UCAR PIPELINE INCORPORATED — Notice of Amendment

party submissionOfficial PDF420191003M_Operator Response to Notice_03212019.pdf#

420191003M_Closure Letter_11222019_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED November 22, 2019 Neelam Shah President UCAR Pipeline Incorporated 1000 County Rd 340 Angleton, Texas 77515 CPF 4-2019-1003M Dear Ms. Shah: On April 16, 2018 through April 28, 2018, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of UCAR Pipeline Incorporated’s (UCAR) procedures in Angleton, Texas. As a result of the inspection, UCAR was issued a Notice of Amendment on February 22, 2019. UCAR submitted its amended procedures on March 21, 2019. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420191003M_Notice of Amendment_02222019_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED February 22, 2019 Otto Parets President UCAR Pipeline Incorporated 1000 County Rd 340 Angleton, Texas 77515 CPF 4-2019-1003M Dear Mr. Parets: On April 16, 2018 through April 28, 2018, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected UCAR Pipeline Incorporated’s (UCAR) Texas City – Napoleonville pipeline in Texas and Louisiana. On the basis of the inspection, PHMSA has identified an apparent inadequacy found within UCAR’s plans or procedures, as described below: 1. §192.463 External corrosion control: Cathodic protection. (a) Each cathodic protection system required by this subpart must provide a level of cathodic protection that complies with one or more of the applicable criteria contained in appendix D of this part. If none of these criteria is applicable, the cathodic protection system must provide a level of cathodic protection at least equal to that provided by compliance with one or more of these criteria.#

420191003M_Notice of Amendment_02222019_text.pdf, page 2UCAR’s written procedure titled OME M-15 Corrosion Control does not provide for the determination of the adequate level of cathodic protection in accordance with Appendix D of Part 192. OME M-15 includes the following process for determining the adequacy of cathodic protection in step 2: The structure potential shall be at least a negative .85 volt with reference to a saturated copper-copper sulfate half-cell. This measurement is to be made with the protective current applied and the reference cell placed in the electrolyte in close proximity to the structure to minimize I x R drop error. Appendix D of Part 192 includes the following requirement for calculating the voltage drop. II. Interpretation of voltage measurement. Voltage (IR) drops other than those across the structure-electrolyte boundary must be considered for valid interpretation of the voltage measurement in paragraphs A (1) and (2) and paragraph B (1) of section I of this appendix. OME M-15 does not require the measurement or calculation of the IR drop error, instead it only seeks to minimize it via measurement in close proximity to the pipe. In practice, UCAR employees measure the potential through several feet of earth which can induce significant IR drop error. UCAR must amend this procedure to require proper consideration of the IR drop error. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. 2#

420191003M_Notice of Amendment_02222019_text.pdf, page 3It is requested (not mandated) that UCAR Pipeline Incorporated maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, P.E., Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2019-1003M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings. 3#