{"operation":"document","citation":"CPF 420195013M","title":"ENTERPRISE PRODUCTS OPERATING LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-05-28","effective_on":null,"summary":"CLOSED notice of amendment citing 195.3(b)(23), 195.3(c)(2), 195.3(c)(3), 195.3(g)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195013m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195013m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195013m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420195013M","body":"Notice of Amendment involving ENTERPRISE PRODUCTS OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.3(b)(23),  195.3(c)(2),  195.3(c)(3),  195.3(g)(3). The case was opened on 2019-05-28 and is reported as closed as of 2019-05-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420195013M_Notice of Amendment_05282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195013M/420195013M_Notice%20of%20Amendment_05282019.pdf\n\n420195013M_Notice of Amendment_05282019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195013M/420195013M_Notice%20of%20Amendment_05282019_text.pdf\n\n420195013M_Notice of Amendment_05282019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 28, 2019\nGraham Bacon\nExecutive Vice President, Operations & Engineering\nEnterprise Products Operating LLC\n1100 Louisiana Street\nHouston, TX 77002\nCPF 4-2019-5013M\nDear Mr. Bacon:\nFrom January 22, 2018 through August 31, 2018, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nEnterprise Products Operating LLC’s (Enterprise) procedures for Integrity Management in Houston,\nTexas.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy found within Enterprise\nProducts Operating LLC’s plans or procedures, as described below:\n1. §195.3 What documents are incorporated by reference partly or wholly in this part?\n(b) American Petroleum Institute (API), 1220 L Street NW., Washington, DC 20005, and\nphone: 202-682-8000, Web site: http://api.org/.\n(23) API Standard 1163, “In-Line Inspection Systems Qualification” Second edition, April\n2013, (API Std 1163), IBR approved for §195.591.\n(c) ASME International (ASME), Two Park Avenue, New York, NY 10016, 800-843-2763\n(U.S/Canada), Web site: http://www.asme.org/.\n(2) ASME/ANSI B31G-1991 (Reaffirmed 2004), “Manual for Determining the Remaining\nStrength of Corroded Pipelines,” 2004, (ASME/ANSI B31G), IBR approved for\n§§195.452(h); 195.587; and 195.588(c).\n\n\n\n(3) ASME/ANSI B31.4-2006, “Pipeline Transportation Systems for Liquid Hydrocarbons\nand Other Liquids” October 20, 2006, (ASME/ANSI B31.4), IBR approved for §§195.110(a);\n195.452(h).\n(g) NACE International (NACE), 1440 South Creek Drive, Houston, TX 77084, phone: 281-\n228-6223 or 800-797-6223, Web site: http://www.nace.org/Publications/.\n(3) NACE SP0102-2010, “Standard Practice, Inline Inspection of Pipelines” revised March\n13, 2010, (NACE SP0102), IBR approved for §195.591.\nEnterprise’s written Integrity Management Procedures IM Procedure 4-01 Rev. A date 9/22/2017 and\nIM Procedure 4-02 Rev. A date 9/22/2017 were inadequate because they did not include the editions of\nthe recognized industry practices and standards that are incorporated by reference in §195.3.\nDuring the inspection Enterprise provided IM Procedure 4-01 Rev. A date 9/22/2017 (ILI DATA\nANALYSIS AND REPORTING PROCEDURE) Section 4.2 Industry References and IM Procedure 4-\n01 Rev. A date 9/22/2017 (ILI REPORT ANALYSIS PROCEDURE FOR HCAS) Section 3.2 Industry\nReferences. Both procedures included a list of all industry references, listed below, without the editions\nincorporated by reference in §195.3.\nAPI 1160 – Managing System Integrity for Hazardous Liquid Pipelines\nAPI 1163 – In-Line Inspection Systems Qualification Standard\nAPI 1176 – Recommended Practice for Assessment and Management of Cracking in Pipelines\nASME B31G – Manual for Determining the Remaining Strength of Corroded Pipelines\nASME B31.4 – 2006 Pipeline Transportation Systems for Liquid Hydrocarbons and Other Liquids\nASME B31.8S – Managing System Integrity of Gas Pipelines Responses To Integrity Assessments and\nMitigation (Repair And Prevention) – Section 7, Figure 4.\nASNT ILI-PQ – In-line Inspection Personnel Qualification and Certification\nNACE SP0102 – In-Line Inspection of Pipelines\nEnterprise submitted revisions to both IM Procedure 4-01 and 4-02 on May 14, 2019, updating the\nprocedures to include the references with the correct incorporated by reference date. No further revisions\nare necessary at this time.\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 part of\nthis 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 material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment 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 procedures,\nor a request for a hearing under §190.211. 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 Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and\nto issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures\nto my office within 30 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended procedures,\nthis enforcement action will be closed.\nIt is requested (not mandated) that Enterprise Products Operations, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Mary L. McDaniel, P.E., Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2019-5013M and, for each document you submit, please provide a copy in electronic format\nwhenever 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","truncated":false,"body_characters":6737}