{"operation":"document","citation":"CPF 420207005M","title":"CANTIUM. LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-06-09","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(13).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420207005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420207005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420207005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420207005M","body":"Notice of Amendment involving CANTIUM. LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(13). The case was opened on 2020-06-09 and is reported as closed as of 2020-11-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420207005M_Closure Letter_11172020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207005M/420207005M_Closure%20Letter_11172020.pdf\n\n420207005M_Closure Letter_11172020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207005M/420207005M_Closure%20Letter_11172020_text.pdf\n\n420207005M_Notice of Amendment_06092020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207005M/420207005M_Notice%20of%20Amendment_06092020.pdf\n\n420207005M_Notice of Amendment_06092020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207005M/420207005M_Notice%20of%20Amendment_06092020_text.pdf\n\n420207005M_Operator Response to Notice_09082020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207005M/420207005M_Operator%20Response%20to%20Notice_09082020.pdf\n\n420207005M_Notice of Amendment_06092020_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nJune 9, 2020\nRichard Kirkland\nChief Executive Officer\nCantium, LLC\n111 Park Place Drive, Suite 100\nCovington, Louisiana 70433\nCPF 4-2020-7005M\nDear Mr. Kirkland:\nOn August 26 - 30, 2019, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Cantium,\nLLC’s (Cantium) procedures for its facilities in Port Fourchon, Louisiana and the Gulf of Mexico.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCantium’s plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to ensure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\n2\nCantium’s written procedures for conducting normal operations and maintenance (O&M)\nactivities and emergencies were inadequate as they lacked detailed instructions necessary\nfor recording results of valve inspections and cathodic protection inspections.\nCantium’s O&M manual (Rev. 8/2019) section 9.8, Pressure Limiting Device Inspections,\ndetails the procedures for inspecting each pressure limiting station, relief device, pressure\nregulating station, and its associated equipment. Section 9.13, Safety Device Capacity\nReviews, details the procedures for reviewing and calculating the required capacity of each\nrelief device. Section 10.6.12, Cathodic Protection Survey, details the procedures for\nreporting results of survey data for a pipeline or segment of line. The procedures require\nthe use of specific forms (Form-4(a) Pressure Limiting Device Inspection, For-6 Cathodic\nProtection Survey report) as the record of the completed inspection.\nAt the time of the inspection, Cantium provided inspection results on forms not specified\nin its written procedures.\nCantium must amend its procedures to include any additional methods used to record the\nresults of required inspections other than the forms listed in its procedures.\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\nmaintenance and normal operations:\n(13) Periodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and taking\ncorrective action where deficiencies are found.\nCantium’s written procedures for conducting normal operations and maintenance activities\nwere inadequate as they provide insufficient requirements to ensure that the procedures\nwill be reviewed for effectiveness on a regular basis.\nCantium’s O&M manual section 1.9 Review of Personnel Performance requires a periodic\nreview of the performance of normal O&M procedures conducted by Cantium personnel\nand/or contractors to determine the effectiveness of its procedures. Cantium defines\nperiodically as “Recommended in combination with Operator Qualification evaluations,\nafter the occurrence of any AOC, SRC, or emergency, and anytime significant procedures\nwithin this manual are changed,” however it does not provide a defined schedule for such\nreviews.\nCantium must revise its procedure to provide specific timelines for periodic reviews on a\nregularly scheduled basis.\n\n\n\n3\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 Cantium, LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Mary McDaniel, Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2020-7005M and, for each document you submit, please provide a copy in\nelectronic 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\n\n420207005M_Closure Letter_11172020_text.pdf\n\nELECTRONIC MAIL\nNovember 17, 2020\nRichard A. Kirkland\nChief Executive Officer\nCantium, LLC\n111 Park Place Drive, Suite 100\nCovington, Louisiana 70433\nCPF 4-2020-7005M\nDear Mr. Kirkland:\nOn August 26 - 30, 2019, a representatives of the Office of Pipeline Safety (OPS), Southwest\nRegion, pursuant to Chapter 601 of 49 United States Code, conducted a pipeline safety inspection\nof Cantium, LLC’s for its facilities and records in Port Fourchon, Louisiana and the Gulf of\nMexico. As a result of the inspection, Cantium was issued a Notice of Amendment on June 9,\n2020, which proposed amendment of your procedures.\nCantium submitted its amended procedures on September 8, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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":8671}