{"operation":"document","citation":"CPF 420172003M","title":"SHELL PIPELINE CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-03","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.605(c)(1)(ii), 192.605(e), 192.613(a), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420172003M","body":"Notice of Amendment involving SHELL PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(c)(1)(ii),  192.605(e),  192.613(a),  192.709(c). The case was opened on 2017-05-03 and is reported as closed as of 2017-12-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420172003M_Closure Letter_12012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172003M/420172003M_Closure%20Letter_12012017.pdf\n\n420172003M_Closure Letter_12012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172003M/420172003M_Closure%20Letter_12012017_text.pdf\n\n420172003M_Notice of Amendment_05032017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172003M/420172003M_Notice%20of%20Amendment_05032017.pdf\n\n420172003M_Notice of Amendment_05032017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172003M/420172003M_Notice%20of%20Amendment_05032017_text.pdf\n\n420172003M_Operator Response to the Notice_05312017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172003M/420172003M_Operator%20Response%20to%20the%20Notice_05312017.pdf\n\n420172003M_Notice of Amendment_05032017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 3, 2017\nMr. Greg Smith\nPresident\nShell Pipeline Corp\nTwo Shell Plaza\n777 Walker Street\nHouston, TX 77077\nCPF 4-2017-2003M\nDear Mr. Smith:\nBetween June and November 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Shell\nPipeline Corp (Shell) procedures for operation and maintenance in Houston, Texas and Houma,\nLouisiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nShell’s procedures as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(c) Abnormal operation. For transmission lines, the manual required by paragraph\n(a) of this section must include procedures for the following to provide safety when\noperating design limits have been exceeded:\n(1) Responding to, investigating, and correcting the cause of:\n(ii) Increase or decrease in pressure or flow rate outside normal operating limits;\n\n\n\nShell’s procedure Section IV: Emergency and Abnormal Conditions Procedures did not account\nfor responding to, investigating and correcting the cause of increases or decreases in pressure or\nflow rate outside normal operating limits.\nShell needs to modify its procedure Section IV: Emergency and Abnormal Conditions Procedures\nto include considerations for responding to, investigating and correcting the cause of increases or\ndecreases in pressure or flow rate outside normal operating limits.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(e) Surveillance, emergency response, and accident investigation. The procedures\nrequired by §§192.613(a), 192.615, and 192.617 must be included in the manual\nrequired by paragraph (a) of this section.\n§192.613 Continuing surveillance.\n(a) Each operator shall have a procedure for continuing surveillance of its facilities to\ndetermine and take appropriate action concerning changes in class location, failures,\nleakage history, corrosion, substantial changes in cathodic protection requirements,\nand other unusual operating and maintenance conditions.\nShell did not have a procedure for continuing surveillance of its facilities to determine and take\nappropriate action concerning changes in class location, failures, leakage history, corrosion,\nsubstantial changes in cathodic protection requirements, and other unusual operating and\nmaintenance conditions.\nShell needs to modify its operations and maintenance manual to include procedures for continuing\nsurveillance of its facilities in a manner that meets the requirement of §192.613 (a).\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of the\nrequirements of this subpart and subpart M of this part.\n§192.709 Transmission lines: Record keeping.\n(c) A record of each patrol, survey, inspection, and test required by subparts L and\nM of this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\n2\n\n\n\nShell’s Pipeline I&M manual procedure, section 3.31.1 Record Retention did not specify that\nrecords for each patrol, survey, inspection and test required by subparts L&M will be maintained\nfor at least 5 years or until the next test, inspection or survey.\nShell needs to modify its procedure Pipeline I&M manual, section 3.31.1 Record Retention to add\nthat records for each patrol, survey, inspection and test required by subparts L&M will be\nmaintained for at least 5 years or until the next test, inspection or survey.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\n3\n\n\n\nIt is requested (not mandated) that Shell Pipeline Corp maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Terri J Binns, Acting Director, Southwest Region,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 4-2017-2003M and, for each document you submit, please provide a\ncopy in electronic format whenever possible.\nSincerely,\nTerri J. Binns\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4\n\n420172003M_Closure Letter_12012017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 1, 2017\nMr. Greg Smith\nPresident\nShell Pipeline Corp\n150 Dairy Ashford\nBuilding A\nHouston, TX 77079\nCPF 4-2017-2003M\nDear Mr. Greg Smith:\nFrom June to November 2016, representatives 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 Shell Pipeline Corp (Shell) procedures in Houston, TX. As a\nresult of the inspection, Shell was issued a Notice of Amendment on May 3, 2017, which proposed\namendment of your procedures.\nShell submitted its amended procedure on May 31, 2017. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nFrank Causey\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8697}