{"operation":"document","citation":"CPF 420071001M","title":"GULF SOUTH PIPELINE COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-03-27","effective_on":null,"summary":"CLOSED notice of amendment citing 192.7, 192.903, 192.905, 192.933(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420071001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420071001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420071001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420071001M","body":"Notice of Amendment involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.7,  192.903,  192.905,  192.933(b). The case was opened on 2007-03-27 and is reported as closed as of 2008-10-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420071001M_Notice Letter_03272007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071001M/420071001M_Notice%20Letter_03272007.pdf\n\nGulf South Request for Hearing.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071001M/Gulf%20South%20Request%20for%20Hearing.pdf\n\n420071001M_Notice Letter_03272007.pdf\n\n@\nU.S. Deporhent\nof Tronsportotion\nPipellne ond\nHozordous lrtoleriols sqlely\nAdminislrqtion\n8701 South Gessner, Suite 'l'110\nHouston, TX 77074\nt'4AR 2 e \"..:l\nNOTICE OF AMENDMENT\nCERTIFIED MAIL. RETURN RECEIPT REQUESTED\nMarch 27,2007\nMr. John Earley\nSenior Vice President\nGulf South Pipeline\n20 E. Greenway Plaza\nSuite 900\nHouston, Texas 77046\ncPF 4-2007-1001M\nDear Mr. Earley:\nDuring the weeks of January 23 - 27, and February 6 - 10, 2006, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code inspected your integrity management program in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nGulf South's plans or procedures, as described below:\n1. 5192.7 What documents are incorporated by reference partly or wholly in this\npart? (a) Any documents or portions thereof incorporated by reference in this part\nare included in this part as though set out in full. When only a portion of a\ndocument is referenced, the remainder is not incorporated in this part.\n\n\n\n2.\n3.\nGulf South must modify its procedures to justify deviations from \"should\" statements or\nrecommendations in standards documents. Currently, this practice is not included in the\ndefinition of a \"should\" statement in Section 1.1 .4 of the Gulf South lMP.\n5192.903 What definitions apply to this subpart? Potential impact radius (PlR)\nmeans the radius of a circle within which the potential failure of a pipeline could\nhave significant impact on people or property. PIR is determined by the formula r\n= 0.69* (square root of (p.d2)), where 'r' is the radius of a circular area in feet\nsurrounding the point of failure, 'p' is the maximum allowable operating pressure\n(MAOP) in the pipeline segment in pounds per square inch and 'd' is the nominal\ndiameter of the pipeline in inches.\nNote: 0.69 is the factor for natural gas. This number will vary for other gases\ndepending upon their heat of combustion. An operator transporting gas other\nthan natural gas must use section 3.2 of ASME/ANSI 831.85-2001 (Supplement to\nASME 831 .8; ibr, see 5192.7) to calculate the impact radius formula.\nA. Gulf South must modify its procedures to include process details to routinely re-\nevaluate the potential for gas streams that may exceed the 1'l 00 BTU limit for\nlean natural gas. Failure to re-evaluate gas stream BTU characteristics could\nresult in larger potential impact circles than have been analyzed for the\n' identification of covered segments.\nB. Gulf South must modify its procedures to define PIR buffer tolerance in order to\nensure potential impacts to buildings intended for human occupancy are\nadequately determined. The use of discrete building points without the addition of\na conservative PIR buffer tolerance or actual building outlines can result in the\nexclusion of a dwelling intended for human occupancy in the 20 or more housing\ncount criteria for identification of covered segments.\n5192.91 1 (a) An identification of all high consequence areas, in accordance with\ns192.905.\n5192.905 How does an operator identify a high consequence area? (a) General. To\ndetermine which segments of an operator's transmission pipeline system are\ncovered by this subpart, an operator must identify the high consequence areas.\nAn operator must use method (1) or (2) from the definition in $192.903 to identify a\nhigh consequence area. An operator may apply one method to its entire pipeline\nsystem, or an operator may apply one method to individual portions of the\npipeline system. An operator must describe in its integrity management program\nwhich method it is applying to each portion of the operator's pipeline system, The\ndescription must include the potential impact radius when utilized to establish a\nhigh consequence area. (See appendix E.l. for guidance on identifying high\nconsequence areas.)\nGulf South must revise its procedures in accordance with S192.905 (a) to ensure timely\nand routine acquisition of required data and the associated analysis to identify HCAs.\nThe Gulf South IMP Section 3.'1 .2 describing the aerial photography indicated that new\nimagery will be obtained on an as-needed basis dependent on major changes in land\nuse. This section also indicated that regular contacts with public officials will be\nmaintained in order to obtain new information on identified sites. This process does not\nmeet the intent of the regulation because HCAs and ldentified Sites might well develop\n\n\n\n4.\nin locations that do not undergo significant land use changes. Waiting till such time will\nsurely result in missing HCAs. A specific timeframe for conducting these updates and\ncontacts should be defined.\n5192.911 (e) Provisions meeting the requirements of 5192.933 for remediating\nconditions found during an integrity assessment.\n5192.933 What actions must be taken to address integrity issues?\n(b) Discovery of condition. Discovery of a condition occurs when an operator has\nadequate information about a condition to determine that the condition presents a\npotential threat to the integrity of the pipeline. A condition that presents a\npotential threat includes, but is not limited to, those conditions that require\nremediation or monitoring listed under paragraphs (d)(1) through (dX3) of this\nsection. An operator must promptly, but no laterthan 180 days after conducting\nan integrity assessment, obtain sufficient information about a condition to make\nthat determination, unless the operator demonstrates that the 180-day'period is\nimpracticable.\n(d) Special requirements for scheduling remediation.\n(1) lmmediate repair conditions. An operator's evaluation and remediation\nschedule must follow ASME/ANSI 831.8S, section 7 in providing for immediate\nrepair conditions. To maintain safety, an operator must temporarily reduce\noperating pressure in accordance with paragraph (a) of this section or shut down\nthe pipeline until the operator completes the repair of these conditions, An\noperator must treat the following conditions as immediate repair conditions:\n(3) Monitored conditions. An operator does not have to schedule the following\nconditions for remediation, but must record and monitor the conditions during\nsubsequent risk assessments and integrity assessments for any change that may\nrequire remediation:\n(i) A dent with a depth greater than 6% of the pipeline diameter (greater\nthan 0.50 inches in depth for a pipeline diameter less than NPS 12) located\nbetween the 4 o'clock position and the 8 o'clock position (bottom 1/3 of the pipe).\n(ii) A dent located between the I o'clock and 4 o'clock positions (upper 2/3\nof the pipe) with a depth greater than 6% of the pipeline diameter (greater than\n0.50 inches in depth for a pipeline diameter less than Nominal Pipe Size (NPS) 12),\nand engineering analyses of the dent demonstrate critical strain levels are not\nexceeded.\n(iii) A dent with a depth greater than 2% of the pipeline's diameter (0.250\ninches in depth for a pipeline diameter less than NPS 12) that affects pipe\ncurvature at a girth weld or a longitudinal seam weld, and engineering analyses of\nthe dent and girth or seam weld demonstrate critical strain levels are not\nexceeded. These analyses must consider weld properties.\nA. Gulf South must revise its procedures to ensure that it adequately describes what\nconstitutes sufficient information in order to determine discovery of a condition.\nGulf South's procedure Chapter 10 Anomalous Conditions, does not adequately\ndescribe what constitutes sufficient information to determine discovery. The IMP\nstates in Section 7.2that discovery occurs when sufficient information exists, but\nthere is no detail on what constitutes sufficient information or who is involved in\nthe discovery process.\nB. Gulf South must revise its procedures to provide clear direction on handling both\nimmediate and monitored conditions to ensure correction. The Gulf South IMP\n\n\n\ndoes not have adequate direction on how and when pressure reductions are\ndetermined and implemented. When an immediate repair condition is\ndiscovered, a pressure reduction is expected to be implemented in a timely\nmanner. The IMP does.not clearly define how and when the operator is to take\npressure reductions. The ooerator needs to ensure Dressure is reduced before\nperforming excavations.\nC. Gulf South must develop comprehensive procedures to document the process\nused for monitoring anomalies identified as \"monitored conditions.\" Specific\ninformation must be generated defending expected growth rates, periodicity of\nmonitoring activities, and defining responsible personnel.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. g 60108(a) and 49 C.F.R. S 190.237. 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. lf 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\nconfidentiat treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b). lf 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 atleged in\nthis Notice without further notice to you and lo issue a Final Order.\nlf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. S 190.237). lf you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nln your correspondence on this matter, please refer to GPF 4-2007-'|001M and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerelv.\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":11331}