{"operation":"document","citation":"CPF 320165007M","title":"COFFEYVILLE RESOURCES CRUDE TRANSPORTATION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-09-19","effective_on":null,"summary":"CLOSED notice of amendment citing 195.208, 195.222(a), 195.226(a), 195.302(a), 195.402(a), 195.402(c)(10), 195.402(c)(12), 195.402(c)(13), 195.402(c)(2), 195.402(c)(3), 195.402(c)(4), 195.402(c)(5), 195.402(d)(1), 195.402(d)(2), 195.402(d)(5), 195.402(e)(1), 195.402(e)(2), 195.402(e)(3), 195.402(e)(9), 195.405(a), 195.406(a)(1), 195.408(b)(3), 195.410(a)(1), 195.420(a), 195.422(a), 195.426, 195.428(a), 195.428(d), 195.430, 195.432(b), 195.436, 195.438, 195.442(a), 195.52(b)(6), 195.52(c), 195.561(a), 195.573(a)(2), 195.573(c), 195.573(d), 195.573(e), 195.579(a), 195.587, 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320165007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320165007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320165007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320165007M","body":"Notice of Amendment involving COFFEYVILLE RESOURCES CRUDE TRANSPORTATION, LLC. PHMSA's enforcement data identifies the cited regulations as 195.208,  195.222(a),  195.226(a),  195.302(a),  195.402(a),  195.402(c)(10),  195.402(c)(12),  195.402(c)(13),  195.402(c)(2),  195.402(c)(3),  195.402(c)(4),  195.402(c)(5),  195.402(d)(1),  195.402(d)(2),  195.402(d)(5),  195.402(e)(1),  195.402(e)(2),  195.402(e)(3),  195.402(e)(9),  195.405(a),  195.406(a)(1),  195.408(b)(3),  195.410(a)(1),  195.420(a),  195.422(a),  195.426,  195.428(a),  195.428(d),  195.430,  195.432(b),  195.436,  195.438,  195.442(a),  195.52(b)(6),  195.52(c),  195.561(a),  195.573(a)(2),  195.573(c),  195.573(d),  195.573(e),  195.579(a),  195.587,  195.589(c). The case was opened on 2016-09-19 and is reported as closed as of 2017-02-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320165007M_Closure Letter_02032017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320165007M/320165007M_Closure%20Letter_02032017.pdf\n\n320165007M_Closure Letter_02032017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320165007M/320165007M_Closure%20Letter_02032017_text.pdf\n\n320165007M_Notice of Amendment_09192016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320165007M/320165007M_Notice%20of%20Amendment_09192016.pdf\n\n320165007M_Notice of Amendment_09192016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320165007M/320165007M_Notice%20of%20Amendment_09192016_text.pdf\n\n320165007M_Operator Response to Notice_12232016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320165007M/320165007M_Operator%20Response%20to%20Notice_12232016.pdf\n\n320165007M_Notice of Amendment_09192016_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 19, 2016\nMr. Robert Haugen\nExecutive Vice President of Refining Operations\nCoffeyville Resources Crude Transportation, LLC\n2277 Plaza Drive\nSuite 500; Building B\nSugarland, TX 77479\nCPF 3-2016-5007M\nDear Mr. Haugen:\nOn May 9-13, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\noperation and maintenance procedures for Coffeyville Resources Crude Transportation, LLC\n(CRCT) in Bartlesville, Oklahoma.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCRCT’s plans or 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 and\nprovide a reasonable initial estimate of the amount of released product.\nCRCT’s Operation and Maintenance manual (O&M) did not have a procedure to calculate\nand provide a reasonable initial estimate of product released in accordance to 195.52(c).\nCRCT personnel indicated that they could draft a procedure for initial volume based on the\nsize of the spill, the soil contaminated, and the depth of the line.\n\n\n\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nCRCT’s procedure for reviewing the O&M and Emergency plans annually is deficient\nbecause there is no mention of the annual review of the emergency plan in Section 19.\nCRCT personnel indicated that they were going to use the facility response plan (FRP) for\nthe emergency response procedures. If that is the case, the emergency response section in\nthe O&M must reference the FRP and the FRP must be revised to reflect the requirement\nof Part 195 – Emergency Response.\n3. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis Section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(2) Gathering of data needed for reporting accidents under Subpart B of this part in\na timely and effective manner.\n§195.52 Immediate notice of certain accidents.\n(b) Information required. Each notice required by paragraph (a) of this Section\nmust be made to the National Response Center either by telephone to 800-424-8802\n(in Washington, DC, 202-267-2675) or electronically at http://www.nrc.uscg.mil and\nmust include the following information:\n(6) Initial estimate of amount of product released in accordance with paragraph (c)\nof this Section.\nIn Sections 19.12 and 19.13, CRCT’s procedures for gathering data needed for reporting\nincidents did not include the gathering of the initial estimate of amount of product\nreleased.\n2\n\n\n\n4. §195.402 Procedural Manual for Operations, Maintenance and Emergencies.\n§195.402 (c) Maintenance and normal operations. The manual required by\nparagraph (a) of this Section must include procedures for the following to provide\nsafety during maintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.405 Protection against ignitions and safe access/egress involving floating roofs.\n(a) After October 2, 2000, protection provided against ignitions arising out of static\nelectricity, lightning, and stray currents during operation and maintenance activities\ninvolving aboveground breakout tanks must be in accordance with API RP 2003\n(incorporated by reference, see §195.3), unless the operator notes in the procedural\nmanual (§195.402(c)) why compliance with all or certain provisions of API RP 2003 is\nnot necessary for the safety of a particular breakout tank.\nCRCT’s O&M does not have a procedure for protecting against ignitions arising out of\nstatic electricity, lightning, and stray currents during operation and maintenance activities\ninvolving aboveground breakout tanks.\n5. §195.402(c)(3) – See Above\n§195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(1) The internal design pressure of the pipe determined in accordance with §195.106.\nHowever, for steel pipe in pipelines being converted under §195.5, if one or more\nfactors of the design formula (§195.106) are unknown, one of the following pressures\nis to be used as design pressure:\n(i) Eighty percent of the first test pressure that produces yield under Section N5.0 of\nAppendix N of ASME/ANSI B31.8 (incorporated by reference, see §195.3), reduced\nby the appropriate factors in §§195.106(a) and (e); or\n(ii) If the pipe is 323.8 mm (12¾ in) or less outside diameter and is not tested to yield\nunder this paragraph, 1379 kPa (200 psig).\nCRCT’s O&M for establishing maximum operating pressures (MOP) was deficient\nbecause Section 9.1was a restatement of the regulations. CRCT did not include a\nprocedure on how the MOP is going to be determined (ie: calculations, what materials to\nbe used, etc). Additionally, the procedure did not define what records will be kept and for\nhow long. It was also noted that a procedure (Section 9.3) allowed for uprating of a liquid\n3\n\n\n\nline. This is not allowed by the hazardous liquid regulations and should be removed from\nthe O&M.\n6. §195.402(c)(3) – See Above\n§195.408 Communications.\n(b) The communication system required by paragraph (a) of this Section must, as a\nminimum, include means for:\n(3) Conducting two-way vocal communication between a control center and the\nscene of abnormal operations and emergencies;\nCRCT’s procedure for communication systems was deficient because it did not include\nwhat CRCT utilizes for communications between field personnel at separate locations.\nThe communication devices utilized by CRCT were not listed in the procedure.\n7. §195.402(c)(3) – See Above\n§195.410 Line markers.\n(a) Except as provided in paragraph (b) of this Section, each operator shall place and\nmaintain line markers over each buried pipeline in accordance with the following:\n(1) Markers must be located at each public road crossing, at each railroad crossing,\nand in sufficient number along the remainder of each buried line so that its location\nis accurately known.\nCRCT’s O&M procedure for marking the line is deficient because the procedure did not\nreference addendum 6.0-ADM-004 which contain a more detailed procedure for\npermanent line markers.\n8. §195.402(c)(3) – See Above\n§195.420 Valve maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe operation\nof its pipeline systems in good working order at all times.\nCRCT’s procedure was deficient because it did not require that all valves needed for the\nsafe operation of the system will be maintained in good working order at all times. This\nregulation does not just pertain to the mainline valves, but all valves that are needed for the\nsafe operation within the pump station and breakout tank facilities.\n4\n\n\n\n9. §195.402(c)(3) – See Above\n§195.422 Pipeline Repairs. - (a) Each operator shall, in repairing its pipeline systems,\ninsure that the repairs are made in a safe manner and are made so as to prevent\ndamage to persons or property.\n§195.222 Welder Qualifications\na) Each welder or welding operator must be qualified in accordance with Section 6\nor 12 of API Std 1104 (incorporated by reference, see §195.3) or with Section IX of\nASME Boiler and Pressure Vessel Code (BPVC) (incorporated by reference, see\n§195.3), except that a welder qualified under an earlier edition than listed in §195.3\nmay weld but may not re-qualify under that earlier edition.\nCRCT’s O&M Section 16 did not reference the correct edition of API 1104. Additionally,\nthe incorrect section for welder qualification was also referenced in the manual. Currently,\nthe 20th Edition and Section 6 are the correct edition and section of API 1104 incorporated\nby reference.\n10. §195.402(c)(3) – See Above\n§195.422 Pipeline Repairs. - (a) Each operator shall, in repairing its pipeline systems,\ninsure that the repairs are made in a safe manner and are made so as to prevent\ndamage to persons or property.\n§195.226 Welding: Arc burns.\n(a) Each arc burn must be repaired.\nCRCT’s arc burn repair procedure in the O&M was deficient because it did not reference\nthe arc burn removal addendum. All guidance documents and other detailed procedures\nnot included in the O&M must be referenced from the O&M.\n11. §195.402(c)(3) – See Above\n§195.422 Pipeline Repairs. - (a) Each operator shall, in repairing its pipeline systems,\ninsure that the repairs are made in a safe manner and are made so as to prevent\ndamage to persons or property.\n5\n\n\n\n§195.208 Welding of supports and braces.\nSupports or braces may not be welded directly to pipe that will be operated at a\npressure of more than 100 p.s.i. (689 kPa) gage.\nCRCT’s O&M did not have a procedure to prohibit the welding of supports to pipe that\noperate over 100 psig. CRCT’s procedure did not indicate when personnel can weld\nsupports to the pipe and what they have to do to provide another means of support for lines\nthat operate above 100 psig.\n12. §195.402(c)(3) – See Above\n§195.422 Pipeline Repairs. - (a) Each operator shall, in repairing its pipeline systems,\ninsure that the repairs are made in a safe manner and are made so as to prevent\ndamage to persons or property.\n§195.302 General requirements.\n(a) Except as otherwise provided in this Section and in §195.305(b) , no operator may\noperate a pipeline unless it has been pressure tested under this subpart without\nleakage. In addition, no operator may return to service a segment of pipeline that\nhas been replaced, relocated, or otherwise changed until it has been pressure tested\nunder this subpart without leakage.\nCRCT’s O&M procedure for hydrotesting (Section 17) did not contain any information on\ndetermining the correct pressures on a pipeline hydro-test based on elevations and location\nof the test gauges. CRCT provided this information in an Excel spreadsheet which was\nshown to PHMSA during the review. This spreadsheet was not included or referenced\nfrom the procedure.\n13. §195.402(c)(3) – See Above\n§195.426 Scraper and sphere facilities.\nNo operator may use a launcher or receiver that is not equipped with a relief device\ncapable of safely relieving pressure in the barrel before insertion or removal of\nscrapers or spheres. The operator must use a suitable device to indicate that\npressure has been relieved in the barrel or must provide a means to prevent insertion\nor removal of scrapers or spheres if pressure has not been relieved in the barrel.\nCRCT’s O&M Section 8.1 is deficient because it did not reference addendum 7.01-ADM-\n009 Pig Launcher and Receiving. Section 8.1 is a restatement of the regulations while the\naddendum has the actual procedures for launching and receiving a pig.\n6\n\n\n\n14. §195.402(c)(3) – See Above\n§195.428 Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this Section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the case\nof pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months,\nbut at least twice each calendar year, inspect and test each pressure limiting device,\nrelief valve, pressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nCRCT’s O&M procedure for checking pressure limiting devices in Section 9.4 does not\naddress the inspection of the flow controllers. Also, the referenced addendum 7.01-ADM-\n006 does not address the flow controllers either. Additionally, CRCT’s process for\nchecking the high pressure switches at the pump stations in the field did not match what is\nin the procedure (Section 9 and referenced addendum 701-ADM-006).\n15. 195.402(c)(3) – See Above\n§195.428 Overpressure safety devices and overfill protection systems\n(d) After October 2, 2000, the requirements of paragraphs (a) and (b) of this Section\nfor inspection and testing of pressure control equipment apply to the inspection and\ntesting of overfill protection systems.\nCRCT’s O&M does not have a section that addresses the inspection of the overfill\nprotection systems for the breakout tanks. The CRCT document 7.01-ADM-006 does\ncover inspection of over-fill devices, but was not referenced as an addendum from the\nO&M.\n16. §195.402(c)(3) – See Above\n§195.430 Firefighting equipment.\nEach operator shall maintain adequate firefighting equipment at each pump station\nand breakout tank area. The equipment must be-\n(a) In proper operating condition at all times;\n(b) Plainly marked so that its identity as firefighting equipment is clear; and,\n(c) Located so that it is easily accessible during a fire.\n7\n\n\n\nCRCT’s procedure for firefighting equipment was deficient because it did not reference\nthe addendum 2.01-ADM-026. Additionally, the procedure did not provide any details on\nthe type, size, number and location of the firefighting equipment.\n17. §195.402(c)(3) – See Above\n§195.432 Inspection of in-service breakout tanks.\n(b) Each operator must inspect the physical integrity of in-service atmospheric and\nlow-pressure steel above-ground breakout tanks according to API Std 653 (except\nSection 6.4.3, Alternative Internal Inspection Interval) (incorporated by reference,\nsee §195.3). However, if structural conditions prevent access to the tank bottom, its\nintegrity may be assessed according to a plan included in the operations and\nmaintenance manual under §195.402(c)(3). The risk- based internal inspection\nprocedures in API Std 653, Section 6.4.3 cannot be used to determine the internal\ninspection interval.\nCRCT’s procedure for the required API 653 inspections of their tanks was deficient\nbecause it did not address the external 5 year ultrasonic inspection. Additionally, neither\nO&M Section 6 nor the referenced addendum 5.02-ADM-005 - Out of Service Tank\nInspection defined the out of service inspection intervals which is 10 years. Also, the\nprocedure did not define how they will justify an internal inspection interval that exceeds\n10 years per API 653 and how that will be documented.\n18. §195.402(c)(3) – See Above\n§195.436 Security of facilities.\nEach operator shall provide protection for each pumping station and breakout tank\narea and other exposed facility (such as scraper traps) from vandalism and\nunauthorized entry.\nCRCT’s O&M does not have a procedure for providing protection for each pump station\nand breakout tank areas. Section 18.5 is a restatement of the regulations. The procedure\ndid not provide guidance to personnel in determining what kind of security is required for\nthese facilities.\n8\n\n\n\n19. §195.402(c)(3) – See Above\n§195.438 Smoking or open flames.\nEach operator shall prohibit smoking and open flames in each pump station area and\neach breakout tank area where there is a possibility of the leakage of a flammable\nhazardous liquid or of the presence of flammable vapors.\nCRCT’s procedure was deficient because it did not reference the addendum 2.01-ADM-\n033. This addendum provides more guidance on CRCT’s smoking and open flames\npolicy.\n20. §195.402(c)(3) – See Above\n§195.442 Damage Prevention Program\n(a) Except as provided in paragraph (d) of this Section, each operator of a buried\npipeline must carry out, in accordance with this Section, a written program to\nprevent damage to that pipeline from excavation activities. For the purpose of this\nSection, the term \"excavation activities\" includes excavation, blasting, boring,\ntunneling, backfilling, the removal of aboveground structures by either explosive or\nmechanical means, and other earthmoving operations.\nCRCT’s O&M procedure for damage prevention in Section 18 was deficient because the\nprocedure did not reference the following addendums which provided specific procedures\nfor multiple tasks. They are as follows: 6.06-ADM-009 - One Call, 6.06-ADM-005 -\nEncroachment Guidelines, 606-ADM-003 - Line Locating, 606-ADM-006 - Blasting and\nAnalysis.\nAdditionally, it was noted that 606-ADM-003 - Line Locating states CRCT personnel will\nbe on-site if excavation is within 75 feet, but O&M Section 18 page 18-2 states 10 feet.\nCRCT did not ensure that there were no conflicts between the referenced addendums and\nthe O&M procedure. Also, the requirement of an immediate locate or 48 hour locate is not\nin the Line Locating and One Call addendums.\n21. §195.402(c)(3) – See Above\n§195.561 When must I inspect pipe coating used for external corrosion control?\n(a) You must inspect all external pipe coating required by Sec. 195.557 just prior to\nlowering the pipe into the ditch or submerging the pipe.\nCRCT’s O&M procedure in Section 10.2 is inadequate because CRCT did not have\nenough details about how they are going to inspect the pipe prior to lowering in. For\n9\n\n\n\nexample, there was no holiday detector (jeeping) information in the procedure, which is\nhow CRCT inspects the pipe. Some jeeping information is located in a coating specific\ndocument, but was incomplete (no voltage settings or jeep speed) and was not referenced\nfrom the O&M.\n22. §195.402(c)(3) – See Above\n§195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE SP 0169 (incorporated by reference, see § 195.3).\nCRCT’s O&M procedures did not identify the circumstances in which a close interval\nsurvey (CIS) is needed. However, during the O&M review, CRCT personnel explained to\nPHMSA what circumstances they utilize in which they would require a CIS. Those\ncircumstances must be included in the manual.\n23. §195.402(c)(3) – See Above\n§195.573 What must I do to monitor external corrosion control?\nc) Rectifiers and other devices. You must electrically check for proper performance\neach device in the first column at the frequency stated in the second column.\nDevice Check frequency\nRectifier.................................................. At least six times each calendar year, but with\nintervals not exceeding 2 ½ months\nReverse current switch, Diode………...At least six times each calendar year, but with\nInterference bond whose failure intervals not exceeding 2 ½ months\nwould jeopardize structural\nprotection\nOther interference bond ....................... At least once each calendar year, but with\nintervals not exceeding 15 months.\nCRCT’s O&M procedure for checking rectifiers in Section 10.5 of the corrosion section is\ninadequate because CRCT acquired the #1-8 and #3-8 lines from another company and\nthey did not have a procedure to check the rectifiers that protect those new lines. Those\n10\n\n\n\nlines are protected by rectifiers owned by another company and will require a different\nprocedure for CRCT to ensure that they are working correctly.\n24. §195.402(c)(3) – See Above\n§195.573 What must I do to monitor external corrosion control?\n(d) Breakout tanks. You must inspect each cathodic protection system used to\ncontrol corrosion on the bottom of an aboveground breakout tank to ensure that\noperation and maintenance of the system are in accordance with API RP 651\n(incorporated by reference, see § 195.3). However, this inspection is not required if\nyou note in the corrosion control procedures established under §195.402(c)(3) why\ncomplying with all or certain operation and maintenance provisions of API RP 651 is\nnot necessary for the safety of the tank.\nCRCT’s O&M did not have procedures for taking cathodic protection readings on the tank\nbottoms. CRCT did not provide guidance on where and when the readings on the tanks\nmust be taken.\n25. §195.402(c)(3) – See Above\n§195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion control\nas required by Sec. 195.401(b). However, if the deficiency involves a pipeline in an\nintegrity management program under Sec. 195.452, you must correct the deficiency\nas required by Sec. 195.452(h).\nCRCT’s O&M procedure for remedial action on deficient cathodic protection readings was\ninadequate because it did not define what prompt remedial action means. PHMSA’s\nexpectation is that remedial action occurs before the next monitoring period.\n26. §195.402(c)(3) – See Above\n§195.579 What must I do to mitigate internal corrosion?\na) General. If you transport any hazardous liquid or carbon dioxide that would\ncorrode the pipeline, you must investigate the corrosive effect of the hazardous liquid\nor carbon dioxide on the pipeline and take adequate steps to mitigate internal\ncorrosion.\n11\n\n\n\nCRCT’s O&M procedure for internal corrosion in Section 10.1 was inadequate because it\ndid not have or reference their 6.01-ADM-001 document. This document provides more\nspecific procedures for investigating and providing preventative measures.\n27. §195.402(c)(3) – See Above\n§195.587 What methods are available to determine the strength of corroded pipe?\nUnder §195.585,, you may use the procedure in ASME/ANSI B31G (incorporated by\nreference, see §195.3) or in PRCI PR-3-805 (R- STRENG) (incorporated by\nreference, see §195.3) to determine the strength of corroded pipe based on actual\nremaining wall thickness. These procedures apply to corroded regions that do not\npenetrate the pipe wall, subject to the limitations set out in the respective procedures.\nCRCT’s O&M procedures for determining remaining strength due to external corrosion\nwere deficient because Section 10.8 and 10.10 should have all references changed from R-\nSTRENG to B-31G, because B-31G is the method used by CRCT. Also, CRCT must\nrevise the referenced addendum 6.01-ADM-002 to show that B-31G is used instead of R-\nSTRENG.\n28. §195.402(c)(3) – See Above\n§195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in\nsufficient detail to demonstrate the adequacy of corrosion control measures or that\ncorrosion requiring control measures does not exist. You must retain these records\nfor at least 5 years, except that records related to Secs. 195.569, 195.573(a) and (b),\nand 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in\nservice.\nCRCT’s O&M Procedure 4.8 is deficient because it did not indicate that annual surveys\nand exposed pipe inspections will be kept for the life of pipeline.\n29. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis Section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n12\n\n\n\n(4) Determining which pipeline facilities are located in areas that would require an\nimmediate response by the operator to prevent hazards to the public if the facilities\nfailed or malfunctioned.\nCRCT’s O&M did not have a procedure for determining which pipelines are located in\nareas that would require an immediate response if the facilities failed or malfunctioned.\nCRCT indicated that they respond to all incidents on their pipelines the same regardless of\nlocation, but that was not stated in the O&M.\n30. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis Section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(5) Analyzing pipeline accidents to determine their causes.\nCRCT’s O&M Section 19.16 for investigating a pipeline failure does not detail what the\ncompany is going to do to analyze and investigate an incident. For example, the procedure\ndid not include a change of custody form for transportation of the failed specimen or the\nuse of metallurgical testing protocols.\n31. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis Section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(10) Abandoning pipeline facilities, including safe disconnection from an operating\npipeline system, purging of combustibles, and sealing abandoned facilities left in\nplace to minimize safety and environmental hazards. For each abandoned offshore\npipeline facility or each abandoned onshore pipeline facility that crosses over, under\nor through commercially navigable waterways the last operator of that facility must\nfile a report upon abandonment of that facility in accordance with §195.59 of this\npart.\nCRCT’s O&M Section 3.4 for abandonment was inadequate because it is a restatement of\nthe code. CRCT personnel indicated that they would develop an abandonment procedure\nwhen they actually need to abandon a line. However, that was not in the procedures.\nAlso, if CRCT has an addendum procedure for abandonment, it should be referenced from\nthe O&M.\n13\n\n\n\n32. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis Section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(12) Establishing and maintaining liaison with fire, police, and other appropriate\npublic officials to learn the responsibility and resources of each government\norganization that may respond to a hazardous liquid or pipeline emergency and\nacquaint the officials with the operator's ability in responding to a hazardous liquid\nor carbon dioxide pipeline emergency and means of communication.\nCRCT’s procedure for establishing liaison with fire, police, and other public officials in\nSection 18.7 is deficient because it did not reference the Public Awareness plan (PAP).\nThe current procedure indicates that they will annually meet with fire, police, and public\nofficials face to face. CRCT personnel indicated that they do not do this. They are relying\non their PAP for this.\n33. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis Section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(13) Periodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and taking\ncorrective action where deficiencies are found.\nCRCT’s O&M procedure for the effectiveness review of the O&M in Section 1.10 is\ninadequate because the procedure is a partial restatement of the regulation. It does not\ndefine how company personnel will do the review and how often. Additionally, the\nprocedure does not indicate how personnel will document the effectiveness review.\n34. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(d) Abnormal operation. The manual required by paragraph (a) of this Section must\ninclude procedures for the following to provide safety when operating design limits\nhave been exceeded;\n(1) Responding to, investigating, and correcting the cause of;\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating limits;\n(iii) Loss of communications;\n14\n\n\n\n(iv) Operation of any safety device;\n(v) Any other malfunction of a component, deviation from normal operation, or\npersonnel error which could cause a hazard to persons or property.\nCRCT’s O&M for abnormal operations located in Section 13 was deficient because the\nprocedure did not provide enough guidance on what actions need to be performed in each\nspecific situation. For example, in the Loss of Communication Section, CRCT did not\ndefine what a “reasonable length of time” is before they classify the event as an abnormal\noperation. Also, CRCT did not define the activities each person is responsible for. The\naddendum 7.01-ADM-002 contains more specific procedures for abnormal operations but\nwas not referenced from the O&M.\n35. §195.402(d) – See above\n(2) Checking variations from normal operation after abnormal operation has ended\nat sufficient critical locations in the system to determine continued integrity and safe\noperation.\nCRCT’s O&M for checking the critical locations after an abnormal operation was\ninadequate because it was a repeat of the code language. Section 13.10 did not have a\nprocedure for their personnel to know what to do. For example, CRCT indicated that they\nwould determine the critical locations after the abnormal event occur and then check them\nas soon as the abnormal condition event was over.\n36. §195.402(d) – See above\n(5) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking corrective\naction where deficiencies are found.\nCRCT’s O&M for periodic review of employee actions to determine the effectiveness of\nthe abnormal operation procedure was just a restatement of the regulations. Section 13.9\ndid not define how often they do the evaluation, and how they will document it.\n37. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(e) Emergencies. The manual required by paragraph (a) of this Section must include\nprocedures for the following to provide safety when an emergency condition occurs;\n(1) Receiving, identifying, and classifying notices of events which need immediate\nresponse by the operator or notice to fire, police, or other appropriate public officials\nand communicating this information to appropriate operator personnel for\ncorrective action.\n15\n\n\n\nCRCT’s procedures in Sections 19.3 and 19.4 were deficient because they did not\nreference the Facility Response Plan (FRP) which contains the procedures for notification\nof the qualified individuals and other appropriate personnel.\n38. §195.402 (e) – See above\n(2) Prompt and effective response to a notice of each type emergency, including fire\nor explosion occurring near or directly involving a pipeline facility, accidental release\nof hazardous liquid or carbon dioxide from a pipeline facility, operational failure\ncausing a hazardous condition, and natural disaster affecting pipeline facilities.\nCRCT’s procedure for providing effective response to fire, natural disaster, and accidental\nrelease was deficient because it did not accurately detail what personnel would do if these\nscenarios should occur. For example, one of the steps indicated “If leaks are identified,\nshut the field down and close the liquid line inlet lines and blanket gas if it can be done\nsafely”. It does not appear that this step applies to crude oil pipelines.\n39. §195.402 (e) – See above\n(3) Having personnel, equipment, instruments, tools, and material available as\nneeded at the scene of an emergency.\nCRCT’s procedure for identifying the personnel and equipment needed at the scene of an\nemergency in Section 19.10 was not accurately defined. The list of personnel and\nequipment can be found in the FRP, which was not referenced from the O&M.\n40. §195.402 (e) – See above\n(9) Providing for a post accident review of employee activities to determine whether\nthe procedures were effective in each emergency and taking corrective action where\ndeficiencies are found.\nCRCT’s procedure for post-accident review of employee’s activities was deficient because\nthe procedure did not provide any guidance on how to meet this requirement. For\nexample, the procedure states: “Determine whether the procedures were effective in each\nemergency and taking corrective action where deficiencies are found.” This is a partial\nrestatement of the regulation with no guidance on how personnel are going to do this. The\nprocedure did not provide guidance on what the post-accident review consists of, and how\nCRCT will document it.\n16\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 inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 90 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have\nbeen addressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Coffeyville Resources Crude Transportation, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Allan C.\nBeshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration.\nIn correspondence concerning this matter, please refer to CPF 3-2016-5007M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n17\n\n320165007M_Closure Letter_02032017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 3, 2017\nMr. Robert Haugen\nExecutive Vice President of Refining Operations\nCoffeyville Resources Crude Transportation, LLC\n2277 Plaza Drive\nSuite 500; Building B\nSugarland, TX 77479\nCPF 3-2016-5007M\nDear Mr. Haugen:\nOn May 9-13, 2016, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of Coffeyville Resources Crude Transportation, LLC’s (CRCT)\nprocedures in Bartlesville, Oklahoma. As a result of the inspection, CRCT was issued a Notice\nof Amendment on September 19, 2016, which proposed amendment of your procedures.\nCRCT submitted its amended procedures on October 20, 2016 and December 23, 2016. My\nstaff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":38448}