{"operation":"document","citation":"CPF 420185008M","title":"INDORAMA VENTURES OLEFINS LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-04-27","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420185008M","body":"Notice of Amendment involving INDORAMA VENTURES OLEFINS LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2018-04-27 and is reported as closed as of 2018-07-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420185008M_Closure Letter_07102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185008M/420185008M_Closure%20Letter_07102018.pdf\n\n420185008M_Closure Letter_07102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185008M/420185008M_Closure%20Letter_07102018_text.pdf\n\n420185008M_Notice of Amendment_04272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185008M/420185008M_Notice%20of%20Amendment_04272018.pdf\n\n420185008M_Notice of Amendment_04272018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185008M/420185008M_Notice%20of%20Amendment_04272018_text.pdf\n\n420185008M_Operator Response to Notice_05252018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185008M/420185008M_Operator%20Response%20to%20Notice_05252018.pdf\n\n420185008M_Notice of Amendment_04272018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 27, 2018\nMr. Saswati Biswas\nChief Financial Officer\nIndorama Ventures Olefins, LLC\n4300 Hwy 108\nWestlake, LA 70669\nCPF-4-2018-5008M\nDear Mr. Biswas:\nFrom June 12, 2017 to August 3, 2017, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nIndorama Ventures Olefins, LLC procedures for the Lake Charles/Orange Ethylene Pipeline in\nHouston, TX.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nIndorama’s plans or procedures, as described below:\n§195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at intervals\nnot exceeding 15 months, but at least once each calendar year, and appropriate changes\nmade as necessary to insure that the manual is effective. This manual shall be prepared\nbefore initial operations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted.\nThroughout Indorama’s Liquid Pipeline Operations, Maintenance & Emergency Manual, the\nprocedures replicate and paraphrase the regulations, and reference the regulations instead of their\nown processes and procedures. Indorama’s procedures must be amended to be more specific to\n\n\n\nthe Indorama system, provide adequate details and not simply paraphrase the regulations for\nconducting normal operations and maintenance activities.\nThe following sections of Indorama’s Liquid Pipeline Operations, Maintenance & Emergency\nManual need to be amended:\n1. Section 1.11: Communications to meet the requirements of §195.408 Communications.\nIndorama’s procedures closely paraphrased the regulations and did not include details\nspecific to the Indorama pipeline system. Indorama’s procedure should include specific\ndetails of the Indorama communication system requirements that ensure the communications\nsystem provides for the efficient transmission of information needed for the safe operation\nof the Indorama pipeline system.\n2. Section 7.4: CPM Leak Detection to meet the requirements of §195.444 CPM Leak\nDetection. Indorama’s procedures paraphrase the regulations and did not include details\nspecific to the Indorama pipeline system. Indorama’s procedure should include the\nrequirement to evaluate the capability of its lead detection system, and modify as necessary,\nwhere the process for evaluation includes length and size of the pipeline, type of product\ncarried, the pipeline's proximity to the high consequence area, the swiftness of leak detection,\nlocation of nearest response personnel, leak history, and risk assessment results.\n3. Section 19: Emergency Response Plan of the Liquid Pipeline Operations, Maintenance\n& Emergency Manual and Section 10: Training of the Emergency Response Plan to meet\nthe requirements of §195.403 Emergency Response Training. Indorama’s procedures\nparaphrase the regulations and did not include details specific to the Indorama pipeline\nsystem. Indorama’s procedure also did not include product specific guidance for emergency\nresponse and emergency response training. Indorama’s procedures must include the\nrequirement that emergency personnel are trained on the specific characteristics and hazards\nof the hazardous liquids transported, which is ethylene for this pipeline.\n4. Section 19 Emergency Response Plan, Part 19.10: Accidental Release of Hazardous\nLiquid to meet the requirements of §195.402(e) Emergencies. Indorama’s procedures did\nnot include details specific to the Indorama pipeline system. Section 19.10: Accidental\nRelease of Hazardous Liquid procedure should include correct information for forms used\nto notify the Accident Commander during an accidental spill. Indorama’s procedure directs\npersonnel to fill out the Indorama Spill Report Form and to fax this form to the Accident\nCommander. This referenced form is not assigned a number and is not included in the list\nof forms Section 21: Forms, with this manual. Indorama had not developed the Spill Report\nForm at the time of this inspection.\n2\n\n\n\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.\nIt is requested (not mandated) that Indorama Ventures Olefins, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary McDaniel, Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF-4-2018-5008M and, for each document you submit,\nplease provide a 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\n3\n\n420185008M_Closure Letter_07102018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 10, 2018\nMr. Saswati Biswas\nChief Financial Officer\nIndorama Ventures Olefins, LLC\n4300 Hwy 108\nWestlake, LA 70669\nCPF-4-2018-5008M\nDear Mr. Biswas:\nFrom June 12, 2017 to August 3, 2017, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Indorama Ventures Olefins, LLC procedures in Houston, TX.\nAs a result of the inspection, Indorama Ventures Olefins was issued a Notice of Amendment on\nApril 27, 2018, which proposed amendment of your procedures.\nIndorama Ventures Olefins submitted its amended procedures on May 25, 2018. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment 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","truncated":false,"body_characters":9189}