HOLLY ENERGY PARTNERS - OPERATING, L.P. — Notice of Amendment

party submissionOfficial PDF420075013M_Operator Response to notice letter_05072007.pdf#

420075013M_notice letter_04232007.pdf, page 1Official PDFU.S. Department of Transportation Pipellne and Hazardous Materials Safety Administration 8701 South Gessner, Suite 11 10 Houston, TX 77074 NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 23, 2007 Mr. Jim Townsend Holly Energy Vice President, Operations PO Box 1260 1 31 1 W. Quay Avenue Artesia, New Mexico 88210 CPF NO. 4-2007-5013M Dear Mr. Townsend: On February 26 - March 2, 2007, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code inspected your procedures for operations and maintenance in Artesia, New Mexico. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Holly Energy's procedures and are descried below: 1. 9195.402 Procedural manual for operations, maintenance, and emergencies (a)General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. .r#

420075013M_notice letter_04232007.pdf, page 2§195.402(f) Safety related condition reports. Holly Energy procedures did not clearly state that employees are trained on an ongoing basis to recognize safety related conditions. Holly Energy needs to amend their procedures to clarify that employees are trained on an ongoing basis to recognize safety related conditions. 2. 5195.577 What must I do to alleviate interference currents? (a) For pipelines exposed to stray currents, you must have a program to identify, test for, and minimize the detrimental effects of such currents. Holly Energy procedures do not have a prograrrr to identify, test for, and minimize the detrimental effects of interference currents. Holly Energy needs to amend their procedures to address the identification, testing for, and minimizing the detrimental effects of interference currents. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 601 08(a) and 49 C.F.R. § 190.237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within [number of days] days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. In correspondence concerning this matter, please refer to CPF No 4-2007-5013M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, & 7 4 ; ' R.M. Seeley Director, Southwest Region Pipeline and Hazardous Material Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance#