SHELL PIPELINE CO., L.P. — Notice of Amendment

party submissionOfficial PDF420175016M_Operator Response to the Notice_05312017.pdf#

420175016M_Closure Letter_12042017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED December 4, 2017 Mr. Greg Smith President Shell Pipeline Company 150 Dairy Ashford Building A Houston, TX 77079 CPF 4-2017-5016M Dear Mr. Greg Smith: From June to November 2016, representatives from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on- site pipeline safety inspection of Shell Pipeline Corp (Shell) procedures in Houston, TX. As a result of the inspection, Shell was issued a Notice of Amendment on May 3, 2017, which proposed amendment of your procedures. Shell submitted its amended procedure on May 31, 2017. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Frank Causey Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420175016M_Notice of Amendment_05032017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED May 3, 2017 Mr. Greg Smith President, Shell Pipeline Company Two Shell Plaza 777 Walker Street Houston, TX 77002 CPF 4-2017-5016M Dear Mr. Smith: Between June and November 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Shell Pipeline Company’s (Shell) operation and maintenance procedures in Houston, Texas. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Shell’s procedures, as described below: 1. § 195.202 Compliance with Specifications or Standards Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. § 195.248 Cover Over Buried Pipeline (a) Unless specifically exempted in this subpart, all pipe must be buried so that it is below the level of cultivation. Except as provided by paragraph (b) of this section, the pipe must be installed so that the cover between the top of the ground level, road bed, River bottom, or underwater natural bottom (as determined and generally accepted practices), as applicable, complies with the following table….#

420175016M_Notice of Amendment_05032017_text.pdf, page 2Shell’s procedure 40 TS-002 Construction of Onshore Pipelines and Related Facilities Section 17 Backfilling did not reference where to find depth of cover standards for use when backfilling operations are being performed. Shell’s Manual (40 TS-002), Section 17 Backfilling needs to include a reference to Pipeline I&M Manual section 3.7.6 Depth of Cover Requirements to adequately convey the required depth of cover when performing backfilling operations. 2. § 195.202 Compliance with Specifications or Standards Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. § 195.260 Valves: Location A valve must be installed at each of the following locations: (a) On the suction end and the discharge end of a pump station in a manner that permits isolation of the pump station equipment in the event of an emergency. (b) On each line entering or leaving a breakout storage tank area in a manner that permits isolation of the tank area from other facilities. (c) On each mainline at locations along the pipeline system that will minimize damage or pollution from accidental hazardous liquid discharge, as appropriate for the terrain in open country, for offshore areas, or for populated areas. (d) On each lateral takeoff from trunk line in a manner that permits shutting off the lateral without interrupting the flow in the trunk line. (e) On each side of a water crossing that is more than 100 feet (30 meters) wide from high-water mark to high-water mark unless the Administrator finds in a particular case that valves are not justified. (f) On each side of a reservoir holding water for human consumption. 2#

420175016M_Notice of Amendment_05032017_text.pdf, page 3Shell’s procedure ODM 05.01.T.00 Basic Design & Engineering Package did not specify where valves are to be placed during design and construction of their pipelines. Shells’ procedure ODM 05.01.T.00 Basic Design & Engineering Package needs to specify where valves are to be located in a manner that meets the requirements of §195.260 during the design and construction phase. 3. § 195.202 Compliance with Specifications or Standards Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. § 195.212 Bending of Pipes (b) Each circumferential weld which is located where the stress during bending causes a permanent deformation in the pipe must be nondestructively tested either before or after the bending process. Shell’s procedure 40 TS-002 Construction of Onshore Pipelines and Related Facilities Section 14 Field Bends did not specify that circumferential welds located where the stress during bending causes a permanent deformation in the pipe must be nondestructively tested either before or after the bending process. Shell’s procedure 40 TS-002 Construction of Onshore Pipelines and Related Facilities Section 14 Field Bends needs to specify that circumferential welds located where the stress during bending causes a permanent deformation in the pipe must be nondestructively tested either before or after the bending process. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). 3#

420175016M_Notice of Amendment_05032017_text.pdf, page 4Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Shell Pipeline Company maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Terri J. Binns, Acting Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2017-5016M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Terri J. Binns Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 4#