{"operation":"document","citation":"CPF 420075014M","title":"TRINITY PIPELINE GP LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-05-02","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075014m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075014m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075014m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420075014M","body":"Notice of Amendment involving TRINITY PIPELINE GP LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3). The case was opened on 2007-05-02 and is reported as closed as of 2007-11-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420075014M_notice letter_05022007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075014M/420075014M_notice%20letter_05022007.pdf\n\n420075014M_notice letter_05022007.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n8701 South Gessner, Suite 11 10\nHouston, TX 77074\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 2,2007\nMr. Barry F. Petty, Managing Partner\nTrinity C02 LLC\n401 West Wall Street\nMidland, TX 79701\nCPF 4-2007-5014M\nDear Mr. Petty:\nOn July 17-20, 2006, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nprocedures for operations and maintenance in Hobbs, New Mexico.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTrinity C02, LLC (Trinity), as described below:\n1. 5195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nA. 5195.402 Procedural manual for operations, maintenance, and emergencies.\n\n\n\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety\nduring maintenance and normal operations:\n(10) Abandoning pipeline facilities, including safe disconnection from an\noperating pipeline system, purging of combustibles, and sealing abandoned\nfacilities left in place to minimize safety and environmental hazards. For each\nabandoned offshore pipeline facility or each abandoned onshore pipeline\nfacility that crosses over, under or through commercially navigable waterways\nthe last operator of that facility must file a report upon abandonment of that\nfacility in accordance with 9195.59\nof this part.\nTrinity's procedures need to specify more detail in the process for abandonment of pipelines.\nB. 9195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations,\nno operator may operate a pipeline at a pressure that exceeds any of the\nfollowing:\n(1) The internal design pressure of the pipe determined in accordance with\n9195.106. However, for steel pipe in pipelines being converted under 9195.5, if\none or more factors of the design formula (9195.106) are unknown, one of the\nfollowing pressures is to be used as design pressure:\n(i) Eighty percent of the first test pressure that produces yield under section\nN5.0 of Appendix N of ASME B31.8, reduced by the appropriate factors in\n99195.106(a) and (e); or\n(ii) If the pipe is 323.8 mm (12% in) or less outside diameter and is not tested\nto yield under this paragraph, 1379 kPa (200 psig).\n(2) The design pressure of any other component of the pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has\nbeen pressure tested under Subpart E of this part.\n(4) Eighty percent of the factory test pressure or of the prototype test pressure\nfor any individually installed component which is excepted from testing under\n9195.305.\n(5) For pipelines under 99195.302(b)(l) and (b)(2)(i), that have not been\npressure tested under Subpart E of this part, 80 percent of the test pressure or\nhighest operating pressure to which the pipeline was subjected for 4 or more\ncontinuous hours that can be demonstrated by recording charts or logs made\nat the time the test or operations were conducted.\nTrinity needs to specify procedures for establishing Maximum Operating Pressure.\nC. 9195.406 Maximum operating pressure.\n(b) No operator may permit the pressure in a pipeline during surges or other\nvariations from normal operations to exceed 110 percent of the operating\npressure limit established under paragraph (a) of this section. Each operator\n\n\n\nmust provide adequate controls and protective equipment to control the\npressure within this limit.\nTrinity's procedures need to specify that during surges or other variations from normal\noperations the pressure in the pipeline is not permitted to exceed 110 percent of the operating\npressure limit established under paragraph (a) of this section and that adequate controls and\nprotective equipment to control the pressure within this limit must be provided.\nD. 5195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is exposed,\nyou must examine the exposed portion for evidence of external corrosion if the\npipe is bare, or if the coating is deteriorated. If you find external corrosion\nrequiring corrective action under Sec. 195.585, you must investigate\ncircumferentially and longitudinally beyond the exposed portion (by visual\nexamination, indirect method, or both) to determine whether additional\ncorrosion requiring remedial action exists in the vicinity of the exposed portion.\nTrinity's procedures need to specify that if you find external corrosion during examination of\nexposed pipe you must investigate circumferentially and longitudinally beyond the exposed\nportion to determine whether additional corrosion requiring remedial action exists in the vicinity\nof the exposed portion.\nE. 5195.579 What must I do to mitigate internal corrosion?\n(a) General. If you transport any hazardous liquid or carbon dioxide that would\ncorrode the pipeline, you must investigate the corrosive effect of the hazardous\nliquid or carbon dioxide on the pipeline and take adequate steps to mitigate\ninternal corrosion.\n(b) Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion, you\nmust--\n(1) Use inhibitors in sufficient quantity to protect the entire part of the pipeline\nsystem that the inhibitors are designed to protect;\n(2) Use coupons or other monitoring equipment to determine the effectiveness\nof the inhibitors in mitigating internal corrosion; and\n(3) Examine the coupons or other monitoring equipment at least twice each\ncalendar year, but with intervals not exceeding 7 112 months.\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must\ninspect the internal surface of the pipe for evidence of corrosion. If you find\ninternal corrosion requiring corrective action under Sec. 195.585, you must\ninvestigate circumferentially and longitudinally beyond the removed pipe (by\nvisual examination, indirect method, or both) to determine whether additional\ncorrosion requiring remedial action exists in the vicinity of the removed pipe.\nTrinity needs to specify procedures for mitigating internal corrosion.\nF. 5195.589 What corrosion control information do I have to maintain?\n\n\n\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You\nmust retain these records for at least 5 years, except that records related to\n195.569,195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as\nlong as the pipeline remains in service.\nTrinity's procedures need to specify that records for pipe-to-soil potentials and internal corrosion\ncoupons will be retained for as long as the pipeline remains in service.\n2. s195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nA. s195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104\n(ibr, see 195.3 or section IX of the ASME Boiler and Pressure Vessel Code, (ibr,\nsee § 195.3) except that a welder qualified under an earlier edition than listed in §\n195.3 may weld but may not re-qualify under that earlier edition.\nTrinity's procedures need to reference the correct section pertaining to the latest incorporated\nby reference edition of API 11 04. The correct section for welder qualification is section 6 of API\n1 104 1 91h ~dition.\nB. s195.222 Welders: Qualification of welders.\n(b) No welder may weld with a welding process unless, within the preceding 6\ncalendar months, the welder has-\n(1) Engaged in welding with that process; and\n(2) Had one welded tested and found acceptable under section 9 of API 1104\nTrinity's procedures need to specify that welders may not weld with a particular welding process\nunless, within the preceding 6 calendar months, the welder has (1) Engaged in welding with\nthat process; and (2) Had one weld tested and found acceptable under Section 9 of API 1104.\nC. s195.226 Welding: Arc burns.\n(b) An arc burn may be repaired by completely removing the notch by\ngrinding, if the grinding does not reduce the remaining wall thickness to less\nthan the minimum thickness required by the tolerances in the specification to\nwhich the pipe is manufactured. If a notch is not repairable by grinding, a\ncylinder of the pipe containing the entire notch must be removed.\n\n\n\nTrinity's procedures need to specify that arc burn repairs require verification of removal of the\nmetallurgical notch by nondestructive testing.\nD. 9195.266 Construction records.\nA complete record that shows the following must be maintained by the operator\ninvolved for the life of each pipeline facility:\n(a) The total number of girth welds and the number nondestructively tested,\nincluding the number rejected and the disposition of each rejected weld.\nTrinity's procedures need to specify that records of the total number of girth welds and the\nnumber nondestructively tested, including the number rejected and the disposition of each weld\nmust be maintained for the life of the facility.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. 5 60108(a) and 49 C.F.R. 5 190.237. 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. 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). If 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 alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIf, 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. 5 190.237). If 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.\nIn your correspondence on this matter, please refer to CPF 4-2007-5014M and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nDirector, southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":12768}