EASTON ENERGY PIPELINES LLC — Notice of Amendment

party submissionOfficial PDF42021014NOA_Operator Response to Notice_04052021_(20-187765).pdf#

42021014NOA_Closure Letter_06112021_(20-187765)_text.pdf, page 1Official PDFELECTRONIC MAIL - RETURN RECEIPT REQUESTED June 11, 2021 Joel McComas President and Chief Executive Officer Easton Energy Pipelines LLC 15375 Memorial Drive, Suite 850 Houston, Texas 77079 CPF 4-2021-014-NOA Dear Mr. McComas: From August 10, 2020 through October 7, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Easton Energy Pipelines LLC’s (Easton) Ocelot Energy Liquids LPG & HVL pipeline system, which runs from Iowa, Louisiana to Orange, Texas. As a result of the inspection, PHMSA issued a Notice of Amendment to Easton on March 18, 2021, which required amendments to its procedures. On April 5, 2021, Easton submitted its amended procedures and after receiving PHMSA’s feedback, provided an additional amended copy of the procedures on May 14, 2021. PHMSA reviewed the amended procedures, and it appears that the inadequacies outlined in this 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#

42021014NOA_Notice of Amendment_03182021_(20-187765)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT ELECTRONIC MAIL - RETURN RECEIPT REQUESTED March 18, 2021 Joel McComas President and Chief Executive Officer Easton Energy Pipelines LLC 15375 Memorial Drive, Suite 850 Houston, Texas 77079 CPF 4-2021-014-NOA Dear Mr. McComas: From August 10, 2020 through October 7, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Easton Energy Pipelines LLC’s (Easton) Ocelot Energy Liquids LPG & HVL pipeline system, which runs from Iowa, Louisiana to Orange, Texas, via video teleconference. As a result of the inspection, PHMSA has identified the apparent inadequacies found within Easton’s plans or procedures, as described below: 1. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. § 195.420 Valve maintenance. (a) Each operator shall maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times.#

42021014NOA_Notice of Amendment_03182021_(20-187765)_text.pdf, page 2Easton’s procedure for the Inspection of Mainline Valves Procedure P-195.420, Section II, “Valve Inspection” is inadequate to ensure the safe operation of the pipeline. Specifically, the procedure does not include a definition for “follow up work” and limits the valves that require this follow up work to those that “can only be operated with great difficulty or clearly in need of repair.” The term “follow up work,” as used in the procedure, does not provide enough detail to determine what actions are included, such as repairs or tracking. Additionally, limiting “in good working condition” to valves that can only be operated with great difficulty or are in need of repair as described in the procedure, instead of valves that are operating outside its required normal working conditions, does not ensure the safe operation of the pipeline. Easton’s Inspection of Mainline Valves Procedure P-195.420 must be amended to clarify the term “follow up work” as used in the procedure. Furthermore, the procedure must be amended to encompass all remedial conditions to ensure valves are in good working condition rather than valves operated with great difficulty or are in need of repairs as is currently specified in the procedure. 2. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General… § 195.575 Which facilities must I electrically isolate and what inspections, tests, and safeguards are required? (a) You must electrically isolate each buried or submerged pipeline from other metallic structures, unless you electrically interconnect and cathodically protect the pipeline and the other structures as a single unit. Easton’s written Corrosion Control Procedure P – 195.551 is inadequate because it does not to include provisions for carrying out the task of electrically isolating each buried or submerged pipeline from other metallic structures unless you electrically interconnect and cathodically protect the pipeline and the other structures as a single unit as required under § 195.575(a). Easton could not identify a procedure in its manual of written procedures that addressed the provisions of this requirement. Easton’s Corrosion Control procedure must be amended to include a procedure for carrying out the task of electrical isolation as required under § 195.575(a). 3. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General… § 195.52 Immediate notice of certain accidents. (a) Notice requirements. At the earliest practicable moment following discovery, of a#

42021014NOA_Notice of Amendment_03182021_(20-187765)_text.pdf, page 3release of the hazardous liquid or carbon dioxide transported resulting in an event described in § 195.50, but no later than one hour after confirmed discovery, the operator of the system must give notice, in accordance with paragraph (b) of this section of any failure that: . . . Easton’s written procedure Telephonic Notice of Certain Accidents Procedure P – 195.52 is inadequate because it does not include the requirement for providing the notice required under § 195.52(a) to report accidents no later than one hour after the confirmed discovery. The procedure was amended during the inspection to include the requirement for providing notice to the National Response Center no later than one hour after confirmed discovery of an accident. The required amendment has been made, and no further action is required. 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.#

42021014NOA_Notice of Amendment_03182021_(20-187765)_text.pdf, page 4It is requested (not mandated) that Easton Energy Pipelines LLC maintains 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 4-2021-014-NOA 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#