{"operation":"document","citation":"CPF 420155015M","title":"ENTERPRISE CRUDE PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-07-10","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.579(a), 195.579(b), 195.579(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155015m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155015m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155015m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420155015M","body":"Notice of Amendment involving ENTERPRISE CRUDE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.579(a),  195.579(b),  195.579(c). The case was opened on 2015-07-10 and is reported as closed as of 2015-08-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420155015M_Closure Letter_08182015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155015M/420155015M_Closure%20Letter_08182015.pdf\n\n420155015M_Closure Letter_08182015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155015M/420155015M_Closure%20Letter_08182015_text.pdf\n\n420155015M_NOA_07102015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155015M/420155015M_NOA_07102015.pdf\n\n420155015M_NOA_07102015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155015M/420155015M_NOA_07102015_text.pdf\n\n420155015M_Operator Reponse to Notice_08042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155015M/420155015M_Operator%20Reponse%20to%20Notice_08042015.pdf\n\n420155015M_Closure Letter_08182015_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 18, 2015\nMr. Graham Bacon\nGroup SVP, Operations & EHS&T\nEnterprise Crude Pipeline LLC\n1100 Louisiana Street.\nHouston, TX 77002\nCPF 4-2015-5015M\nDear Mr. Bacon:\nOn May 18, 2015, 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 Enterprise Crude Pipeline’s (Enterprise) procedures in Houston,\nTX. As a result of the inspection, Enterprise was issued a Notice of Amendment on July 10,\n2015, which proposed amendment of your procedures.\nEnterprise submitted its amended procedures on August 4, 2015. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave 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\n\n420155015M_Operator Reponse to Notice_08042015.pdf\n\nEnterprise\nProducts\nENTERPRISE PRODUCTS PARTNERS L.P.\nENTERPRISE PRODUCTS HOLDINGS LLC\n(General Partner)\nENTERPRISE PRODUCTS OPERATING LLC\nAugust 4, 2015\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n8701 South Gessner, Suite 1110\nHouston, TX 77074\nBy\nAttn: Mr. R. M. Seeley\nDirector, Southwest Region, PHMSA\nRe: Notice of Amendment CPF 4-2015-5015M\nDear Mr. Seeley,\nEnterprise Crude Pipeline LLC (\"Enterprise\") is in receipt of the above referenced \"Notice of\nAmendment\" dated July 10, 2015. This letter constitutes Enterprise's timely response to the\nrequest.\nItem 1:\n§195.402 Procedural manual for operations, maintenance and emergency response.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\n§195.579 What must I do to mitigate internal corrosion?\n(a) General. If you transport any hazardous liquid or carbon dioxide that would corrode\nthe pipeline, you must investigate the corrosive effect of the hazardous liquid or carbon\ndioxide on the pipeline and take adequate steps to mitigate internal corrosion.\n(b) Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion, you must-\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.\nP.O. BOX 4324\nHOUSTON, TEXAS 7721 0·4324\n713.381.6500\n1100 LOUISIANA STREET\nHOUSTON, TEXAS 77002-5227\nwww.enterpriseproducts.com\n\n\n\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the\ninternal surface of the pipe for evidence of corrosion. If you find internal corrosion\nrequiring corrective action under Sec. 195.585, you must investigate circumferentially\nand longitudinally beyond the removed pipe (by visual examination, indirect method, or\nboth) to determine whether additional corrosion requiring remedial action exists in the\nvicinity of the removed pipe.\nEnterprise's Internal Corrosion Procedures, Section 1502, contained within their Operations and\nMaintenance manual fail to include all procedures utilized by Enterprise in their Internal\nCorrosion Control Program. Enterprise procedures do not reference the procedure CPP-ICP-00\nControl of Internal Corrosion Steel and Piping Systems within the company Operations and\nMaintenance Manual. This document should be referenced, as it contains details for the control\nof internal corrosion for all gas and liquid pipeline facilities.\nEnterprise's Response to Item 1:\nEnterprise has amended O&M Section 1502 to reference procedure CPP-ICP-00 Control of\nInternal Corrosion in Steel Pipelines and Piping Systems. The revised Section 1502 date\n7124/2015 is attached.\nShould you have any questions, require additional information or wish to discuss this matter in\ngreater detail, please do not hesitate to contact our office. Enterprise welcomes the opportunity\nto work with PHMSA regarding the safe construction and operation of our pipelines.\nSincerely,\non\nDirector, Transportation Compliance\n2\n\n\n\nPROCEDURES MANUAL FOR HAZARDOUS LIQUIDS PIPELINE OPERATIONS,\nMAINTENANCE, AND EMERGENCIES\nCorrosion Control Procedures\nSubject: Internal Corrosion Section: 1502\nReferences:49CFR§§195 Subp;ut H- Corrosion Control 195.551\nApplicability\n195.555\nQualifications of\nSupervisors\nPage 1 of3\nDate: 07/2412015\nAll the Company's steel pipelines will be protected against corrosion by means\nof the corrosion prevention program, which includes this document and the\nspecifications and procedures as specifically referenced herein. The corrosion\nprevention program will be instituted, operated, and maintained to insure\nadequate protection.\nThe Corrosion Prevention Group Supervisors must have thorough knowledge\nof the corrosion control procedures associated with the program and their\nprofessional activities shall include suitable experience in the field of corrosion\ncontrol. The training may be accomplished through the National Association of\nCorrosion Engineers educational and training programs, in-house training or\ncomparable industry training programs. Corrosion Prevention Group\nSupervisor resumes are maintained as a part of the Hazardous Liquid Pipeline\nIntegrity Management Program. Verification of training and certification can\nalso be made directly through the National Association of Corrosion Engineers\n195.579\nInternal\nCorrosion\nStandardized methods for the control of internal corrosion in steel pipelines\nand piping systems used to gather, transport or distribute hazardous liquids or\ncarbon dioxide should be as specified in Company specification and procedure\nEPCO CPP-ICP-00 \"Control of Internal Corrosion in Steel Pipelines and piping\nSystems\".\nMonitoring techniques can include but are not limited to:\n• In-line inspection\n• Hydro-static testing\n• Weight loss coupon\n• Corrosion rate probes\n• Product analysis (liquids, solids, microbiological activity, etc.)\n• Copper strip testing\n• Direct measurement\n• Visual examination\nSampling locations shall be carefully chosen so that a sample collected,\nrepresents the majority of liquids within a system, and/or represents the\nlocation where corrosion is expected to be most aggressive. If an upset\ncondition is known to have occurred, a reasonable effort should be made to\ncollect a liquid sample.\nWhen monitoring results indicate, steps will be taken to mitigate internal\ncorrosion of the pipeline system. The design, selection and installation of\n\n\n\nPROCEDURES MANUAL FOR HAZARDOUS LIQUIDS PIPELINE OPERATIONS,\nMAINTENANCE, AND EMERGENCIES\nCorrosion Control Procedures\nSubject: Internal Corrosion Section: 1502\nReferences:49CFR§§195 Subpart H -Corrosion Control Page 2 of3\nDate: 07/24/2015\ninternal corrosion control and monitoring systems should be in accordance with\nthe Company specification and procedure EPCO CPP-ICP-00 \"Control of\nInternal Corrosion in Steel Pipelines and piping Systems\". Mitigation\ntechniques can include but are not limited to:\n• Elimination/control of corrosive constituents\n• Maintenance pigging\n• Chemical treatment\n• Changes to pipe configurations\n• Changes to operating conditions\nIf chemical mitigation is used, coupons or other monitoring equipment will be\nutilized to determine the effectiveness of the chemical mitigation. Coupons or\nother types of monitoring equipment shall be examined at intervals not\nexceeding seven and a half months, but at least twice each calendar year, to\ndetermine the effectiveness of the chemical mitigation or the extent of any\ncorrosion. The Corrosion Prevention Group will determine the coupon\nlocations. As a general rule, coupons should be placed in 1) locations\navailable that can provide representative data of the system and/or 2) in\nlocations with significant potential for internal corrosion. Many operational and\nenvironmental conditions influence the optimal selection of locations for\ncoupon installations. Since it is normally impractical to locate internal corrosion\nmonitoring devices at natural low points of the pipe line system, monitoring\nlocations and equipment type will be utilized in a manner to best simulate such\nareas.\nThe results shall be documented on the appropriate form or database.\n195.585 and\n195.587\nCorroded Pipe\nEvaluation and\nRepair\nWhen circumstances allow for the inspection of the internal surface of pipe for\nany reason, the internal surface of the pipe and adjacent pipe shall be\ninspected both circumferentially and longitudinally, for internal corrosion. If\ninternal corrosion is found requiring corrective action under §195.585, the\nextent of corrosion will be determined, and appropriate steps taken to maintain\npipe integrity.\nInternal corrosion shall be evaluated and the strength of corroded pipe\ndetermined in accordance with the Company Standard STD.9006 \"Pipeline\nDefect Evaluation and Repair Procedure\".\nIf the strength of the corroded pipe is less than required for the MOP, the\nfollowing shall be performed:\n\n\n\nPROCEDURES MANUAL FOR HAZARDOUS LIQUIDS PIPELINE OPERATIONS,\nMAINTENANCE, AND EMERGENCIES\nCorrosion Control Procedures\nSubject: Internal Corrosion Section: 1502\nReferences:49CFR§§195 Subpart H -Corrosion Control Page 3 of3\nDate: 07/24/2015\n1. Reduce the MOP commensurate with the strength of the corroded pipe\nneeded for serviceability in accordance with the Company Operating\nPressure Procedure.\n2. Repair the pipe in accordance with the Company Standard STD.9006\n\"Pipeline Defect Evaluation and Repair Procedure\".\nAll examination, evaluation, and repair information shall be documented on the\nappropriate Company form or in the appropriate database and shall be\nforwarded to the Asset Data Management Group. Contact the Liquid Pipeline\nIntegrity Group, as necessary, for assistance with the evaluation of anomalies.\nContact the Corrosion Prevention Group for assistance with evaluating\ncorrosion control deficiencies.\nAny linings installed in breakout tanks shall be installed in accordance with API\nRP 652.\n195.589\nRecords:\nRecords shall be maintained for each test or inspection for internal corrosion\nutilizing the appropriate form(s) and or database.\nThese records may be supplemented by additional information or data at any\ntime, as well as by laboratory reports from outside laboratories.\nInternal corrosion records shall be retained for no less than 5 years and those\nrecords outlined in 195.589(c) must be retained for the life of the pipeline as\nlong as it is in service.\nRecords Retention information is located in the Enterprise Records Retention\nSchedule available through the Enterprise Internet Portal.\nAssociated\nOperator\nQualification\nTasks\nResponsibilities:\n1 0.1 Insert and Remove Coupons\n10.2 Monitor Probes (online)\n11 Perform Internal Corrosion Remediation\n12 Inspect Internal Pipe Surface\nIt shall be the responsibility of the Corrosion Prevention Group to establish and\ncoordinate an adequate and effective Corrosion Prevention Program, provide\nprocedures for implementing the program, arrange for any necessary tests and\nanalysis by outside parties, provide technical guidance, and maintain corrosion\ncontrol records except for those records related to 195.579(c) and 195.587 or\nany other record not exclusively generated by the Corrosion Prevention Group.\nIt shall be the responsibility of the Corrosion Prevention Group supervision to\n\n\n\nPROCEDURES MANUAL FOR HAZARDOUS LIQUIDS PIPELINE OPERATIONS,\nMAINTENANCE, AND EMERGENCIES\nCorrosion Control Procedures\nSubject: Internal Corrosion Section: 1502\nReferences:49CFR§§195 Subpart H- Corrosion Control Page 4of3\nDate: 07/2412015\nsee that the Corrosion Prevention Program and procedures are implemented,\nthat the required field tests are conducted, and the proper records are\nprepared and submitted.\n0\n******","truncated":false,"body_characters":13440}