{"operation":"document","citation":"CPF 420175022M","title":"FRONTIER ENERGY SERVICES, L.L.C. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-20","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(7), 195.432(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175022m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175022m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175022m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175022M","body":"Notice of Amendment involving FRONTIER ENERGY SERVICES, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(7),  195.432(b). The case was opened on 2017-06-20 and is reported as closed as of 2019-04-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175022M_Closure Letter_04032019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175022M/420175022M_Closure%20Letter_04032019.pdf\n\n420175022M_Closure Letter_04032019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175022M/420175022M_Closure%20Letter_04032019_text.pdf\n\n420175022M_Notice of Amendment_06202017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175022M/420175022M_Notice%20of%20Amendment_06202017.pdf\n\n420175022M_Notice of Amendment_06202017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175022M/420175022M_Notice%20of%20Amendment_06202017_text.pdf\n\n420175022M_Operator Response to Notice_06282017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175022M/420175022M_Operator%20Response%20to%20Notice_06282017.pdf\n\n420175022M_Closure Letter_04032019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 3, 2019\nRobert Shain\nSenior Vice President of Engineering\nFrontier Energy Services, LLC\n4200 E. Skelly Drive, Suite 400\nTulsa, OK 74135\nCPF 4-2017-5022M\nDear Mr. Shain:\nOn various dates in 2015 and 2016, representatives from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, inspected\nFrontier Energy Services, LLC’s procedures and records for design and construction and\nconducted field inspections of the Alpha Crude Cunnector pipeline and facilities located in New\nMexico and Texas. As a result of the inspection, Frontier Energy Services, LLC was issued a\nNotice of Amendment on June 20, 2017, which proposed amendment of your procedures.\nFrontier Energy Services, LLC submitted notification D-20170222-14510 to PHMSA on February\n22, 2017. This notification informed PHMSA of Frontier Energy Services, LLC’s divestiture from\nall PHMSA-regulated pipeline assets and requested deactivation of their Operator Identification\nNumber. As a result, PHMSA has determined that the proposed amendments are no longer\nrelevant.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420175022M_Notice of Amendment_06202017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 20, 2017\nMr. Robert Shain\nSenior Vice President of Engineering\nFrontier Energy Services, LLC\n4200 E. Skelly Drive, Suite 400\nTulsa, OK 74135-3256\nCPF 4-2017-5022M\nDear Mr. Shain:\nOn various dates in 2015 and 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code inspected the Frontier Energy Services, LLC procedures and records for design and\nconstruction and conducted field inspections of the Alpha Crude Connector pipeline and facilities\nlocated in New Mexico and Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within the\nFrontier Energy plans or procedures, as described below:\n1. §195.432 Inspection of in-service breakout tanks.\n(b) Each operator must inspect the physical integrity of in-service atmospheric and low-\npressure steel above-ground breakout tanks according to API Std 653 (except section\n6.4.3, Alternative Internal Inspection Interval) (incorporated by reference, see §195.3).\nHowever, if structural conditions prevent access to the tank bottom, its integrity may be\nassessed according to a plan included in the operations and maintenance manual under\n§195.402(c)(3). The risk-based internal inspection procedures in API Std 653, section\n\n\n\n6.4.3 cannot be used to determine the internal inspection interval.\nFrontier Energy Services procedures, (Liquid Pipeline Operations, Maintenance & Emergency\nManual, Section 6 Breakout Tanks, Last Revision Date: Dec. 15, 2015), do not define the\nmethodology for performing external ultrasonic thickness inspections of steel atmospheric and low\npressure breakout tanks. The procedures must define the methodology the operators use to satisfy\nthe requirements of §195.432 and API 653.6.3.3 (IBR).\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\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(7) Starting up and shutting down any part of the pipeline system in a manner\ndesigned to assure operation within the limits prescribed by §195.406, consider the\nhazardous liquid or carbon dioxide in transportation, variations in altitude along the\npipeline, and pressure monitoring and control devices.\nFrontier Energy Services failed to have adequate procedures to ensure the operator does not exceed\nthe maximum operating pressure (MOP) while starting up and shutting down the pipeline (ACC\nO&M Liquid Pipeline Operations, Maintenance & Emergency Manual – Section 3.2 & 3.3 – Last\nRevised: December 15, 2015). Frontier Energy must amend its procedures to specify detailed\nprocedures including verification of the function and set points for overpressure protection devices,\nthe method(s) and frequency for monitoring pressures and flow rates and the documentation\nrequirements (i.e. pressure records, flow rates) during startup and shut down of their pipelines.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\n2\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 45 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in\nyour amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Frontier Energy Services 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 4-2017-5022M and, for each document you submit, please provide a\ncopy in electronic format whenever possible.\nSincerely,\nJon Manning\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":8119}