{"operation":"document","citation":"CPF 420145027H","title":"BOARDWALK PETROCHEMICAL PIPELINE, LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-10-20","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145027h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145027h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145027h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420145027H","body":"Corrective Action Order involving BOARDWALK PETROCHEMICAL PIPELINE, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2014-10-20 and is reported as closed as of 2016-01-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420145027H_Closure Letter_01052016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145027H/420145027H_Closure%20Letter_01052016.pdf\n\n420145027H_Closure Letter_01052016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145027H/420145027H_Closure%20Letter_01052016_text.pdf\n\n420145027H_Corrective Action Order_10202014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145027H/420145027H_Corrective%20Action%20Order_10202014.pdf\n\n420145027H_Corrective Action Order_10202014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145027H/420145027H_Corrective%20Action%20Order_10202014_text.pdf\n\n420145027H_Corrective Action Order_10202014_text.pdf\n\nOCTOBER 20, 2014\nVIA CERTIFIED MAIL AND FAX TO: (713) 479-1711\nMr. Albert Williams\nPresident\nChevron Petrochemical Pipeline LLC\n4800 Fournace Place\nBellaire, TX 77401\nMr. Stanley Horton\nCEO, President and Director\nBoardwalk Pipeline Partners, LP\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nRe: CPF No.: 4-2014-5027H\nDear Mr. Williams:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires Chevron\nPetrochemical Pipeline LLC to take certain corrective actions with respect to the Evangeline\nEthylene Pipeline that failed on October 10, 2014 in Cameron Parish, Louisiana. Service is\nbeing made by certified mail and facsimile. Service of the Corrective Action Order by electronic\ntransmission is deemed complete upon transmission and acknowledgement of receipt, or as\notherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are\neffective upon completion of service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Rodrick Seeley, Regional Director, PHMSA, Southwest Region\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nChevron Petrochemical Pipeline LLC, ) CPF No.: 4-2014-5027H\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C. § 60112,\nto require Chevron Petrochemical Pipeline LLC (Chevron or Respondent), to take the necessary\ncorrective action to protect the public, property, and the environment from potential hazards\nassociated with the recent failure on Chevron’s Evangeline Ethylene Pipeline (Evangeline\nPipeline)1 near Cameron, Louisiana.\nOn October 10, 2014, an accident occurred on the Evangeline Pipeline, resulting in a minor\nrelease of Ethylene (the Failure). The Evangeline Pipeline is a 16-inch diameter pipeline\napproximately 176 miles in length that transports ethylene from the Port Neches meter station in\nJefferson County, TX, to the Exxon Mobile Anchorage Tank Farm in West Baton Rouge Parish,\nLA. The cause of the Failure is unknown but an investigation is ongoing. Pursuant to 49 U.S.C.\n§ 60117, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of\nPipeline Safety (OPS), initiated an investigation of the accident. The preliminary findings of the\nongoing investigation are as follows.\n1 The Evangeline System was purchased by Boardwalk Pipeline Partners, LP (Boardwalk) on October 8, 2014, but\nby prior agreement Chevron remains the operator of record until November 1, 2014. Boardwalk is a midstream\nmaster limited partnership that provides transportation, storage, gathering and processing of natural gas and liquids.\nThrough subsidiaries, Boardwalk owns and operate approximately 14,195 miles of interconnected natural gas\npipelines, with customers in thirteen states.\n\n\n\nPreliminary Findings:\n• Chevron, an indirect wholly-owned subsidiary of Chevron Corporation, operates\napproximately 10,000 miles of pipeline transporting crude oil, refined petroleum\nproducts, liquefied petroleum gas, natural gas and chemicals within the United States.2\n• The failed pipeline is a 16-inch diameter line that transports ethylene from the Port\nNeches meter station in Jefferson County, TX, to the Exxon Mobile Anchorage Tank\nFarm in West Baton Rouge Parish, LA, a distance of approximately 176 miles. The\nFailure occurred near milepost identifier MP 16.65 near Cameron, Louisiana (Failure\nSite).\n• The pipe was manufactured in 1953. The Evangeline Pipeline was constructed in 1954 as\na crude products line, and converted to natural gas service in 1966. The pipeline was\nthen converted back to a liquids line in 2001. The Failure site consists of 16-inch\ndiameter, 0.312/0.314 wall thickness, Grade X 52 LF-ERW seam pipe.\n• The maximum operating pressure (MOP) of the pipeline is 1336 psig, as established by\nhydrostatic test in 2001. At the time of the Failure, the actual operating pressure of the\npipeline was 1191 psig.\n• At approximately 12:30 pm CST on October 10, 2014 Chevron experienced a minor leak\non their Evangeline Pipeline system located in Cameron Parish, Louisiana. The leak on\nthe ethylene line is the most recent pinhole leak identified on the system in the last 4\nyears. The release occurred adjacent to an intra-coastal waterway, in a marshy area. The\nrelease was identified when bubbles were observed in the marsh. There were no reported\ninjuries, fatalities, or evacuations and there was no ignition.\n• There were no reported road closures. The line crosses major waterways including the\nCalcasieu River. The 29 mile section of line has to be flared to remove the product.\n• As a result of the leak, Chevron took action to shut the Evangeline Pipeline in and began\nevacuating the line to identify the leak site. It is anticipated the line will be isolated and\nrepairs initiated by Monday October 20, 2014.\n• The probable cause of the failure is unknown but the investigation is ongoing. However,\nthere is pertinent history:\no LF-ERW pipe manufactured prior to 1962 was made by direct current (d.c) or low\nfrequency alternating current (a.c) using low carbon steels. The inclusion of dirt,\ngrease, scale, or other oxide films during the welding of the “skelp” (steel plates\nused to form the pipe) often prevented adequate heating at the bonding interfaces.\nThese areas of non-bonding are called “cold welds”. “A significant number of\ncold welds in close proximity could reduce the strength of the bondline, and a\nrupture would occur when the pipe is subjected to pressurization”.\n2 See http://chevronpipeline.com/about/ (last accessed on October 16, 2014).\n\n\n\no On April 6, 2011 and November 8, 2011, two incidents occurred on the\nEvangeline Pipeline. Both incidents were determined to be caused by a “cold\nweld” in the longitudinal LF ERW pipe seam. In both cases, metallurgical\nanalysis concluded that the cold welds were original manufacturing defects in the\npipe seam.\no In the summer of 2013, an additional 10 pinhole leaks in the weld were identified\nduring maintenance on the line. (NRC #’s 1054340, 1058513, 1058754, 1058760,\n1058762, 1058766, 1058771, 1058774, 1058777, 1058779 - There were no\nreported injuries, fatalities, or evacuations and there was no ignition).\no In September 2013, PHMSA issued a NOPV and CO to Chevron in CPF 4-2013-\n5019. The CO required Chevron to perform an integrity assessment of their\npipeline by a method prescribed in Appendix G of their Pipeline Integrity\nManagement Program Manual.. Chevron completed hydrostatic testing of the line\nprior to the end of 2013. A spike test was performed to 1.39 MOP; however, the\ntesting was limited to 80% SMYS. As a result of the hydrostatic test, 41 repairs\nwere made. In addition, there were two failures during the hydrostatic testing.\nOne of the ruptures occurred during the spike test.\n• In June 2012, the Evangeline Pipeline was assessed using the geometry and MFL tool.\nThere was no hydro-test performed in 2012. From September – December 2013, the\nEvangeline Pipeline was hydrostatically tested to 1670 psig, and then 1858 psig for a 30\nminute spike test.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, having considered the nature of the Failure, the location of the\nFailure, the proximity of the Affected Segment to populated areas, marshlands, an intra-coastal\nwaterway, and other sensitive areas, the history of known problems with this pipeline, and the\nnature of the product being transported, I find that a failure to issue this Order expeditiously to\n\n\n\nrequire immediate corrective action would result in the likelihood of serious harm to life,\nproperty, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,\nPHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person\nin the Southwest Regional office or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order Chevron to immediately take the following\ncorrective actions:\nDefinitions\nThe “Affected Segment” means the 29 miles of the Evangeline Ethylene system from Mile Post 0\nto Mile Post 29.\nThe \"Director\" means Rod Seeley, Director, Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Southwest Region. The Director’s address\nis 8701 S. Gessner, Suite 1110, Houston, Texas 77074.\nCorrective Actions\n1. Operating Restriction. Chevron must not operate the Affected Segment until authorized to\ndo so by the Director.\n2. Operating Pressure Restriction. Respondent must reduce and maintain a twenty\npercent (20%) pressure reduction in the actual operating pressure along the entire\nlength of the Evangeline Pipeline System such that the operating pressure on this\nsegment will not exceed eighty percent (80%) of the actual operating pressure in effect\nimmediately prior to the failure on October 10,2014.\n\n\n\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is\nobtained from the Director.\nb. This pressure restriction requires that any relevant remote or local alarm limits,\nsoftware programming set-points or control points, and mechanical over­ pressure\ndevices be adjusted accordingly.\n3. Restart Plan. Prior to resuming operation of the Affected Segment, develop and submit a\nwritten Restart Plan to the Director for approval.\na. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Affected Segment cannot resume operation until the Restart\nPlan is approved in its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by\nreference into this Order.\nc. The Restart Plan must provide for adequate patrolling of the Affected Segment\nduring the restart process and must include incremental pressure increases during\nstart-up, with each increment to be held for at least one hour.\nd. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\ne. The Restart Plan must provide for a review of the Affected Segment for conditions\nsimilar to those of the failure, including a review of construction, operating and\nmaintenance (O&M) and integrity management records. These would include such\nrecords as in-line inspection (ILl) results, hydrostatic tests, root-cause failure\nanalysis of prior failures, aerial and ground patrols, corrosion, cathodic protection,\nexcavations and pipe replacements. Respondent must address any findings that\nrequire remedial measures to be implemented prior to restart.\nf. The Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all\nprocedural modifications are incorporated into Chevron’s/Boardwalk’s operations\nand maintenance procedures manual.\n4. Return to Service. After the Director approves the Restart Plan, Respondent may return\nthe Affected Segment to service, but the operating pressure must not exceed eighty percent\n(80%) of the actual operating pressure in effect immediately prior to the failure on October\n10, 2014, in accordance with Item 2 above.\n5. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction upon\na written request from Respondent demonstrating that restoring the pipeline to\nits pre-failure operating pressure is justified, based on a reliable engineering analysis\nshowing that the pressure increase is safe considering all known defects, anomalies,\nand operating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Respondent demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\n\n\n\n6. 7. determination will be based on the failure cause and provision of evidence that\npreventative and mitigative actions taken by the operator provide for the safe\noperation of the Affected Segment during the temporary removal or modification\nof the pressure restriction. Appeals to determinations of the Director in this regard\nwill be decided by the Associate Administrator for Pipeline Safety.\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order,\ncomplete mechanical and metallurgical testing and failure analysis of the failed pipe,\nincluding an analysis of soil samples and any foreign materials. The company must\ncomplete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site;\nb. Within 10 days of receipt of this Order, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval;\nc. Prior to beginning the mechanical and metallurgical testing, provide the\nDirector with the scheduled date, time, and location of the testing to allow for an\nOPS representative to witness the testing; and\nd. Ensure the testing laboratory distributes all reports, whether draft or final, in their\nentirety to the Director at the same time they are made available to Respondent.\nIntegrity Verification and Remediation Plan (IVRP).\na. Within 90 days following receipt of this Order, Chevron must submit an Integrity\nVerification and Remediation Plan (IVRP) to the Director for approval for the entire\n176 mile length of the Evangeline pipeline from MP 0 to MP 197.\nb. The Director may approve the IVRP incrementally without approving the entire\nIVRP.\nc. Once approved by the Director, the IVRP will be incorporated by reference into this\nOrder.\nd. The IVRP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures Chevron will use to verify the integrity of the Evangeline Pipeline.\nChevron should consider both the risk of another failure and the consequence of\nanother failure to develop a prioritized schedule for IVRP related work along the\nEvangeline System.\ne. The IVRP must include a procedure or process to:\ni. Conduct additional field tests, inspections, assessments, and/or evaluations to\ndetermine the integrity of the Evangeline System. At a minimum, this process\nmust specify the use of one or more of the following:\n1. Inline inspection (ILI) tools that are technically appropriate for\nassessing the pipeline system based on the cause of failure on October\n10, 2014, (including prior seam leaks/failures) and that can reliably\ndetect and identify these anomalies; and\n2. Hydrostatic pressure testing at a level that will produce 90% SMYS.\nf. Implement continuing long-term periodic testing and integrity verification measures\nto ensure the ongoing safe operation of the Evangeline System considering the\n\n\n\ng. results of the analyses, inspections, evaluations, and corrective measures undertaken\npursuant to the Order.\nInclude a proposed schedule for completion of the IVRP.\nNote: Respondent may use the results of previous tests, inspections, assessments, and\nevaluations, if approved by the Director, provided the results of the tests, inspections,\nassessments, and evaluations are analyzed with regard to the factors known or suspected to have\ncaused the October 10, 2014 failure.\n8. Record Keeping. Respondent must maintain records demonstrating its progress in\ncompleting all requirements of this Order, make them available to the Director, and retain\nthem for a period of at least five years following completion of all work to be performed.\nWhen Respondent believes it has concluded all the items in this Order, it will submit a\nproposed completion report to the Director.\nOther Requirements\n1. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure, including\nrepairs, replacements and other modifications; and (3) environmental remediation, if\napplicable.\n2. Approvals. With respect to each submission requiring the approval of the Director, the\nDirector may: (a) approve the submission in whole or in part; (b) approve the submission on\nspecified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove the\nsubmission in whole or in part and direct Respondent to modify the submission; or (e) any\ncombination of the above. In the event of approval, approval upon conditions, or\nmodification by the Director, Respondent shall proceed to take all action required by the\nsubmission, as approved or modified by the Director. If the Director disapproves all or any\nportion of a submission, Respondent must correct all deficiencies within the time specified\nby the Director and resubmit it for approval.\n3. Extensions of Time. The Director may grant an extension of time for compliance with any of\nthe terms of this Order upon a written request timely submitted and demonstrating good\ncause for an extension.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any\nother order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or under any\nother provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\n\n\n\nBe advised 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).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No.: 4-2014-5027H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n_________________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420145027H_Closure Letter_01052016_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 5, 2016\nMr. Stanley Horton\nCEO, President and Director\nBoardwalk Pipeline Partners, LP\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nRe: CPF 4-2014-5027H Request for Closure\nDear Mr. Horton:\nOn October 10, 2014, an accident occurred on the Evangeline Pipeline, resulting in a minor\nrelease of Ethylene. The Evangeline Pipeline is a 16-inch diameter pipeline approximately 176\nmiles in length that transports ethylene from the Port Neches meter station in Jefferson County,\nTX, to the Exxon Mobil Anchorage Tank Farm in West Baton Rouge Parish, LA. At the time of\nthe failure, the pipeline was operated by Chevron Petrochemical Pipeline LLC (Chevron)\npending a transition to the new owner/operator Boardwalk Pipeline Partners, LP (Boardwalk).\nPHMSA issued the Corrective Action Order (CAO), to both Chevron and Boardwalk on October\n20, 2014, requiring the development and communication of a restart plan, a mandated pressure\nrestriction on the affected segment, development of an integrity verification and remediation plan\n(IVRP) for the entire pipeline, and implementation of mitigative actions necessary for the safe\noperation of the pipeline. The implementation of the CAO was transitioned to Boardwalk\nLouisiana Midstream, LLC following the assignment of the assets from Chevron. All references\nto Chevron in the CAO were completed by Boardwalk.\nBoardwalk has completed all of the requirements of the CAO. This letter is to inform you that\nno further action is necessary and this case is now closed. Thank you for your cooperation.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":24087}