{"operation":"document","citation":"CPF 420071006W","title":"UCAR PIPELINE INCORPORATED — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-08-01","effective_on":null,"summary":"CLOSED warning letter citing 192.605(b)(5), 192.707(a)(2), 192.743.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420071006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420071006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420071006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420071006W","body":"Warning Letter involving UCAR PIPELINE INCORPORATED. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(5),  192.707(a)(2),  192.743. The case was opened on 2007-08-01 and is reported as closed as of 2007-08-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420071006W_warningletter_08012007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071006W/420071006W_warningletter_08012007.pdf\n\n420071006w_warningletter_08012007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071006W/420071006w_warningletter_08012007_text.pdf\n\n420071006w_warningletter_08012007_text.pdf\n\nU. S. Department\naf Transportation\nfslpetlne and\nHmarstous Hlaierlafs Safety\nAdmlnfstrsstion\n8701 South Gessher, Suits ttttt\nHouston, TX 77D74\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 1, 2007\nMr. Kevin C. Weyer, President\nUCAR Pipeline, Incorporated\n1000 County Road 340\nAngleton, TX 77515-7515\nCPF 4-2007-1006W\nDear Mr. Weyer:\nOn March 20-22, September 11-15, and October 10, 2006, a representative of the Pipeline and\nHazardous Matenals Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your UCAR Pipeline System.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are\nII192. 707 Line markers for mains and transmission lines.\n(a) Buried pipe(ines. Except as prowded in paragraph (b) of this section, a line marker\nmust be placed and maintained as close as practical over each buried main and\ntransmission line'\n(2) Wherever necessary to identify the location of the transmission line or main to reduce\nthe possibility of damage or interference.\nUCAR has does not have an adequate number of pipeline markers along the nght-of-way to\nclearly identify the location of the transmission line\nAt vanous locations along the pipeline right-of-way between Lake Charles, LA and Texas City,\nTX, the location of the pipeline cannot easily be determined from the UCAR pipeline markers.\nIn many cases adkacent markers cannot be seen when standing at a given pipeline marker\nmaking it difficult to determine the pipeline route. UCAR needs to install additional pipeline\nmarkers so that the location of the transmission line is clearly identified.\n\n\n\n192. 605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwntten procedures for conducting operations and maintenance actiwties and for\nemergency response. For transmission hnes, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted\n(b) Maintenance and normal operahons. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety during\nmaintenance and operations.\n(5) Starting up and shutting down any part of the pipeline in a manner des'igned to\nassure operation within the IVIAGP limits prescribed by this part, plus the build-up\nallowed for operation of pressure-limiting and control devices.\nThe UCAR procedures for startup/shutdown of pipeline facilities are not adequate T' he UCAR\nprocedures for startup/shutdown of the pipeline system deal mainly with hazardous air/fuel\nmixtures and purging. UCAR operations personnel have stated that the pipeline is fully\nautomated and that field operations personnel have no need for startup/shutdown procedures.\nHowever, the regulations require at least a basic description of the procedures used to start and\nstop pipeline operations including basic fieid equipment checks, ensuring protection of the\nMAOP, and responding to abnormal operating conditions that may occur during the process.\n192. 748 Pressure limiting and regulating stations: Capacity of relief devices.\n(a) Pressure relief devices at pressure hmiting stations and pressure regulating stations\nmust have sufficient capacity to protect the facilities to which they are connected.\nExcept as provided in )192. 739(b), the capacity must be consistent with the pressure\nlimits of 5192. 201(a). This capacity must be determined at intervals not exceeding 15\nmonths, but at least once each calendar year, by testing the devices in place or by\nreview and calculations.\n(b) If review and calculations are used to determine if a device has sufficient capacity,\nthe calculated capacity must be compared with the rated or experimentally determined\nrelieving capacity of the device for the conditions under which it operates. After the\ninitial calculations, subsequent calculations need not be made if the annual review\ndocuments that parameters have not changed to cause the rated or experimentally\ndetermined relieving capacity to be insufhcient.\nUCAR did not produce annual documentation indicating that the parameters under which the\nrelief valve capacity was sized have not changed thereby eliminating the need for additional\ncalcul'ations\nThe original relief valve calculations as well as some subsequent determinations that the\noperational parameters under which the relief valves were sized were present in the UCAR\nrecords However, documentation for the annual determination over the past five years that the\n2\n\n\n\noperational conditions used to onginally size the relief valves has not changed, was not found in\nthe UCAR files. UCAR needs to ensure that this annual check is performed and documented.\nUnder 49 United States Code, g 60 122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violations per ists up to a maximum of $1, 000, 000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments irwolved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Be advised that failure to do so will result in UCAR Pipeline, Inc. being subject to\nadditional enforcement action.\nhlo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2007-1006W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\nR. M Seeley\nOirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration","truncated":false,"body_characters":7209}