{"operation":"document","citation":"CPF 320196007M","title":"CRESTWOOD MIDSTREAM PARTNERS LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-11-22","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3), 195.432(b), 195.452(f)(1), 195.452(f)(3), 195.452(f)(5), 195.452(f)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320196007M","body":"Notice of Amendment involving CRESTWOOD MIDSTREAM PARTNERS LP. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  195.432(b),  195.452(f)(1),  195.452(f)(3),  195.452(f)(5),  195.452(f)(6). The case was opened on 2019-11-22 and is reported as closed as of 2020-06-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320196007M_Closure Letter_06032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196007M/320196007M_Closure%20Letter_06032020.pdf\n\n320196007M_Closure Letter_06032020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196007M/320196007M_Closure%20Letter_06032020_text.pdf\n\n320196007M_Notice of Amendment_11222019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196007M/320196007M_Notice%20of%20Amendment_11222019.pdf\n\n320196007M_Notice of Amendment_11222019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196007M/320196007M_Notice%20of%20Amendment_11222019_text.pdf\n\n320196007M_Operator Response to Notice (REVISED)_04062020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196007M/320196007M_Operator%20Response%20to%20Notice%20(REVISED)_04062020.pdf\n\n320196007M_Operator Response to Notice__12312019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196007M/320196007M_Operator%20Response%20to%20Notice__12312019.pdf\n\n320196007M_Notice of Amendment_11222019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 22, 2019\nMr. Robert G. Phillips\nPresident and Chief Executive Officer\nCrestwood Equity Partners LP\n811 Main Street Suit 3400\nHouston, Texas 77002\nCPF 3-2019-6007M\nDear Mr. Phillips:\nFrom March 19-23, 2018, and September 10-14, 2018, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Crestwood Equity Partners LP (Crestwood) procedures in Williston,\nNorth Dakota.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCrestwood’s 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(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\n\n\n(1) . . . .\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§195.432 Inspection of in-service breakout tanks.\n(a) . . . .\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\nreference, see §195.3). However, if structural conditions prevent access to the tank\nbottom, its integrity may be assessed according to a plan included in the operations\nand maintenance 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.\nAPI 653\n6.3.2.1 All tanks shall be given a visual external inspection by an authorized inspector.\nThis inspection shall be called the external inspection and must be conducted at least\nevery 5 years or RCA/4N years (where RCA is the difference between the measured shell\nthickness and the minimum required thickness in mils, and N is the shell corrosion rate in\nmils per year) whichever is less. Tanks may be in operation during this inspection.\nCrestwood’s breakout tank inspection procedure 2.19 failed to incorporate the 5-year\nexternal inspection cycle as required by API Standard 653 Section 6.3.2.1. Crestwood’s\nprocedural manual must be amended to include this requirement.\n2. §195.402(c)(3) – See above\n§195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area\n2\n\n\n\nCrestwood’s Integrity Management Plan (IMP) did not contain adequate procedures to\nidentify line segments that could affect high consequence areas (HCA). Specifically, the\nmanual did not have procedures on how Crestwood conducts an analysis of the pipeline\nalong the right-of-way and for breakout tanks and pump station facilities. Crestwood’s\nIMP procedures must be amended to include details on the process to identify these line\nsegments that could affect HCA directly, by overland spread or water transport.\n3. §195.402(c)(3) – See above\n§195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program\n(1) . . . .\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nCrestwood’s IMP did not have procedures to identify and evaluate the risks to the\nbreakout tanks and pump station in Epping, ND that could affect HCAs. Crestwood must\namend its IMP to include this requirement.\n4. §195.402(c)(3) – See above\n§195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program\n(1) . . . .\n(5) A continual process of assessment and evaluation to maintain a pipeline's\nintegrity (see paragraph (j) of this section);\n3\n\n\n\nCrestwood’s IMP did not include procedures to perform continual evaluations of facility\nintegrity for the breakout tanks and pump station in Epping, ND. Crestwood must amend\nits IMP to include this requirement.\n5. §195.402(c)(3) – See above\n§195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program\n(1) . . . .\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\nCrestwood’s IMP did not include procedures for the identification of facility preventive\nand mitigative measures to protect the HCAs for the breakout tanks and pump station in\nEpping, ND. Crestwood must amend its IMP to include this requirement.\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\n4\n\n\n\nwithin 60 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Crestwood Equity Partners LP maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2019-6007M and, for each document you\nsubmit, 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 Enforcement Proceedings\n5\n\n320196007M_Closure Letter_06032020_text.pdf\n\nVIA ELECTRONIC MAIL TO: Robert.Phillips@crestwoodlp.com and\nJustin.Davidson@crestwoodllp.com\nJune 3, 2020\nMr. Robert G. Phillips\nPresident and Chief Executive Officer\nCrestwood Equity Partners LP\n811 Main Street Suite 3400\nHouston, Texas 77002\nRobert.Phillips@crestwoodlp.com\nRe: CPF 3-2019-6007M\nDear Mr. Phillips:\nOn March 19-23, 2018, and September 10-14, 2018, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Crestwood Equity Partners LP\n(Crestwood) procedures in Williston, North Dakota. As a result of the inspection, Crestwood\nCrestwood was issued a Notice of Amendment on November 22, 2019, which proposed\namendment of your procedures.\nCrestwood submitted its amended procedures in November 2019 and January 2020 with final\nversions submitted on April 15, 2020. My staff reviewed the amended procedures, and it appears\nthat the inadequacies outlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nCopy: Justin Davidson, Pipeline Compliance Advisor, Crestwood, 811 Main St., Suite 3400,\nHouston, TX 77002, Justin.Davidson@crestwoodllp.com","truncated":false,"body_characters":12677}