{"operation":"document","citation":"CPF 320185010M","title":"ENBRIDGE STORAGE (CUSHING) L.L.C. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-10-05","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(c)(2), 195.446(f)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320185010m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320185010m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320185010m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320185010M","body":"Notice of Amendment involving ENBRIDGE STORAGE (CUSHING) L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(c)(2),  195.446(f)(1). The case was opened on 2018-10-05 and is reported as closed as of 2019-03-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320185010M_Closure Letter_03202019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185010M/320185010M_Closure%20Letter_03202019.pdf\n\n320185010M_Closure Letter_03202019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185010M/320185010M_Closure%20Letter_03202019_text.pdf\n\n320185010M_Notice of Amendment_10052018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185010M/320185010M_Notice%20of%20Amendment_10052018.pdf\n\n320185010M_Notice of Amendment_10052018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185010M/320185010M_Notice%20of%20Amendment_10052018_text.pdf\n\n320185010M_Closure Letter_03202019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 20, 2019\nMr. Bradley Shamla\nVice President, US Operation, Liquid Pipelines\nEnbridge Storage (Cushing) L.L.C.\n7701 France Ave. S, Suite 600\nCentennial Lakes Office Park\nEdina, MN 55435\nCPF 3-2018-5010M\nDear Mr. Shamla:\nOn August 13-17, 2018, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Enbridge Storage (Cushing) L.L.C. procedures in\nCushing, OK. As a result of the inspection, Enbridge Storage was issued a Notice of\nAmendment on 10-5-2018, which proposed amendment of your procedures.\nEnbridge Storage submitted its amended procedures for review during the inspection. 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\n\n320185010M_Notice of Amendment_10052018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 5, 2018\nMr. Bradley Shamla\nVice President, US Operation, Liquid Pipelines\nEnbridge Storage (Cushing) L.L.C.\n7701 France Ave. S, Suite 600\nCentennial Lakes Office Park\nEdina, MN 55435\nCPF 3-2018-5010M\nDear Mr. Shamla:\nOn August 13 – 17, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nEnbridge Storage (Cushing) L.L.C. procedures for Control Room Management in Cushing,\nOK.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEnbridge Storage (Cushing) L.L.C. plans or procedures, as described below:\n1. §195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements\nof this section. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by § 195.402…\n\n\n\n(c) Provide adequate information. Each operator must provide its controllers\nwith the information, tools, processes and procedures necessary for the\ncontrollers to carry out the roles and responsibilities the operator has defined by\nperforming each of the following:\n(2) Conduct a point-to-point verification between SCADA displays and\nrelated field equipment when field equipment is added or moved and when\nother changes that affect pipeline safety are made to field equipment or\nSCADA displays;\nEnbridge failed to develop adequate processes for the thoroughness of the point-to-\npoint verification. Specifically, the Enbridge SCADA Point to Point Verification\nProcedure failed to include a time limit and quality control checkpoints for completing\nmultiphase point to point.\nAlso, Enbridge failed to develop an adequate process for defining when the point-to-\npoint verification must be completed. Specifically, the Enbridge Point to Point\nVerification - PLC Changes Procedure failed to include a time limit for point to point\nverification.\nEnbridge submitted updated procedures. PHMSA has reviewed the procedures and\nfound them satisfactory. No further action is required.\n2. §195.446(a) – See Above\n§195.446 Control room management.\n(f) Change management. Each operator must assure that changes that could\naffect control room operations are coordinated with the control room personnel\nby performing each of the following:\n(1) Implement section 7 of API RP 1168 (incorporated by reference, see §\n195.3) for control room management change and require coordination\nbetween control room representatives, operator's management, and\nassociated field personnel when planning and implementing physical\nchanges to pipeline equipment or configuration; and\nEnbridge failed to develop a process to mandate that a control room representative will\nparticipate in meetings where changes that could directly or indirectly affect control\nroom operations (including routine maintenance and repairs) are being considered,\ndesigned and implemented. Specifically, Cushing Control Room Management Plan\nsection 7.2.1 states that “control room personnel should be included in the project or\nchange design and planning process.”\n2\n\n\n\nEnbridge submitted updated procedures. PHMSA has reviewed the procedures and\nfound them satisfactory. No further action is required.\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).\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 Enbridge Storage (Cushing) L.L.C. 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 Beshore,\nDirector, Central Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 3-2018-5010M 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\n3","truncated":false,"body_characters":8301}