{"operation":"document","citation":"CPF 420055008M","title":"NAVAJO NATION OIL AND GAS COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2005-01-07","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(4), 195.452(f)(6), 195.452(i)(2), 195.452(i)(3), 195.452(j)(2), 195.452(j)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420055008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420055008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420055008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420055008M","body":"Notice of Amendment involving NAVAJO NATION OIL AND GAS COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(4),  195.452(f)(6),  195.452(i)(2),  195.452(i)(3),  195.452(j)(2),  195.452(j)(5). The case was opened on 2005-01-07 and is reported as closed as of 2007-05-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420055008M_Order Directing Amendment_09062006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420055008M/420055008M_Order%20Directing%20Amendment_09062006.pdf\n\nCPF_NO_4-2005-5008M.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420055008M/CPF_NO_4-2005-5008M.pdf\n\n420055008M_Order Directing Amendment_09062006.pdf\n\n@\nU.S. Deporlment\nof Tronsporlotion\nPipeline ond Hozqrdous\nMoteriols Sofety Administrqtion 400 Seventh Street, S.W\nWashington, D.C.20590\n$EP - 6 2006\nMr. Wilson Groen\nPresident and General Manager\nNavajo Nation Oil and Gas Company, Inc.\nP.O. Box 4439\nWindow Rock, AZ 86515-4439\nRe: CPF No. 4-2005-5008M\nDear Mr. Groen:\nEnclosed is the Order Directing Amendment issued by the Associate Administrator for\nPipeline Safety in the above-referenced case. It makes a finding of inadequate procedures and\nrequires that you amend your written integrity management program. When the terms of the\nOrder are completed, as determined by the Director, Southwest Region, this enforcement action\nwill be closed. Your receipt of the Order Directing Amendment constitutes service of that\ndocument under 49 C.F.R. $ 190.5.\nSincerely,\nd=\"\". {1--\nJames Reynolds\nPipeline Compliance Registry\nOffice of Pipeline Safety\nEnclosure\nCERTIFIED MAIL - RETURN RECEIPT REOUESTED\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON. DC 20590\nIn the Matter of\nNavajo Nation Oil and Gas Company,Inc.,\nRespondent\nCPF No.4-20085-5008M\n)\nORDER DIRECTING AMENDM4NT\nOn October 12-15,2004, pursuant to 49 U.S.C. $ 60117, representatives of the Pipeline and\nHazardous Materials Safety Administration's OfFrce of Pipeline Safety inspected Respondent's\nwritten integrity management program (IMP) at its facility in Window Rock, Arizona. As a\n'result of the inspection, the Director, Southwest Region, issued to Respondent, by letter dated\nJanuary 7, 2005, a Notice of Amendment (NOA). The NOA alleged inadequacies in\nRespondent's IMP and proposed to require amendment of Respondent's procedures to comply\nwith the requirements at 49 C.F.R. g 195.452.\nRespondent did not respond to the NOA within 30 days, but submitted a letter dated March 24,\n2005. Respondent did not contest the allegations set forth in the NOA and described the actions\nit is taking to address the inadequacies. Respondent did not request a hearing and has waived its\nright to one. Respondent requested an extension of 90 days to submit documentation of its\ncompliance. By letter dated March 31,2005, the Director, Southwest Region, provided\nRespondent an extension until May 20, 2005 to submit amended procedures for review.\nRespondent failed to submit any documentation for review.\nAccordingly, I find that Respondent's IMP is inadequate to ensure safe operation of its pipeline\nsystem. Pursuant to 49 U.S.C. $ 60108(a) and 49 C.F.R. g 190.237, Respondent is ordered to\nmake the following changes to its IMP. Respondent must-\nl. Amend the process for identifying which pipeline segments could affect a high\nconsequence area. The process must document the use of local knowledge, information\nobtained from routine fie.ld activities (such as right-of-way surveillance and aerial\nsurveys), and other information sources to supplement data from the National Pipeline\nMapping System (NPMS) to accurately reflect current conditions in the vicinity of the\npipeline. Although Respondent's IMP refers to the use of \"provisions to assure that local\nknowledge . . . is used as required to supplement NPMS data,\" Respondent does not\nactually provide details for that process. The IMP must provide a detailed process for\n\n\n\n2\n2.\na\nJ .\n4.\nsupplementing NPMS data as described, including how, when and where the process is to\nbe performed, who is responsible, where the data flow goes, and why the process is\nnecessary.\nAmend the process for review of integrity assessment results and information analysis by\nsomeone qualified to evaluate the results and information. Respondent's IMP states that\nafter in-line inspection tool runs, Respondent may implement a process for excavating\nanomalies to validate tool results using actual measured defect characteristics. The IMP\nmust include procedures to identifr and implement each activity that is required to\nvalidate the in-line inspection data. If Respondent chooses not to validate and calibrate\ntool results, the IMP must include documented justification to demonstrate that validation\nand calibration activities are not necessary for Respondent's particular circumstances.\nRespondent's IMP must also contain process documentation to provide guidance or\nprocedures for performing a detailed review of integrity assessment results, generating a\nrepair schedule, and integrating additional sources of risk factor data, such as cathodic\nprotection data and right-of-wa-y surveillance. The process must support the eval'riation\nof pipeline condition and decision-making related to the repair or remediation of\nconditions, to ensure that qualified persons are able to effectively implement the process.\nAmend the process for the review of integrity assessment results and information analysis\nby someone qualified to evaluate the results and information. The IMP must include\npioces documentation specifying how additional information should be integrated with\nintegrity assessment results to support decisions on excavation and repair of identified\nconditions. Respondent's form titled \"Pipeline Integrity Assessment Results Analysis\"\nprovides a place for collected data to be recorded, but Respondent has no guidance for\nusing the form. Respondent must provide guidance for using the form in addition to\ncommunication of results to ensure that the form is fully and consistently utilized.\nAmend the process for analysis that integrates all available information about the\nintegrity of the entire pipeline and the consequences of a failure. The IMP must include a\ndocumented justification or basis for the risk model numerical values and weights used\nfor variables and risk factors. Respondent must remove as much subjectivity from the\nprocess as possible by assigning criteria to the 1, 3, and 5 weights or by providing\nguidance for assigning subjective weights to assure consistent application and\nrepeatability. The IMP must integrate information about pipeline risks associated with all\nmodes of operation where hazardous liquids are present, including startup, shutdown, and\nslack line operation. Respondent's discharge volumes are stated as worst case conditions,\nbut the analyses must consider lack of tankage isolation as a potential contributing factor\nto spill volume. If the tankage is sufficiently isolated to prevent the tank inventory from\nincreasing the worst case spill volume, Respondent must provide a justified statement in\nthe IMP describing the supporting conditions.\nAmend the element for identification of preventive and mitigative measures to protect\nhigh consequence areas. The IMP must document the systematic decision-making\nprocess that includes input from relevant parts of the organization such as management,\noperations, and engineering. The process must consider the results of the risk analysis\n\n\n\nJ\n6.\n8.\nalong with other information in making decisions about which preventive and mitigative\nactions to implement.\nAmend the element for identification of preventive and mitigative measures to protect\nhigh consequence areas. The IMP must document the process for evaluating the\ncapability of leak detection means and modify, as necessary, to protect high consequence\nareas per S 195.452(i)(3). Respondent verbally refers to its Facility Response Procedure\nmanuals regarding leak detection evaluation, but Respondent must include a process in\nthe IMP for leak detection evaluation. The location of the nearest response personnel, as\naddressed in the Facility Response Manuals, is one of the required factors for\nconsideration. Potential changes to leak detection capability as a response to operator\nactions and reactions and lessons learned during drills must also be included in the\nprocess. This manual, if used as part of Respondent's IMP must be referenced in the IMP\ndocumentation.\nAmend the Iiv{P to document the continual piocess of assessment and evaluation to\nmaintain a pipeline's integrity. The periodic evaluation must be conducted as frequently\nas needed to assure pipeline integrity. Respondent must base the frequency of evaluation\non the risk factors specific to its pipeline including the factors specified in $ 195.452(e).\nThe evaluation must consider the results of the baseline and periodic integrity\nassessments, information analysis ($ 195.452(9)), decisions about remediation, and\npreventive and mitigative measures ($ 195.452(h) and (i)).\nAmend the IMP to document the continual process of assessment and evaluation to\nmaintain a pipeline's integrity. The IMP must correlate assessment methods with\npipeline specific conditions and risk factors evaluated in accordance with $ 195.452CX5).\nThe correlation must be specific enough to ensure that Respondent chooses assessment\nmethods capable of detecting anomalies that could result from the specifrc risks to each\npipeline segment assessed. One of the purposes of the hazardous liquids pipeline\nintegrity management regulation is to promote rigorous, systematic management of\npipeline integrity through the implementation of management systems (processes). As\ndiscussed during the inspection, as Respondent's IMP processes and management\nsystems are implemented and revised, there must be greater specificity in process\ndocumentation, including inputs, steps performed, and expected outputs for evaluation to\nensure these processes can be consistently applied and repeated. Respondent's IMP is\nlargely comprised of language taken directly from PHMSA's Liquid IMP Inspection\nProtocols. Although the Protocols are intended to be helpful guidance in the initial\ndeVelopment of an IMP, they do not constitute detailed process descriptions that meet\nregulatory requirements. Respondent must develop sufficiently detailed processes and\nprocedural controls to assure consistent evaluation, quality, and communication of\nintegrity management processes. Where prescriptive terminology is used in the\nregulation, such as deadlines, timelines or quantities, Respondent's IMP shall include that\nlanguage. Respondent must customize the required processes to its unique operating\nenvironment. For example, Respondent must indicate how, when and where the\nprocesses are to be performed, who is responsible, where the data flow goes, and why the\nprocesses are necessary.\n\n\n\n9. Complete each of the above items and submit documentation of completion within 30\ndays of receipt of this Order. Submit documentation to the Director, Southwest Region,\nPipeline and Hazardous Materials Safety Administration, 8701 South Gessner Drive,\nSuite 1110, Houston, TX 77074-2949.\nThe Director, Southwest Region, may grant an extension of time to comply with any of the\nrequired items upon a written request timely submitted by the Respondent demonstrating good\ncause for an extension.\nFailure to comply with this Order may result in administrative assessment of civil penalties up to\nS100,000 per day for each violation and in referral to the Attorney General for appropriate relief\nin a district court of the United States. The terms and conditions of this Order Directing\nAmendment are effective upon receipt.\nsEP - 6 20$$\nDate Issued\nfor Pipeline Safety","truncated":false,"body_characters":11905}