{"operation":"document","citation":"CPF 32021004NOA","title":"OLYMPIC PIPE LINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-01-29","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021004noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021004noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021004noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021004NOA","body":"Notice of Amendment involving OLYMPIC PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2021-01-29 and is reported as closed as of 2021-03-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021004NOA_Closure Letter_03122021_(20-196687).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021004NOA/32021004NOA_Closure%20Letter_03122021_(20-196687).pdf\n\n32021004NOA_Closure Letter_03122021_(20-196687)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021004NOA/32021004NOA_Closure%20Letter_03122021_(20-196687)_text.pdf\n\n32021004NOA_Notice of Amendment_01292021_(20-196687).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021004NOA/32021004NOA_Notice%20of%20Amendment_01292021_(20-196687).pdf\n\n32021004NOA_Notice of Amendment_01292021_(20-196687)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021004NOA/32021004NOA_Notice%20of%20Amendment_01292021_(20-196687)_text.pdf\n\n32021004NOA_Operator Response to Notice_02192021_(20-196687).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021004NOA/32021004NOA_Operator%20Response%20to%20Notice_02192021_(20-196687).pdf\n\n32021004NOA_Closure Letter_03122021_(20-196687)_text.pdf\n\nVIA ELECTRONIC MAIL TO: gerald.maret@bp.com and Timothy.Smith@bp.com\nMarch 12, 2021\nMr. Gerald Maret, President\nOlympic Pipeline Company\n30 S Wacker Drive,\nChicago, IL 60606\nCPF 3-2021-004-NOA\nDear Mr. Maret:\nFrom August 3 through 19 and October 12 through 16, 2020 a representative from the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Olympic Pipeline Company’s\n(Olympic) procedures. As a result of the inspection, Olympic was issued a Notice of\nAmendment on January 29, 2021, which proposed amendment of your procedures.\nOlympic submitted its response on February 19 and amended procedures on March 1, 2021. 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 you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n\n32021004NOA_Notice of Amendment_01292021_(20-196687)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: gerald.maret@bp.com and Timothy.Smith@bp.com\nJanuary 29, 2021\nMr. Gerald Maret, President\nOlympic Pipeline Company\n30 S Wacker Drive,\nChicago, IL 60606\nCPF 3-2021-004-NOA\nDear Mr. Maret:\nFrom August 3 through 19, and October 12 through October 16, 2020, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code inspected your pipeline procedures for repairs virtually.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nOlympic Pipeline Company (Olympic) plans or procedures, as described below:\n1. §195.402 Procedure manual for operations, maintenance, and emergencies.\n(a) Procedural manual for operations, maintenance, and emergencies.\nOlympic’s Operations and Maintenance (O&M) manual failed to address criteria for repairs in a\nhigh consequence area (HCA) and is therefore inadequate to comply with §§ 195.402(c)(3) and\n195.452(f). Olympic’s repair procedure, P 195.422, directs Olympic personnel or contractors to\nfollow the ASME B 31.4 repair criteria in HCAs. Section 195.402(c)(3) requires an operator to\ninclude in the O&M manual procedures for “operating, maintaining, and repairing the pipeline\nsystem in accordance with each of the requirements of this subpart [subpart F] and subpart H of\nthis part.” Section 195.452(f), which is included within subpart F, governs what must be\nincluded in an operators’ integrity management program, and that section specifically references\n§ 195.452(h) as the regulatory section controlling remedial actions to address integrity issues in\n\n\n\nHCAs. These regulatory sections taken together require operators to include the repair criteria\nspecified in § 195.452(h) in a written Integrity Management program. The omission of a\nreference to the repair criteria under § 195.452(h) for repairs in HCAs renders the procedure\ninadequate to comply with the regulation.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart 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 for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust 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 information\nqualifies 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 of\nreceipt 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 in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n[number of days] days of receipt of this Notice. This period may be extended by written request\nfor good 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 Olympic Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Gregory A. Ochs, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2021-004-NOA and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nCC: Mr. Timothy Smith, Manager, DOT Compliance, 30 S. Wacker Drive,\nChicago, IL 60606 (Timothy.Smith@bp.com)\n2","truncated":false,"body_characters":7069}