WHITE CLIFFS PIPELINE, LLC — Notice of Amendment

party submissionOfficial PDF320175003M_Operators Response To Notice_06062017.pdf#

320175003M_Notice of Amendment_05112017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED May 11, 2017 Mr. David Minielly Vice President of Operations White Cliffs Pipeline, LLC 6120 S. Yale Ave. Suite 1500 Tulsa, Oklahoma 74136 CPF 3-2017-5003M Dear Mr. Minielly: On October 3rd – 14th, 2016, representatives of the Central Region office of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the operation and maintenance (O&M) procedures for White Cliffs Pipeline, LLC at your offices in Colorado, Kansas, and Oklahoma. As a result of the inspection, PHMSA has identified the apparent inadequacies found within White Cliffs Pipeline, LLC plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted.#

320175003M_Notice of Amendment_05112017_text.pdf, page 2(c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. §195.420 Valve maintenance. (a) Each operator shall maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times White Cliffs Pipeline procedures at the time of the inspection were simply repeat of the code. The procedures did not indicate which valves are necessary for the safe operation of its pipeline system or how they would ensure that the valves were in good working order. 2. §195.402 (a) See above (d) Abnormal operation. The manual required by paragraph (a) of this section must include procedures for the following to provide safety when operating design limits have been exceeded: (5) Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. White Cliffs Pipeline procedures did not address how they would determine the effectiveness of the abnormal operations procedures. The procedures did not address who would review procedures or how often the procedures would be reviewed. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).#

320175003M_Notice of Amendment_05112017_text.pdf, page 3Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within [number of days] days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that White Cliffs Pipeline maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 3-2017-5003M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration#

320175003M_Closure Letter_03282018_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 28, 2018 Mr. David Minielly Vice President of Operations White Cliffs Pipeline, LLC 6120 S. Yale Ave. Suite 1500 Tulsa, Oklahoma 74136 CPF 3-2017-5003M Dear Mr. Minielly: On October 3rd -14th, 2016, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on- site pipeline safety inspection of White Cliffs Pipeline, LLC procedures in Colorado, Kansas, and Oklahoma. As a result of the inspection, White Cliffs Pipeline, LLC was issued a Notice of Amendment on May 11, 2017, which proposed amendment of your procedures. White Cliffs Pipeline, LLC submitted its amended procedures on June 6, 2017. My staff 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 this case is now closed. Thank you for your cooperation. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration#