{"operation":"document","citation":"CPF 420125002M","title":"ROSE ROCK MIDSTREAM OPERATING, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-02-24","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(b)(1), 195.452(e), 195.452(f), 195.452(f)(1), 195.452(f)(3), 195.452(i)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420125002M","body":"Notice of Amendment involving ROSE ROCK MIDSTREAM OPERATING, LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(b)(1),  195.452(e),  195.452(f),  195.452(f)(1),  195.452(f)(3),  195.452(i)(3). The case was opened on 2012-02-24 and is reported as closed as of 2015-12-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420125002M_Closure Letter_12082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125002M/420125002M_Closure%20Letter_12082015.pdf\n\n420125002M_Closure Letter_12082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125002M/420125002M_Closure%20Letter_12082015_text.pdf\n\n420125002M_Notice of Amendment_02242012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125002M/420125002M_Notice%20of%20Amendment_02242012.pdf\n\n420125002M_Notice of Amendment_02242012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125002M/420125002M_Notice%20of%20Amendment_02242012_text.pdf\n\n420125002M_Operator Response to NOA_03292012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125002M/420125002M_Operator%20Response%20to%20NOA_03292012.pdf\n\n420125002M_Notice of Amendment_02242012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 24, 2012\nMr. Pete Schwiering\nPresident of SemCrude\nSemGroup\n6120 S. Yale Ave.,\nSuite 650\nTulsa, OK 74136\nCPF 4-2012-5002M\nDear Mr Schwiering:\nOn November 14-19, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nSemGroup procedures for Integrity Management in Oklahoma City, OK.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSemGroup’s plans or procedures, as described below:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area;\nThe team reviewed the process used to calculate the volume spilled at points along the pipeline.\n\n\n\nThe spill volume calculation considered drain down from the pipeline and assumed that the\nclosest valves to the point of the spill are closed within 2 hrs. The spill volume results were then\nforwarded to Applied Science Associates (ASA) for the overland and water transport analyses.\nThe volume spilled analysis did not appear to consider the time the pipeline continues to run\nuntil a pipeline failure is recognized by the controller, the line is shutdown, and the time to close\nany remotely operated valves (ROVs).\nTanks and connections to other sources (i.e. other pipelines, etc) need to be considered in the\nspill volume calculations. This is especially relevant where SemGroup’s pipelines are isolated\nfrom these additional sources by manually operated valves and no check valves or ROV’s exist\nto prevent product from tankage contributing to spill volume on SemGroup’s pipelines.\nSemGroup performed segment identification considering a pipeline rupture scenario. SemGroup\nindicated that they are reviewing the effect of small leaks (leaks below the capability of the\nSCADA system or line balance calculations to be readily detected) to compare with the results of\nthe rupture scenario. The inspection team encourages SemGroup continue with this small leak\nanalysis and make appropriate changes to segment identification as necessary. Results of the\nsmall leak analysis should be documented and maintained.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\n(5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n(ii) Pressure test conducted in accordance with subpart E of this part;\nSemGroup does not state in its IMP that SemGroup will assess the effectiveness of its\ncorrosion control program for segments hydrostatically assessed. From the Liquid IM\nFAQ’s: (6.5 What type of pressure test can be used to assess pipeline integrity?)\nstates that “The rule requires that pressure tests be conducted according to the\nrequirements of 49 CFR Part 195, Subpart E. Operators choosing to assess by pressure\ntest should also assure their corrosion control program is effective. PHMSA Pipeline\nSafety inspectors will pay particular attention to the adequacy of corrosion control\nprograms for pipelines for which pressure testing is used.”\n2\n\n\n\n3. §195.452 Pipeline integrity management in high consequence areas.\n(e) What are the risk factors for establishing an assessment schedule (for both the\nbaseline and continual integrity assessments)?\n(1) An operator must establish an integrity assessment schedule that prioritizes\npipeline segments for assessment (see paragraphs (d)(1) and (j)(3) of this section).\nAn operator must base the assessment schedule on all risk factors that reflect the\nrisk conditions on the pipeline segment. The factors an operator must consider\ninclude, but are not limited to:\n(i) Results of the previous integrity assessment, defect type and size that the\nassessment method can detect, and defect growth rate;\n(ii) Pipe size, material, manufacturing information, coating type and condition, and\nseam type;\n(iii) Leak history, repair history and cathodic protection history;\n(iv) Product transported;\n(v) Operating stress level;\n(vi) Existing or projected activities in the area;\n(vii) Local environmental factors that could affect the pipeline (e.g., corrosivity of\nsoil, subsidence, climatic);\n(viii) Geo-technical hazards; and(ix) Physical support of the segment such as by a\ncable suspension bridge.\n(2) Appendix C of this part provides further guidance on risk factors.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\n(g) What is an information analysis? In periodically evaluating the integrity of each\npipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the consequences\nof a failure. This information includes:\n(1) Information critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities, and\ndevelopment or planned development along the pipeline segment;\n(2) Data gathered through the integrity assessment required under this section;\n3\n\n\n\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and cathodic\nprotection surveys; and\n(4) Information about how a failure would affect the high consequence area, such as\nlocation of the water intake.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline release\noccurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited to:\n(i) Terrain surrounding the pipeline segment, including drainage systems such as\nsmall streams and other smaller waterways that could act as a conduit to the high\nconsequence area;\n(ii) Elevation profile;\n(iii) Characteristics of the product transported;\n(iv) Amount of product that could be released;\n(v) Possibility of a spillage in a farm field following the drain tile into a waterway;\n(vi) Ditches along side a roadway the pipeline crosses;\n(vii) Physical support of the pipeline segment such as by a cable suspension bridge;\n(viii) Exposure of the pipeline to operating pressure exceeding established maximum\noperating pressure.\nSemgroup uses a risk ranking analysis that does not clearly differentiate the relative risks of\ndifferent pipeline segments. The risk results reviewed by the team indicated that adjacent\npipeline segments that have different types and quantities of HCA’s have the same relative risk\nscore. A segment that affects multiple HCA’s directly could present a higher risk than a segment\nthat affects only one HCA indirectly. The thirteen HCA attribute columns on the SemGroup risk\nranking spreadsheet are effectively reduced to a single yes or no and provide very little\ndifferentiating information to risk ranking, such as physical direct pathways. A segment that has\none of the thirteen columns indicated would have the same risk as one that had all thirteen\ncolumns indicated per the SemGroup risk ranking spreadsheet.\n4. §195.452 Pipeline integrity management in high consequence areas.\n(f) (3) See Above\n(g) See Above.\n4\n\n\n\nThe Semgroup approach to analysis of risk for facilities that affect HCA’s does not appear to be\ncomprehensive or clearly documented.\n5. §195.452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the high\nconsequence area?\n(3) Leak detection. An operator must have a means to detect leaks on its pipeline\nsystem. An operator must evaluate the capability of its leak detection means and\nmodify, as necessary, to protect the high consequence area. An operator’s\nevaluation must, at least, consider the following factors-length and size of the\npipeline, type of product carried, the pipeline’s proximity to high consequence area,\nthe swiftness of leak detection, location of nearest response personnel, leak history,\nand risk assessment results.\nSemgroup does not have a clearly documented Leak Detection Capability Evaluation process.\nSemGroup needs to formalize procedures for operator response to leak detection system\nindications. SemGroup needs to provide a direct link from its IMP to leak detection system and\ncontrol room procedures that address IM requirements.\n6. §195.452 Pipeline integrity management in high consequence areas.\n(b) What program and practices must operators use to manage pipeline integrity?\nEach operator of a pipeline covered by this section must:\n(1) Develop a written integrity management program that addresses the risks on\neach segment of pipeline in the first column of the following table not later than the\ndate in the second column:\nPipeline Date\nCategory 1 March 31, 2002\nCategory 2 February 18, 2003.\nCategory 3 1 year after the date the pipeline begins operation.\n(4) Include in the program a framework that--\n(i) Addresses each element of the integrity management program under paragraph\n(f) of this section, including continual integrity assessment and evaluation under\nparagraph (j) of this section; and\n(ii) Initially indicates how decisions will be made to implement each\nelement.§195.452 (c)(2) An operator must document, prior to implementing any\nchanges to the plan, any modification to the plan, and reasons for the modification.\n(l) What records must be kept?\n5\n\n\n\n(1) An operator must maintain for review during an inspection: A written integrity\nmanagement program in accordance with paragraph (b) of this section.\n(ii) Documents to support the decisions and analyses, including any modifications,\njustifications, variances, deviations, and determinations made, and actions taken, to\nimplement and evaluate each element of the integrity management program listed in\nparagraph (f) of this section.\nSemgroup does not have a statement in its IMP that documentation is obtained from a previous\npipeline owner/operator when acquisitions are made. Obtaining records from previous pipeline\noperators will enable SemGroup to operate pipelines acquired from previous operators more\nsafely.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart 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. § 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 correspondence concerning this matter, please refer to CPF 4-2012-5002M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n6\n\n420125002M_Closure Letter_12082015_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 8, 2015\nMr. Norm Szydlowski\nPresident\nRose Rock Midstream L.P.\n3030 NW Expressway, Suite 1100\nOklahoma City, Ok 73112\nCPF 4-2012-5002M\nDear Mr. Szydlowski:\nOn November 14-19, 2010, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of Rose Rock Midstream L.P. (Rose Rock, formerly SemCrude)\nprocedures for Integrity Management in Oklahoma City, OK. As a result of the inspection, Rose\nRock was issued a Notice of Amendment on February 24, 2012, which proposed amendment of\nyour procedures.\nDuring January through May 2015, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted\nan on-site pipeline safety inspection of Rose Rock procedures for Integrity Management in\nOklahoma City, OK, during which the amended procedures were reviewed, and it appears that the\ninadequacies outlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":17011}