{"operation":"document","citation":"CPF 420185006M","title":"HOLLY ENERGY PARTNERS - OPERATING, L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-06-20","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420185006M","body":"Notice of Amendment involving HOLLY ENERGY PARTNERS - OPERATING, L.P.. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2018-06-20 and is reported as closed as of 2018-12-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420185006M_Closure Letter_12132018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185006M/420185006M_Closure%20Letter_12132018.pdf\n\n420185006M_Closure Letter_12132018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185006M/420185006M_Closure%20Letter_12132018_text.pdf\n\n420185006M_Notice of Amendment_06202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185006M/420185006M_Notice%20of%20Amendment_06202018.pdf\n\n420185006M_Notice of Amendment_06202018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185006M/420185006M_Notice%20of%20Amendment_06202018_text.pdf\n\n420185006M_Operator Response to Notice_08292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185006M/420185006M_Operator%20Response%20to%20Notice_08292018.pdf\n\n420185006M_Closure Letter_12132018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 13, 2018\nMark Cunningham\nSenior Vice President, Engineering & Technical Services\nHolly Energy Partners- Operating, L.P.\n2828 N Hardwood, Suite 1300\nDallas, Texas 75201\nCPF No. 4-2018-5006M\nDear Mr. Cunningham:\nDuring the month of March 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected Holly Energy Partners- Operating, L.P. Operating and\nMaintenance procedures in the city of Carlsbad, New Mexico.\nAs a result of this inspection, a Notice of Amendment, CPF 4-2018-5006M, was issued on June\n20, 2018 to Holly Energy Partners- Operating, L.P. On August 30, 2018, Holly Energy Partners-\nOperating, L.P responded to the Notice. Based upon review of the response letter, it appears that\nthe inadequacies outlined 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,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420185006M_Notice of Amendment_06202018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 20, 2018\nMr. Mark Cunningham\nSr. Vice President, Engineering & Technical Services\nHolly Energy Partners- Operating, L.P.\n2828 N Hardwood, Suite 1300\nDallas, TX 75201\nCPF 4-2018-5006M\nDear Mr. Cunningham:\nDuring the month of March 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Holly\nEnergy Partners- Operating, L.P (HEP) Operating and Maintenance (O&M) procedures in the city\nof Carlsbad, NM.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nHolly Energy Partners- Operating, L.P. plans or 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 maintenance and\nnormal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the\nrequirements of this subpart and subpart H of this part.\nHEP did not have a written procedure to perform calibration of reference half cells used to\ndetermine the adequacy of cathodic protection of their pipeline system as required by §195.571.\n\n\n\nDuring the field inspection, PHMSA asked the corrosion technicians performing the pipe to soil\npotential surveys if the reference half cell was calibrated or not. HEP’s corrosion technician\nresponded that HEP does not have any procedure on reference cell calibration.\nThe M.C. Miller (reference cell manufacturer) technical manual, MAN270 clearly explains in\ndetail about the short-term maintenance, long term maintenance and testing electrodes for\naccuracy.\nHEP must amend its procedure to reflect the reference half cell calibration process. HEP must\ninclude a time frame detailing how often or under what situation, the reference cell must be\ncalibrated or replaced. In the procedure, HEP must explain how corrosion personnel will document\nthe calibration date or replacement date of the reference cell..\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(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the\nrequirements of this subpart and subpart H of this part.\nThe HEP- O&M procedure, O&M-195.571, is inadequate and does not comply with the cathodic\nprotection criteria contained in paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169\nreferenced by §195. 571.\nDuring the procedure review, PHMSA noted HEP is considering a -850 mVdc “ON” reading as\nan indication of adequate cathodic protection on their pipeline.\nThe HEP-O&M-195.571 Cathodic Protection Criteria states: -\n“It as commonly accepted throughout the industry that a steel structure is under cathodic\nprotection when the potential, as referred to a copper sulfate electrode, is -.85 volt current applied\n(ON) or more negative with respect to the soil”.\n“HEP’s Cathodic Protection Criteria complies with NACE SP-0169\nIf -.85-volt current applied (ON) measurement is not achieved, further follow-up action will be\ntaken to achieve adequate protection. 100mv Polarization criterion may be used to determine\nadequate Cathodic Protection.”\nAccording to NACE SP 0169, paragraph 6.2.2, “Voltage drops other than those across the\nstructure-to-electrolyte boundary must be considered for valid interpretation of this voltage\nMeasurement”.\nHEP must amend their procedure to reflect a -850 mV “ON” read with the consideration of IR\ndrop for valid interpretation of the voltage measurement.\n2\n\n\n\n3. §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(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the\nrequirements of this subpart and subpart H of this part.\nHEP did not have an adequate written procedure to reflect the criteria used to determine the\nadequacy of cathodic protection of their pipeline system as required by §195.571.\nDuring the field inspection of the Wichita Falls Tank terminal, PHMSA came across several above\nground storage tanks that have the double tank bottom. PHMSA asked HEP to explain how they\nmaintain cathodic protection on those tank bottoms. HEP responded by providing the records of\nVCI (vapor corrosion inhibitor) injection and ER corrosion probes. Upon request, HEP also\nprovided the procedure for VCI and ER corrosion probes.\nAfter reviewing the procedures and the records, PHMSA noted the authenticity of the procedure\ndoes not indicate whether it is officially approved or not by HEP. The procedure lacks procedure\n#, revision dates, etc. PHMSA also noted a lack of details such as engineering analysis and /or\nbenefits about using the VCI (vapor corrosion inhibitor) in the double tank bottom\nHEP must amend its procedure, “AST Corrosion Control Procedures.” HEP must establish an\nengineering analysis and/ or the benefits from using the VCI (vapor corrosion inhibitor) in the\ndouble tank bottom. HEP must explain in detail the injection and re-injection criteria/requirements\nof VCI (vapor corrosion inhibitor) based on the ER corrosion probes rate.\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).\n3\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 [number of days]\ndays of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that Holly Energy Partners- Operating, L.P. maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary McDaniel, Director, SW\nRegion, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning\nthis matter, please refer to CPF 4-2018-5006M and, for each document you submit, please provide\na copy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4","truncated":false,"body_characters":10470}