{"operation":"document","citation":"CPF 320045013","title":"PHILLIPS 66 PIPELINE LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2004-04-26","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.452(b)(1), 195.452(c)(1), 195.452(c)(1)(i)(A), 195.452(e), 195.452(f), 195.452(g), 195.452(g)(4), 195.452(h)(2), 195.452(h)(4)(i), 195.452(i)(1), 195.452(j)(1), 195.452(j)(5), 195.452(k), 195.452(l)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320045013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320045013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320045013","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320045013","body":"Notice of Probable Violation involving PHILLIPS 66 PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(b)(1),  195.452(c)(1),  195.452(c)(1)(i)(A),  195.452(e),  195.452(f),  195.452(g),  195.452(g)(4),  195.452(h)(2),  195.452(h)(4)(i),  195.452(i)(1),  195.452(j)(1),  195.452(j)(5),  195.452(k),  195.452(l)(1). The case was opened on 2004-04-26 and is reported as closed as of 2007-02-15. Proposed civil penalty: $35,000. Assessed civil penalty: $35,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320045013_Final Order_08292005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045013/320045013_Final%20Order_08292005.pdf\n\ncpf_320045013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045013/cpf_320045013.pdf\n\n320045013_Final Order_08292005.pdf\n\n@\nU.S. Deportment\nof Tronsportotion\nPipeline ond\nHozordous tftoferiols Sofety\nAdministrotion\nAUG 29 ru05\nMr. David ysebaert\nGeneral Manager\nConocoPhillips pipelines and Terminals\nP.Q. Box 2t97 (772s2)\n600 North Dairy Ashford\nHouston, TX 77079\nRE: CPF No. 3-2004-5013\nDear Mr. Ysebaert:\nEnclosed is the Final order issued by the Associate Administrator for pipr\nline Safety\nlXlt\":,:b\"_:l,lffi\"T* .ur\": ,It makes findings of viotarion, assesses u .iuii .\"d;\":H:;;J;i\npenalty of\nof certain\n:l'l,TlLg,il1,T\"in,:lu\"ce procedures. The Final Order urro ,p\"\"ines actions ro\ncomply with the pipeline safety regulations and revision oicertain operating and\ntaken to\nprocedures. The penalty pay-\"ttt terms are set forth in the Final order, w\nntenance\npenalty is paid and the terms of the compriance order and amendment of pr\nthe civil\ncompleted, as determined by the Director, central Region, 1ffi*frffi;i;:\nures are\nll:i\"^d- Your receipt of the Final order constitutes service of that document undt\nwill be\ns 190.5.\n49 C.F.R.\nSincerely,\nfik\nAa* /LL=-\nt/ f,\nVm., Rewolds\nPipeline iompliance Registry\nOffice of Pipeline Safety\nEnclosure\nfteven G. Cooper, Counsel for Conocophillips\n!_t..pl\"n G. Ellison, Counsel for Conocophillips\nKeith H. wooten, piperine integriiy Direetor, conocophiiiips\nIvan Huntoon, Director, CentraiRegion, OpS\n\n\n\nBackground\n1n2002, Conoco merged with Phillips Petroleum Company to create a new entit\nConocoPhillips\nPipelines and Terminals. At that time each entity was operating a separate\nty Management\nProgram @vIP). An IMP inspection was conducted at Phillips inFebruary 2002\nConoco's IMP\nwas inspected by OPS in September,2002. Although Respondent informed O\nof its intent to\nintegratethetwo separateIMPs, OPS toldRespondent in2002 thattheycouldmain\nmtwo separate\nbaseline assessments. The Notice is unrelated to the factthat Respondent had\nseparate IMPs\nat the time of the inspection.\nFINDINGS OF VIOLATION\nUncontested\nRespondent did not contest the alleged violation of $ 195.452 in Items 3(B),4(A-\nB), and 7(A- E), 8(A, C), 9(A-C) and 10(A-B) of the Notice. Accordingly, I find\nviolated 49 C.F.R. Part 195. as more fullv described in the Notice:\n49 C.F.R. 5 195.452(exl) - failure to identify or document the primary\nfor each assessed sesment.\n49 C.F.R. $ 195.452(f) - failure to include in its written integrity\nprogram a process for reviewing and updating assumptions used in the risk\n49 C.F.R. $ 195.452(g) and (iX1-4) - failure to analyze all available in\nabout the integrity of the entire pipeline and the consequences of a fi\nRespondent failed to provide for the timely use of the Assessment Hi\nPlaruring Document, used to capture data from the information analysis;\ndevelop a formal process to assure that the input information is cu\nrunning the risk analysis, as the data obtained from prior internal inspec\n(ILI) was not being used as required for input to the risk model or as val\nthe risk results; and failure to develop a formal process for conducti\nMatter Experts (SME) evaluations that provides a logical documented st\n49 C.F.R. $ 195.452(i)(1) - failure to take sufficient measures to p\nmitigate the consequences of a pipeline failure that could affect\nRespondent's Preventive and Mitigative Process needs to be expanded\nHCA specific risk drivers that exist in each HCA and failure to integra\nanalysis with the preventive and mitigative process for HCA segments.\nThese findings of violation will be considered prior offenses in any subsequent\ntaken against Respondent.\n, 5(A-C), 6(4.-\nprior to\non tools\nidentify\nits risk\n\n\n\nContested\nItem 2 of the Notice alleged that Respondent violated 49 C.F.R. $ 195.452 (\nincluding in its written baseline assessment plan(BAP) internal inspection tools\ndetecting deformation anomalies in the pipe that must be repaired as required by\n$ 195.452(h). At the time of the inspection, Respondent was performing pipeli\nevaluate only top side dents identified in High Consequences Areas (HCAs).\nreviewed five out of eight ILI tool runs which revealed that only a gauging plate\nidentify deformations in the piggable segments. OPS determined that these ej\nidentified as prior assessments in the BAP, will require a geometry tool run to\nassessment.\ntXiXa) by not\n(ILI) capable of\nexcavatrons to\nOPS inspectors\nassessments, all\nualify as a prior\nIrr its response to ltem2\" Respondent asserted that OPS failed to provide an\nuate regulatory\nbasis for the Notice and that the IMP rules does not require that the internal i\nLon tool used in\nits baseline assessment must be capable of discerning the anomalies listed in 49 C.F\nR. $ 1e5.4s2(h).\nRespondent argued that the internal inspection performed in its prior assessments\nclearly meet the\nrequirements of the IMP rule. Respondent advised that it has made unp\nrmderstand how OPS interpreted and implemented IMP. Respondent further advi\nand integration of its two IMPs, Conoco and Phillips, is very complex. Respond\nthatthemerger\nt asserted that it\nwas first notified during the inspection that OPS interpreted the IMP regulati\nassessments to require running geometry inspection tools in a more rigorous\non that the rule\nrequires.\nOPS argued that the process used by Respondent was inadequate to find a\nRespondent's plan was to run a MFL tool for top side dents with metal loss. The\nthe type of tool that can find the requisite defects and that the plan should have i\na deformation tool. OPS further argued that Respondent understands the intent\nknowledge of the rule. As a result of an IMP inspection in February 2002, Phl\nenforcement document that directed it to provide more details in the IMP processes\nthe inputs and outputs of these processes. On a second occasion, this matter was di\nwith the IMP team members of both Conoco and Phillips in September 2002,\nofficial were present during most of the Conoco IMP inspection. OPS argued that\nthrough two IMP inspections and the resulting enforcement action, Respondent\nthe IMP rule requirements.\nor anomaly, as\nMFL tool is not\nluded the use of\nand has clear\nips received an\nPhillips IMP\nrhaving gone\nfully aware of\nRespondent argued that had OPS advised Respondent earlier of OPS interpretati\ncould have been avoided. Respondent suggested that the violation has been\ncompleted the baseline assessment for 50% of its pipe segments that could\nemploying the ILI tools identified by OPS.\nthe violation\nas it has\n,\nbct HCAs by\nOFS couiitered that, ,Jiiring ihc hearing, Respondent was informed that once its n\nconducting a correct risk analysis were in place it should complete a new ri\nsegments in the Conoco and Phillips BAPs. OPS also requested the new risk a\napplied first to those line segments that had not yet been assessed and then applied\nttrat naa akeadybeen assessed. OPS concluded that Respondent's post hearing sub\nto show that Respondent addressed OPS directions and require additional modifi\nprocedures for\nranking of all\nlysis process be\nthose segments\nissions still fail\n\n\n\n4\nContrary to Respondent's position, the focus of the Notice are the inadequate p\nprocedures to achieve the optimal results and not the fact that Respondent had\nor was in the process of integrating the two program .h2002, OPS told Respond\nmaintain two separate baseline assessments.\n, processes and\nseparate IMPs\nthat they could\nAt the time of the inspection, Conoco was using a geometry tool to assess de\nalong with an ILI tool to find other anomalies. However, Phillips used a gaugr\nused a geometry tool occasionally. Phillips was only digging top side dents.\nplace but the process was inadequate to find the deformation anomalies, de\ngrooves. The plan should have included the use of a deformationtool. The MFL\nof tool that can identify the requisite defects. There are two pieces of\nimplementation and the plan and process. There was a lack of consideration in\nRespondent may have changed its plan as suggested on page 8 of its brief dated\nand intends to meet the baseline assessment, at the time of the inspection\nperforming pipeline excavations to evaluate only top side dents identified in HC\npost hearing submissions fail to show that this issue has been satisfactorily\nI find that Respondent violated 49 C.F.R. g 195.452 (cXlXiXa) by not includi\nbaseline assessment plan ILI tools capable of detecting deformation anomalies in t\nbe repaired as required by 49 C.F.R. $ 195.452(h).\nns in the pipe\nplate and only\nprocess was in\nI is not the type\ninvolved. the\nugust I1,2004,\nRespondent's\n, Accordingly,\ng in its written\npipe that must\nItem 3A of the Notice alleged that Respondent violated 49 C.F.R. $ 195.4\nestablishing an integrity assessment schedule that prioritizes pipeline segments for\nNotice further alleged Respondent did not base the assessment schedule on all\nreflect the risk conditions on the pipeline segment. The factors an operator must\nbut are not limited to 49 C.F.R. $ 195.452 (e)(1)(! through (eXlXix). At the time\nRespondent was using two different risk models to risk rank the pipelines and\nwas notprovided adequate informationto determinewhetherthehighestriskpipeh\nbeing assessed as required by the IMP rule.\n2 (e)(1) by not\nrisk factors that\nider include.\nf the inspection,\ninspection team\nsegments were\nIn its response to Item 34, Respondent asserted that prior to the merger each oper\ncompleted baseline assessments of 50% of its riskiest pipeline segments that cou\nwithin the required time frame and that each developed a written integrity mana\nsuccessfully\naffect an HCA\nt plan that\naddressed the risks of each segment, with the baseline assessment to be developed\nfrom prioritizingthe risk factors on each segment. Respondent explained that\nefforts have been made to meet the requirements of each of the integrity manag\nnce the merger,\nent plans of the\ntwo legacy companies by performing the planned baseline assessments. Resp\nthat it has been working to create a third integrated integrity management plan\nadopts the best\npractices of each of the two legacy plans that one day will fully replace the two pl\nRespondent\nposed that OPS is aware of these efforts and support them. Respondent further ar1\nthat the IMP\nrule recognizes lhat the livfP is a continually- changing program that will sr'zslr'r\nfrorn the initial\nprogram and that a provision of the rule requires Respondent to document char\nto its baseline\nptutt. fnt -le specifically contemplates at least one such change-when a new HC\nis identified and\nihat newly identified HCA must be added to the baseline plan within one year\nd assessed in 5\nyears.\n\n\n\nOPS clarified that there can be a Conoco baseline assessment plan (BAP) and teHeritageBAP\nor the Respondent can have a single BAP. It is the Respondent's choice. The is not whether\nthere are separate BAPs or a single BAP. OPS argued that its findings stemmed\nRespondent's\nfailure to provide sufficient information during the inspection to support the ion that the two\nlists were risk ranked as required by 49 C.F.R. 5 I95.452. There is a lack of il to explain the\nprocess or to show how Respondent created the list of the highest risk pipeli segments. Both\nIMPs lacked the attributes to demonstrate risk ranking, as OPS could not\nine from the\ninformation provided how Respondent arrived at its results.\nContraryto Respondent:s position, the focus of Item 3 is an inadequate desc of the processes used to achieve the identified results, not whether it had BAP. Respondent submitted additional information during the pre-hearing and Much of the information submitted addressed Respondent's future plans to comp While there is no requirement that Respondent have a single BAP, adequate details to explain the process used to determine the prioritization of\nassessed. Nevertheless, Respondent provided no information to support the pri\nused to develop the two lists that risk ranked the pipelines. The process for priority of assessment action must be carefully explained. Respondent has fai\ndocument the risk analysis process. Accordingly, I find that Respondent vi\n519s,4s2 (eX1).\nor explanation\nBAPs or a single\n-hearing stages.\ne a single BAP.\nmust provide\nme segments\nftrzatron process\nining the relative\nto adequately\nIated 49 C.F.R.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. ' 60122, Respondent is subject to a civil penalty not to exc\n' violation for each day of the violation up to a maximum of $1,000,000 for an\nviolations. The Notice proposed a $35,000 civil penalty for violations of 49 C.F $100,000 per\nrelated series of\nPart 195.\n49 U.S.C. 5 60122 and 49 C.F.R. S 190.225 require that, in determining the penalty, I consider the following criteria: nature, circumstances, and gravity of the\nof Respondent's culpability, history of Respondent's prior offenses, Respondent's\npenalty, good faithbyRespondent in attempting to achieve compliance, the ability to continue in business, and such other matters as justice may require.\nof the civil\niolation, degree\nility to pay the\nn Respondent's\nItem 2 of the Notice proposed a civil penalty of $20,000 for violati of 49 C.F.R.\n$195.452(cX1)(a), as Respondent failed to include in its written baseline capable of detecting deformation anomalies in the pipe that must be repaired as\n49 C.F.R. $ 195.452(h). In response to Item 2,ilte Respondent argued that t\npenalty should not be levied for any real or perceived missteps it may have m\nprocess because the IMP rule was meant to be a broad and flexible, performance\nlew <ietaiied requirements. Respc,iideni explained that Conoco and Phillips\ncompanies and that both met the first two IMP deadlines, to identify all pipeline se\naffect HCAs and develop a written IMP. Respondent further explained that OPS t\nthe inspection the challenges ConocoPhillips faced in its efforts to create an inte\nplan a ILI\nuired by\nproposed civil\nin the learning\nsystem with\nfrrrn rii cfinnl\nthat could\nognized during\nIMP shortlyafter a merger.\n\n\n\nThe focus of the Notice and this Order are the inadequate plan, processes and p ures to achieve\nthe optimal results. The Notice is unrelated to the fact that Respondent had two e IMPs at\nthe time of the inspection. The primary objective of the Federal pipeline safety is public\nsafety. Failure to find the deformation anomalies, defects, gouges and grooves in subject areas\ncould result in a release and adversely affect public safety and the environment. R pondent has not\nshown any circumstance that would have prevented or justified it not includi\nin its written\nbaseline assessment plan an ILI capable of detecting deformation anomalies in t\npipe that must\nbe repaired as required by 49 C.F.R. $ 195.452(h). Accordingly, having review\nthe record and\nconsidered the assessment criteria, I assess Respondent a civil penalty of $20,\nfor violation of\n49 C.F.R. 5 r9s.4s2.\nItem 3A of the Notice proposed a civil penalty of $10,000 for violation of 49 F.R.$ r9s.4s2\n(eX1), as Respondent failed to provide sufficient details of the process used for pri\nto prioritize the highest risk pipeline segments, and failed to adequately documen\nty assessment,\nthe risk analysis\nprocess.\nRespondent argued that OPS proposed a civil penaltybecause Respondent was ble to state with\nabsolute certainty that the baseline assessments performed on the two legacy IMP\nwill capture\n50Yo of all the highest risk pipeline segments.\nWhile there is no requirement for a statement of absolute certainty, Respondent\nust establish an\nintegrity assessment schedule that shows it prioritized the highest risk pipeli\nsegments and\ndescribe in sufficient details the process and procedures used to achieve its resul\n. Respondent is\nrequired to base the assessment schedule on all relevant categories ofrisk factors t\nreflect the risk\nconditions on its pipeline, in accordance with 49 C.F.R. 5 195.452 (e)(1)(i) throu h (e)(l)(ix). An\noperator's failure to sufficiently document its risk analysis process and analyze potential effects\nofpipeline failures on high consequence areas at specific locations along the pi ine will leave it\nill-prepared to address the severity and extent of the consequences that ensue fol\nrwing a failure.\nA release or failure under such circumstances increases the risk of harm to public and the\nenvironment. Respondent has not shown any circumstance that would have prev\nnted or justified\nit not including sufficient details about the processes and procedures used to ri\nrank its HCA\nsegments and the segments listed in Respondent's BAP. Accordingly, having rev ed the record\nand considered the assessment criteria, I assess Respondent a civil penalty of $10,\nfor violation\n,\nof 49 C.F.R. g I9s. sZ(eXl).\nItem 4C of the Notice proposed a civil penalty of $5,000 for violation of 49 C.F. $ 1e5.452(0,\nas Respondent's factors for risk ranking facilities do not include the\nfundamental reason for applying risk analysis techniques to integrity manage\nobtain an integrated understanding of threats to segment integrity and potential losses of integrity. Therefore, it is essential that an operator's risk assessment\nidentifies the iirajor tl^r-r-eats to HCAs for a given pipeline segment or facility, id\nthreats rank in relation to each other, and how the segments and facilities com\nbased on the risk to HCAs. Respondent did not contest the allegation.\nreviewed the record and considered the assessment crtterTa,I assess Respondent\nof HCAs. A\nprograms is to\nes from\nh clearly\ntifv ho'*r those\nto each other\ningly, having\ncivil penalty of$5,000, for violation of 49 C.F.R. $ 195.452(t.\n\n\n\nAccordingly, having reviewed the record and considered the assessment criteria, I a total civil penalty of $35,000. A determination has been made that Respo\npay this penalty without adversely affecting its ability to continue business.\nRespondent\nhas the abilitv to\nPayment of the civil penalty must be made within 20 days of service. Federal\n(49 C.F.R. $ 89.21(b)(3)) require this payment be made by wire transfer, t Reserve Communications System (Fedwire), to the account of the U.S. Tr\ninstructions are contained in the enclosure. After completing the wire trans\nthe electronic funds transfer receipt to the Office of the Chief Counsel (\nHazardous Materials Administration, Room 8417, U.S. Department ofTransporta\nStreet, SW, Washington, DC 20590-0001.\ngh the Federal\n. Detailed\n,\nsend a copy of\n1), Pipeline and\non,400 Seventh\nQuestions conceming wire transfers should be directed to:\n120), Federal Aviation Administration, Mike Monroney\nOklahoma City, OK 73125; (405) 954-8893.\nFinancial Operations vision (ANIZ-\nAeronautical Center. .O. Box 25082.\nFailure to pay the $35,000 civil penalty will result in accrual of interest at the c\naccordancewith3l U.S.C. $3717,31 C.F.R. $ 901.9 and49 C.F.R. $ 89.23. P\nauthorities, alate penalty charge of six percent (6%)per anntlm will be charged payment ls not\nmade within 110 days of service. Furthermore, failure to paythe civil penalty\nof the matter to the Attorney General for appropriate action in an United States\nannual rate in\nto those same\nresult in referral\nstrict Court.\nCOMPLIAIICE ORDER\nThe Notice proposed a Compliance Order with regards to Item 3(A-B), 4(A), 5( ), and 7(A,C),\nviolation of 49 C.F.R .' 19 5 .452(eX 1 ), 19 5.452(D, 19 5 .a52G)0 X 1 -4), and 19 5 .4 ix1)\nUnder 49 U.S.C. $ 601 18(a), each person who engages in the transportation of liquids or\nwho owns or operates a pipeline facility is required to comply with the applicable\nsafety standards\nestablished under chapter 601. Pursuant to the authority of 49 U.S.C. $ 601 18(b)\nand 49 C.F.R\nS I90.2I7, Respondent is hereby ordered to take the following actions to ensure\nliance with\nthe pipeline safety regulations applicable to Respondent's operations:\n1. Within 30 daysprovide aproposed schedule for establishing and implemen\namendments:\nthefollowing\nI. With regard to Item 3(a), develop a risk ranked Baseline\njointly or separately, with sufficient information to show that\npipeline segments are being assessed in a prioritized manner and\nprocesses and procedures on how conducting the risk ranking of\naffect segments and the risk ranking of the segrnents listed in the B\nwith 49 C.F.R. $ 19s.as2 (e)(1).\nPlan, either\nhighest risk\nlude detailed\nhe HCAs could\nin aeeordarrce\n,\nIL With regard to Item 3(b), establish the primary risk threats for each\nin accordance with 49 C.F.R. 5195.452 (eXl).\nsegment\n\n\n\n8\nng assumptions\n.F.R.$ r95.452\nm.\nWith regard to Item 4(a), establish a process for reviewing and upd\nthat were used in the risk analysis process, in accordancewith 49\n(f)\nry.\nWith regard to Item 5(a), revise your Assessment Plan Hi\nDocument to provide sufficient details of the results of your Infi\nin accordance with 49 C.F.R. $ 195.a52 (g).\nV.\nWith regard to Item 5(b), develop a process to review and\ninformation is the most up to date information available\nanalysis, in accordance with 49 C.F.R. $ 195.a52 (g).\nVL With regard to Item 5(c), develop a formal process for conducting\nthat provides a logical documented structure, if SME evaluations\napart of the IMP, in accordance with49 C.F.R. $ 195.a52 G).\nvII. With regard to Item 7(a), develop a process to identify risk specific\nfor each HCA and review the existing preventive and mitiga\ndetermine whether additional measures are required, in\n5 res.4s2(i)(1) and (D(4).\nVm. With regard to\nItemT(c), develop a process that integrates the\nanalysis of each\nHCA that could affect segment with the preventi\nprocess for that\nsame segrnent in accordance with 49 C.F.R. $1\n(rx4).\nx. With regard to Item 1 (I-V[I), submit written procedu\nimplementation of the procedures satisfying the requirements of P\ndays of receipt of this Order, to Mr. Ivan Huntoon, Director, O\nSafety, Central Region, 901 Locust, Room 452.,Kansas City, MO\nThe Regional Director may extend the period for complying with\nthe req\nRespondent requests an extension and adequately justifies the reasons\nfor the ex\nAMENDMENT OF PROCEDURES\nand Planning\ntion Analysis,\nevaluations\nve measures to\nwith 49 C.F.R.\nIts of the risk\nand mitigative\n.a52$)(r) and\nand proof of\nl95,within 180\ne of Pipeline\n106-264r.\nitems if the\nItems 2, 4(B-C), 6(,4.-8), 7(8, D, E), 8(A, C), 9(A-C) and 10(A-B) of\nNotice alleeed\ninadequacies in Respondent's integfity management program and proposed to\nire amendment\nof Respondent's procedures to comply with the requirements of 49 C.F.R. $$\ns.as2(c)(1)(a),\nr9s.4s2(t), r9s.4s2 (h)(2-4),19s.4s2(l)(r), r95.4s26)(1X2), r9s-452(k), r9s.4s\nD(1XiXiD.\nRespondent did not contest the proposed Notice of Amendment but reques\nschedule to implement the provisions. Accordingly, I find that Respondent's inte\nprocedures are inadequate to ensure safe operation of its pipeline system' Pursu\ng 6010S(a) and 49 C.F.R. 5 190.237, Respondent is ordered to make the followi\nintegrity management program and procedures. Respondent must:\nan altemative\ntymanagement\ntto 49 U.S.C.\nrevisions to its\n\n\n\n1. 2.\na\nJ .\n4.\n5. 6. ,7\n8.\n9. 10.\nl 1 I t .\n9\nAmend your procedures to include a process that requires the use\ndetecting deformation anomalies when intemal tool surveys\nassessment method. in accordance with those listed in 49 C.F.R.\ntools capable of\nchosen as the\nres.452(h).\nAmend your procedures to include a process that documents the\nverall results of\nintegrated data analysis and conclusions regarding the integrity of\nhe segment. The\nprocess must provide details on how to perform a detailed review\nf the assessment\nresults, generate a repair schedule, and perform anintegrated eva\nuation of overall\npipeline integrity.\nAmend your procedures to include a process for risk ranking facil\nfactors for the presence of HCAs.\nes that includes\nAmend your procedures to provide sufficient details that c\nprocedure for discovery and repair of anomalies.\ny describe your\nAmend yourprocedures to revise your existing process for\nin Appendix K of part 3 of your IMP. The revised process must\nthe requirements of paragraph 451.7 of ANSI837.4 regarding t\nof a required pressure reduction.\nreduction found\nconsistent with\nimplementation\nAmend your procedures to include a process for evaluating preventi measures, including the impact on risk of implementing a preven\nproject.\nandmitigative\nve or mitieative\nAmend your procedures to revise your existing process for detection capability for HCAs that are in close proximity to the the evaluation of the potential risk reduction on these HCA could luating the leak\nine, including\nt segments.\nAmend your procedures to expand\nguidance for the utilization of the\nmitigative measures.\nyour process for EFRD eval\nflow chart for evaluation\nation to include\npreventive and\nAmend your procedures to expand your procedure for sel assessment method and selection of the appropriate ILI tool(s), the appropriate\nlicable.\nAmend your procedures to expand your procedures for conducti\nassessment of a HCA that could affect the segment, as the revised\nprocedures submitted on August ll,2004, requires additional\na hydrostatic\nhydrostatic test\nification.\nA - - - J r u I l w l l u \\ r n r r r h r n ^ a A t t . o o\nJ v u r l / r v v v u s r v o\nyour IMP, as the August\ntc expand your progess for e'raluating th effectiveness of\n11, 2004, submission requires additional ification.\n\n\n\n12.\nAmend your procedures to expand your process for commun\ncompany the performance evaluation results on the effectiveness\nany follow-up that may be required as the August II,2004, su\nadditional modifi cation.\n13. Amend your procedures to expand your Management of Change\na revision control process to specifically address revision control\nt4.\nAmend your procedures to revise your corporate document\ninclude the documents required by your IMP.\n15. Submit the amended procedures within 30 days following recer\nDirector, Office of Pipeline Safety Central Region, 901 Locust,\nCity, MO 64106-2641.\nThe Regional Director may extend the period for complying with the requ\nRespondent requests an extension and adequately justifies the reasons for the ex\nWARNING ITEM\nThe Notice did not propose a civil penalty or corrective action for Item 1, 4(D) and\nRespondent that it should take appropriate corrective action to correct the i\npresented information in its response showing that it has addressed the cited ite\nagain warned that if OPS finds a violation in a subsequent inspection, en\ntaken.\nFailure to comply with this Final Order may result in the assessment\nof civil\n$100,000 per violationper day, or in the referral of the case for judicial\nenforcem\nUnder 49 C.F.R. $ 190.215, Respondent has a right to submit a Petition for R\nFinal Order. The petition must be received within 20 days of Respondent's\nOrder and must contain a brief statement of the issue(s). The filing of the peti\nstays the payment of any civil penalty assessed. A11 other terms of the order, incl\ncorrective action and amendment of procedures, remain in full effect\nAdministrator, upon request, gfants a stay. The terms and conditions of this\neffective upon receipt.\nIMP, including\nission requires\nion schedule to\nof this Order to\n452, Kansas\nitems if the\n(E) but warned\nRespondent\nRespondent is\naction will be\nIties of up to\non of this\nipt of this Final\nautomatically\nng anyrequired\nthe Associate\ninal Order are\nC.\n\\ cj\"i\nI-$ ,/ \\\n( \\\nfor Pipeline Safety","truncated":false,"body_characters":27953}