the Kennedy Avenue pump station in Indiana\nto the Freedom Junction pump and metering station in Michigan based on showing that the\nhazard has been abated and that a higher pressure is justified based on an analysis showing that\nthe pressure increase is safe considering all known defects, anomalies and operating parameters\nof the pipeline. The request should include a justification to modify the pressure restriction of\n\n\n\n7\n8. 9. the line with consideration given to the final results of all testing and activities conducted\npursuant to Items 2 through 4 and Item 6 of this Order. The Regional Director's determination\nwill be based on satisfactory completion of these requirements and evidence that mitigative\nactions taken by the operator provide for the safe operation of the pipeline.\nThe Director, Central Region, may grant an extension of time for compliance with any of the\nterms of this order for good cause. A request for an extension must be in writing.\nRespondent may appeal any decision of the Director, Central Region to the Associate\nAdministrator for Pipeline Safety. Decisions of the Associate Administrator shall be final.\nThe procedures for the issuance of this Order are described in Part 190, Title 49, Code of Federal\nRegulations, § 190.233, a copy of which is enclosed, is made part of this Order and describes the\nRespondents’ procedural rights relative to this Order.\nFailure to comply with this Order may result in the assessment of civil penalties of not more than\n$25,000 per day and in referral to the Attorney General for appropriate relief in United States\nDistrict Court.\nProposed Amendment to this Order to Address Integrity - Proposed Corrective Measures;\nWolverine’s Right to a Hearing\nFor the foregoing preliminary findings of fact, I also propose to find that the continued operation\nof the original construction 16-inch loop line from Kennedy Avenue to Niles and the 16-inch\nmainline from Kennedy Avenue to Vicksburg without corrective measures to address pipe installed\nduring 1953 is hazardous to life, property, and the environment. Although some segments of the line\nhave been replaced by ERW, 0.312-inch and 0.375-inch w.t., X-52 coated pipe due to rerouting and\nrefurbishment, the 1953 original line was installed bare with no protective coating which increases\nsafety concerns about the integrity of the pipeline from Niles (MP 67.5) to Vicksburg (MP 117.1)\nand Vicksburg to Freedom Junction (MP198.5) and the loop line from Kennedy(MP 0) to Niles (MP\n67.5). Concern for the continued safe operation of this pipe is heightened by the large number of\npressure reducing anomalies detected by the internal inspection tool survey from Vicksburg to\nFreedom Junction segment of the pipeline. The 16-inch mainline from Niles to Freedom Junction\nand the loop line from Kennedy Avenue to Niles consist of original 1953 bare pipe. Further, the\nsame corrosion control practices were used on these pipeline segments. The loop line transports the\nsame product as the 16-inch mainline. The loop line follows the mainline route from Kennedy to\nNiles where it turns northward and extends to Grand Haven, Michigan. The pipe from Niles to\nGrand Haven was installed in 1973.\nAccordingly, I propose to amend the Corrective Action Order to require Wolverine to take the\nfollowing actions with respect to its original construction 16-inch loop line and 16-inch mainline\nfor the portions containing 1953 pipe:\n\n\n\n8\n10. Following the completion of required corrective actions and approval by the Director, Central\nRegion to increase pressure from Vicksburg to Freedom Junction, maintain a pressure reduction\non the line segment, between Kennedy Avenue and Vicksburg, of 30% of the 1250 psig MOP,\nor 30% of the normal operating pressure, whichever is less.\n11. Maintain a pressure reduction on the loop line segment, between Kennedy Avenue and Niles,\nof 30% of the MOP, or 30% of the normal operating pressure, whichever is less.\n12. The pressure restrictions required in Items 10 and 11 shall remain in place until written approval\nis obtained from the Director, Central Region, to increase the pressure. This approval will be\nbased on a showing by Respondent that an appropriate integrity plan, as required for the\nVicksburg to Freedom Junction segment, has been established and conducted, and that any\nremedial measures necessary to be taken provide assurance that anomalies and defects that\nthreaten the integrity of the pipeline have been repaired or removed, including mitigative\ncorrosion control actions. The plan for this work must be submitted to the Director, Central\nRegion, within 60 days of receipt of this proposed amendment to the Order.\n13. Schedule and conduct internal inspection tests using the same or similar technology which\nidentified the 715 anomalies requiring pressure reduction in the Vicksburg to Freedom Junction\npipeline segment. The internal inspection tool surveys must be performed by August 2002.\n14. For all anomalies identified on the segments that could affect high consequence areas as defined\nin Section 195.450, remedial measures must be taken in accordance with the provisions of\nSection 195.452. The remedial actions required must be completed within 365 days of your\nreceipt of the internal inspection tool results.\n15. For all anomalies identified, remedial measures must be taken in accordance with accepted\nwritten industry practices and 49 C.F.R. Part 195.\n16. Submit a report to the Director, Central Region, on all internal inspection surveys and other\nintegrity testing that have been conducted on Respondent’s loop line from Kennedy Avenue to\nNiles, on the 16-inch mainline from Kennedy Avenue to Vicksburg since 1990, including the\n16-inch mainline segment from Freedom Junction to Detroit, within 60 days of receipt of this\nproposed amendment to the Order. The report shall include:\n(A) The final results of all inspections and tests, as performed by Respondent or as submitted\nto Respondent by persons or firms paid under contract to perform internal inspection\ntests. The final results should include a summary of anomalies which indicate the type\nof pipe in which they occurred and indicate whether the pipe was coated or uncoated.\n(B) Established repair criteria for each internal inspection survey conducted.\n(C) All other information relevant to the repairs made in response to information revealed\nby internal inspection surveys.\n\n\n\n9\nWithin 10 days of receipt of this Proposed Amendment, Wolverine may request a hearing, to be held\nas soon as practicable, by notifying the Associate Administrator of Pipeline Safety in writing,\ndelivered personally, by mail or by telecopy at (202) 366-4566. Any hearing will be held in Kansas\nCity, MO or Washington, DC on a date that is mutually convenient to OPS and Wolverine.\nIf, after receiving and analyzing additional data in the course of this investigation, long-term\ncorrective action is needed, Wolverine will be notified of any additional measures required and\namendment of this Order will be considered. To the extent consistent with safety, Wolverine will\nbe afforded notice and an opportunity for a hearing prior to the imposition of any additional\ncorrective measures.\n____________________________ ______________________\nStacey Gerard Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":25278}