CPF 320116002M
CPF 320116002M
320116002M_Closure_07232013_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED July 23, 2013 Mr. Timothy Barnhart Vice President of Operations Calumet Superior, LLC 2780 Waterfront Parkway East Drive Suite 200 Indianapolis, IN 46214 CPF 3-2011-6002M Dear Mr. Barnhart: During May and June of 2010, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Murphy Oil Corporation’s (Murphy) procedures for hazardous liquid pipelines in Superior, Wisconsin. As a result of the inspection, Murphy was issued a Notice of Amendment on July 25, 2011, which proposed amendment of their procedures. Subsequent to the inspection, Calumet Specialty Products Partners, LP (Calumet) acquired Murphy Oil’s refinery and associated assets (including a PHMSA-regulated pipeline that is the subject of this Notice) on September 30, 2011. Murphy submitted its amended procedures on August 25, 2011. Calumet provided additional amendments on July 22, 2013. My staff has reviewed the amended procedures and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and that this case is now closed. Thank you for your cooperation. Sincerely, David Barrett Director, Central Region Pipeline and Hazardous Materials Safety Administration#
320116002M_Operator Reponse to Notice_08252011.pdf, page 1Official PDFSUPERIOR REFINERY MURPHY 2407 STINSON AVENUE OIL USA. INC. SUPERIOR WISCONSIN 54880 August 25, 2011 Mr. David Barrett Director, Central Region Pipeline and Hazardous Materials Safety Administration 901 Locust Street, Suite 462 Kansas City, MO 64106-2641 Re: CPF 3-2011-6002M Dear Mr. Barrett: On July 28, 2011, Murphy Oil USA received a Notice of Amendment from the Pipeline and Hazardous Materials Administration resulting from inspections performed on May 18-21 and June 2-5, 2010. Murphy has elected not to contest the Notice. Details of Murphy's response to each item in the Notice are provided below. Item 1. In response to the Notice, Murphy has updated section F.1 of the Pipeline Operation and Maintenance Manual (O&M) and section 1.2 of the Emergency Response Plan (ERP) to include the ERP, Recommended Practices, and ancillary procedures into the annual review of the 0&M. Item 2. In response to the Notice, Murphy has updated section F.3.1 of the O&M to address the required information. Item 3. In response to the Notice, Murphy has added a section F.6 Communications to the O&M to address the regulatory requirements. Please note that this change affected the paragraph numbering within section F; references in the NOA to specific O&M sections may no longer be accurate. Item 4. In response to the Notice, Murphy has added language to Section F.10 of the O&M to address the regulatory requirements. Item 5. In response to the Notice, Murphy has added language to Section F.11 of the O&M to address the regulatory requirement. MURPHY USAN#
320116002M_Operator Reponse to Notice_08252011.pdf, page 2Mr. David Barrett August 25, 2011 Page 2 Item 6. In response to the Notice, Murphy has added language to Section F.14 of the O&M to address the regulatory requirement. Item 7. In response to the Notice, Murphy has added language to Section 1.3 of the 0&M requiring development of a list of company-approved coatings. With regard to the specific instance mentioned in item 7, Murphy has added language to Section 1.3 of the 0&M requiring individuals who apply coating to be qualified for the task and to adhere to the manufacturer's installation recommendations. Item 8. In response to the Notice, Murphy has added language to Section 1.10 of the O&M to address the regulatory requirements. Item 9. In response to the Notice, Murphy has added language to Section I.11 of the O&M to provide additional detail on electrical isolation methods. Item 10. In response to the Notice, Murphy has added an item under Section I.17.3 of the O&M to establish the required retention schedule. Item 11. In response to the Notice, Murphy has revised its Operator Qualification program to require observation of work as an evaluation method for applicable covered tasks. Sections F.1 and H.6 of the O&M have been updated to reflect this change. The updated O&M is enclosed with this letter. Item 12. In response to the Notice, Murphy has added an initial response action to shut down the pipeline in Section 3 of the ERP and has updated the Receptionist's responsibilities in Section 5 of the ERP. Item 13. In response to the Notice, Murphy has added language to Section F.2 of the O&M to specify that emergency response training is to be conducted as part of annual 8-hour HAZWOPER refresher training. Item 14. In response to the Notice, Murphy has added language to the table in Section G.2 of the O&M such that communications to stakeholders are now required to address leak recognition. Item 15. In response to the Notice, Murphy has expanded Section G.5 of the O&M to address the regulatory requirements and provide additional detail on program execution. The revised Pipeline Operations and Maintenance Manual (both a markup showing the revisions and the final) and revised sections of our Emergency Response Plan on a CD as pdf files are enclosed with this letter. Please be aware that Murphy Oil recently reached an agreement to sell the Superior Refinery and associated pipeline. The transaction is scheduled to close near October 1, 2011. To ensure#
320116002M_Operator Reponse to Notice_08252011.pdf, page 3Mr. David Barrett August 25, 2011 Page 3 that any correspondence receives immediate attention, I would request that you send a copy to me here in Superior in addition to our corporate office in El Dorado, Arkansas. DelPhit David J. Podratz Refinery Manager Cc: Steve Hunkus, El Dorado Enclosures: Revised Pipeline Operation and Maintenance Manual (final) Revised Pipeline Operation and Vaintenance Manual (showing markups) Revised Emergency Response Plan Pages#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.