{"operation":"document","citation":"CPF 420175020M","title":"ENTERPRISE PRODUCTS OPERATING LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-10","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175020m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175020m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175020m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175020M","body":"Notice of Amendment involving ENTERPRISE PRODUCTS OPERATING LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-05-10 and is reported as closed as of 2017-08-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175020M_Closure Letter_08152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175020M/420175020M_Closure%20Letter_08152017.pdf\n\n420175020M_Closure Letter_08152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175020M/420175020M_Closure%20Letter_08152017_text.pdf\n\n420175020M_Notice of Amendment_05102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175020M/420175020M_Notice%20of%20Amendment_05102017.pdf\n\n420175020M_Notice of Amendment_05102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175020M/420175020M_Notice%20of%20Amendment_05102017_text.pdf\n\n420175020M_Operator Response to Notice_06092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175020M/420175020M_Operator%20Response%20to%20Notice_06092017.pdf\n\n420175020M_Notice of Amendment_05102017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 10, 2017\nMr. Graham Bacon\nExecutive VP-Ops and Engineering\nEnterprise Products Partners, L.P.\n1100 Louisiana Street\nHouston, TX 77002\nCPF 4-2017-5020M\nDear Mr. Graham Bacon:\nFrom October 27, 2014 until November 20, 2015, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Enterprise Products - Mid-America Pipeline Company (EP_MAPCO) procedures for\nO&M, Emergency, Corrosion Control, Public Awareness, Integrity Management, and Training &\nQualifications in Houston, TX.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nEP_MAPCO’s plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies. This\nmanual shall be reviewed at intervals not exceeding 15 months, but at least once\neach calendar year, and appropriate changes made as necessary to insure that\nthe manual is effective. This manual shall be prepared before initial operations\nof a pipeline system commence, and appropriate parts shall be kept at locations\nwhere operations and maintenance activities are conducted.\n\n\n\nEP_MAPCO fails to have a procedure or procedures that deal with In-service Welding regarding\nthe following: pipe wall burn through, weld cooling rate, hydrogen cracking, metallurgy of the\nmaterials being welded, proper support of the pipe in the ditch, and delay times prior to inspection\nof the weld. The Federal Regulations, §195.422(a) states,\n“Each operator shall, in repairing its pipeline systems, insure that the\nrepairs are made in a safe manner and are made so as to prevent damage\nto persons or property.”\nThe EP_MAPCO Engineering Standards and Specifications, STD.8004 In-service Welding, Pre-\nassessment, Evaluation, and Approval, is a form with instructions for completing the Pre-\nAssessment Letter (PAL). The standard fails to address pipe wall burn through, weld cooling rate,\nhydrogen cracking, metallurgy of the materials being welded, proper support of the pipe in the\nditch, and delay times prior to inspection of the weld. The standard does reference API 1104\nAppendix B In-Service Welding, but fails to elaborate on the processes.\nEP_MAPCO must amend their procedures to address pipe wall burn through, weld cooling rate,\nhydrogen cracking, metallurgy of the materials being welded, proper support of the pipe in the\nditch, and delay times prior to inspection of the weld.\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.\n2\n\n\n\nIt is requested (not mandated) that Enterprise Products - Mid-America Pipeline Company maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Terri J. Binns,\nActing Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 4-2017-5020M and, for each\ndocument you submit, please provide a copy 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\n3\n\n420175020M_Closure Letter_08152017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 15, 2017\nMr. Graham Bacon\nExecutive VP-Ops and Engineering\nEnterprise Products Partners, L.P.\n1100 Louisiana Street\nHouston, TX 77002\nCPF 4-2017-5020M\nDear Mr. Graham Bacon:\nFrom October 27, 2014 until November 20, 2015, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States\nCode, conducted an on-site pipeline safety inspection of Enterprise Products - Mid-America\nPipeline Company (EP_MAPCO) procedures in Houston, TX. As a result of the inspection,\nEP_MAPCO was issued a Notice of Amendment on May 10, 2017, which proposed amendment\nof your procedures.\nEP_MAPCO submitted its amended procedure on June 9, 2017 (received in the PHMSA office on\nJune 14, 2017). My staff reviewed the amended procedure, and it appears that the inadequacies\noutlined 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,\nFrank Causey\nActing Director, SW Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7661}