{"operation":"document","citation":"CPF 420177005M","title":"WHITECAP PIPE LINE COMPANY, L.L.C. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-10-20","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.587.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420177005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420177005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420177005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420177005M","body":"Notice of Amendment involving WHITECAP PIPE LINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.587. The case was opened on 2017-10-20 and is reported as closed as of 2018-06-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420177005M_Closure Letter_06112018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420177005M/420177005M_Closure%20Letter_06112018.pdf\n\n420177005M_Closure Letter_06112018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420177005M/420177005M_Closure%20Letter_06112018_text.pdf\n\n420177005M_Notice Of Amendment_10202017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420177005M/420177005M_Notice%20Of%20Amendment_10202017.pdf\n\n420177005M_Notice Of Amendment_10202017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420177005M/420177005M_Notice%20Of%20Amendment_10202017_text.pdf\n\n420177005M_Operator Response To Notice_11132017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420177005M/420177005M_Operator%20Response%20To%20Notice_11132017.pdf\n\n420177005M_Closure Letter_06112018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 11, 2018\nFrank Cassulo\nPresident\nWhitecap Pipeline Company, L.L.C\n1400 Smith Street\nHouston, TX 77002\nCPF 4-2017-7005M\nDear Mr. Cassulo:\nBetween May 16 to July 10, 2017, representatives of 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 Whitecap Pipeline Company L.L.C’s (Whitecap) operations and\nmaintenance procedures in Houston, Texas. As a result of the inspection, Whitecap was issued a\nNotice of Amendment on October 19, 2017. This Notice proposed amendment of your procedure\nto assure safe operation of your pipeline facility.\nWhitecap submitted its amended procedure on April 23, 2018, via email. My staff reviewed the\namended procedure, and it appears that the inadequacy outlined in this Notice of Amendment has\nbeen corrected.\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\n420177005M_Notice Of Amendment_10202017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 20, 2017\nMr. Frank Cassulo\nPresident\nWhitecap Pipeline Company L.L.C\n1400 Smith Street\nHouston, TX 77002\nCPF 4-2017-7005M\nDear Mr. Cassulo:\nFrom May 16-19, 2017, and July 10-13, 2017, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Whitecap Pipeline Company (Whitecap) procedures for operation and maintenance in\nHouston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nWhitecap’s procedures, as described below:\n1. §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\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n\n\n\n§195.587 What methods are available to determine the strength of corroded pipe?\nUnder §195.585, you may use the procedure in ASME/ANSI B31G (incorporated by\nreference, see §195.3) or in PRCI PR-3-805 (R-STRENG) (incorporated by\nreference, see §195.3) to determine the strength of corroded pipe based on actual\nremaining wall thickness. These procedures apply to corroded regions that do not\npenetrate the pipe wall, subject to the limitations set out in the respective procedures.\nWhitecap failed to state in its internal corrosion control manual, the method that will be used to\ndetermine the strength of internally corroded pipe based on actual remaining wall thickness as\nrequired by §195.587.\nPHMSA inspectors reviewed section 6.5, “Inspection of Removed Pipe” of Whitecap’s internal\ncorrosion control manual, and found that the procedure stated in the manual did not give sufficient\nguidance for personnel to evaluate the strength of pipe that has been discovered to be internally\ncorroded. One or more of the methods (ASME/ANSI B31G, PRCI PR-3-805 (R-STRENG))\nrequired by §195.587 was identified in Chevron’s Integrity Management manual. Chevron\nexcluded Whitecap Pipeline from its integrity management program based on PHMSA FAQ 19.\nWhitecap should amend its procedure for “Inspection of Removed Pipe” to include the method\nthat will be used to determine the strength of internally corroded pipes based on actual remaining\nwall thickness or at the least cross reference section 5.6 of Chevron’s Integrity Management\nmanual in its Internal Corrosion Manual.\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).\n2\n\n\n\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.\nIt is requested (not mandated) that Whitecap Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Terri J Binns, Acting Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2017-7005M and, for each document you submit,\nplease 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","truncated":false,"body_characters":7508}