{"operation":"document","citation":"CPF 320175003M","title":"WHITE CLIFFS PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-11","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3), 195.402(d)(5), 195.420(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320175003M","body":"Notice of Amendment involving WHITE CLIFFS PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  195.402(d)(5),  195.420(a). The case was opened on 2017-05-11 and is reported as closed as of 2018-03-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320175003M_Closure Letter_03282018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175003M/320175003M_Closure%20Letter_03282018.pdf\n\n320175003M_Closure Letter_03282018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175003M/320175003M_Closure%20Letter_03282018_text.pdf\n\n320175003M_Notice of Amendment_05112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175003M/320175003M_Notice%20of%20Amendment_05112017.pdf\n\n320175003M_Notice of Amendment_05112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175003M/320175003M_Notice%20of%20Amendment_05112017_text.pdf\n\n320175003M_Operators Response To Notice_06062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175003M/320175003M_Operators%20Response%20To%20Notice_06062017.pdf\n\n320175003M_Notice of Amendment_05112017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 11, 2017\nMr. David Minielly\nVice President of Operations\nWhite Cliffs Pipeline, LLC\n6120 S. Yale Ave.\nSuite 1500\nTulsa, Oklahoma 74136\nCPF 3-2017-5003M\nDear Mr. Minielly:\nOn October 3rd – 14th, 2016, representatives of the Central Region office of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected the operation and maintenance (O&M) procedures for White Cliffs\nPipeline, LLC at your offices in Colorado, Kansas, and Oklahoma.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nWhite Cliffs Pipeline, LLC plans or procedures, as described below:\n1. §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.\n\n\n\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(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§195.420 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\nWhite Cliffs Pipeline procedures at the time of the inspection were simply repeat of the\ncode. The procedures did not indicate which valves are necessary for the safe operation of\nits pipeline system or how they would ensure that the valves were in good working order.\n2. §195.402 (a) See above\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(5) Periodically reviewing the response of operator personnel to\ndetermine the effectiveness of the procedures controlling abnormal\noperation and taking corrective action where deficiencies are found.\nWhite Cliffs Pipeline procedures did not address how they would determine the\neffectiveness of the abnormal operations procedures. The procedures did not address who\nwould review procedures or how often the procedures would be reviewed.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\n\n\n\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin [number of days] days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed\nin your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that White Cliffs Pipeline maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to Allan C. Beshore, Director, Central Region,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 3-2017-5003M and, for each document you submit, please provide\na copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n\n320175003M_Closure Letter_03282018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 28, 2018\nMr. David Minielly\nVice President of Operations\nWhite Cliffs Pipeline, LLC\n6120 S. Yale Ave.\nSuite 1500\nTulsa, Oklahoma 74136\nCPF 3-2017-5003M\nDear Mr. Minielly:\nOn October 3rd -14th, 2016, a representative 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 White Cliffs Pipeline, LLC procedures in Colorado, Kansas,\nand Oklahoma. As a result of the inspection, White Cliffs Pipeline, LLC was issued a Notice of\nAmendment on May 11, 2017, which proposed amendment of your procedures.\nWhite Cliffs Pipeline, LLC submitted its amended procedures on June 6, 2017. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment 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":7651}