{"operation":"document","citation":"CPF 42021014NOA","title":"EASTON ENERGY PIPELINES LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-18","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.52(a), 195.575(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021014noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021014noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021014noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021014NOA","body":"Notice of Amendment involving EASTON ENERGY PIPELINES LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.52(a),  195.575(a). The case was opened on 2021-03-18 and is reported as closed as of 2021-06-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021014NOA_Closure Letter_06112021_(20-187765).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Closure%20Letter_06112021_(20-187765).pdf\n\n42021014NOA_Closure Letter_06112021_(20-187765)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Closure%20Letter_06112021_(20-187765)_text.pdf\n\n42021014NOA_Notice of Amendment_03182021_(20-187765).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Notice%20of%20Amendment_03182021_(20-187765).pdf\n\n42021014NOA_Notice of Amendment_03182021_(20-187765)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Notice%20of%20Amendment_03182021_(20-187765)_text.pdf\n\n42021014NOA_Operator Response to Notice_04052021_(20-187765).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Operator%20Response%20to%20Notice_04052021_(20-187765).pdf\n\n42021014NOA_Closure Letter_06112021_(20-187765)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nJune 11, 2021\nJoel McComas\nPresident and Chief Executive Officer\nEaston Energy Pipelines LLC\n15375 Memorial Drive, Suite 850\nHouston, Texas 77079\nCPF 4-2021-014-NOA\nDear Mr. McComas:\nFrom August 10, 2020 through October 7, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Easton Energy Pipelines LLC’s (Easton) Ocelot Energy Liquids LPG & HVL\npipeline system, which runs from Iowa, Louisiana to Orange, Texas. As a result of the inspection,\nPHMSA issued a Notice of Amendment to Easton on March 18, 2021, which required amendments\nto its procedures.\nOn April 5, 2021, Easton submitted its amended procedures and after receiving PHMSA’s\nfeedback, provided an additional amended copy of the procedures on May 14, 2021. PHMSA\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\n\n42021014NOA_Notice of Amendment_03182021_(20-187765)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nMarch 18, 2021\nJoel McComas\nPresident and Chief Executive Officer\nEaston Energy Pipelines LLC\n15375 Memorial Drive, Suite 850\nHouston, Texas 77079\nCPF 4-2021-014-NOA\nDear Mr. McComas:\nFrom August 10, 2020 through October 7, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Easton Energy Pipelines LLC’s (Easton) Ocelot Energy Liquids LPG & HVL\npipeline system, which runs from Iowa, Louisiana to Orange, Texas, via video teleconference.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nEaston’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 insure 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§ 195.420 Valve maintenance.\n(a) Each operator shall maintain each valve that is necessary for the safe operation of\nits pipeline systems in good working order at all times.\n\n\n\nEaston’s procedure for the Inspection of Mainline Valves Procedure P-195.420, Section II,\n“Valve Inspection” is inadequate to ensure the safe operation of the pipeline. Specifically,\nthe procedure does not include a definition for “follow up work” and limits the valves that\nrequire this follow up work to those that “can only be operated with great difficulty or clearly\nin need of repair.”\nThe term “follow up work,” as used in the procedure, does not provide enough detail to\ndetermine what actions are included, such as repairs or tracking. Additionally, limiting “in\ngood working condition” to valves that can only be operated with great difficulty or are in\nneed of repair as described in the procedure, instead of valves that are operating outside its\nrequired normal working conditions, does not ensure the safe operation of the pipeline.\nEaston’s Inspection of Mainline Valves Procedure P-195.420 must be amended to clarify the\nterm “follow up work” as used in the procedure. Furthermore, the procedure must be\namended to encompass all remedial conditions to ensure valves are in good working\ncondition rather than valves operated with great difficulty or are in need of repairs as is\ncurrently specified in the procedure.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General…\n§ 195.575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n(a) You must electrically isolate each buried or submerged pipeline from other\nmetallic structures, unless you electrically interconnect and cathodically protect the\npipeline and the other structures as a single unit.\nEaston’s written Corrosion Control Procedure P – 195.551 is inadequate because it does not\nto include provisions for carrying out the task of electrically isolating each buried or\nsubmerged pipeline from other metallic structures unless you electrically interconnect and\ncathodically protect the pipeline and the other structures as a single unit as required under §\n195.575(a). Easton could not identify a procedure in its manual of written procedures that\naddressed the provisions of this requirement.\nEaston’s Corrosion Control procedure must be amended to include a procedure for carrying\nout the task of electrical isolation as required under § 195.575(a).\n3. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General…\n§ 195.52 Immediate notice of certain accidents.\n(a) Notice requirements. At the earliest practicable moment following discovery, of a\n\n\n\nrelease of the hazardous liquid or carbon dioxide transported resulting in an event\ndescribed in § 195.50, but no later than one hour after confirmed discovery, the\noperator of the system must give notice, in accordance with paragraph (b) of this\nsection of any failure that: . . .\nEaston’s written procedure Telephonic Notice of Certain Accidents Procedure P – 195.52 is\ninadequate because it does not include the requirement for providing the notice required\nunder § 195.52(a) to report accidents no later than one hour after the confirmed discovery.\nThe procedure was amended during the inspection to include the requirement for providing\nnotice to the National Response Center no later than one hour after confirmed discovery of\nan accident. The required amendment has been made, and no further action is required.\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.\n\n\n\nIt is requested (not mandated) that Easton Energy Pipelines LLC maintains documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel P.E.,\nDirector, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 4-2021-014-NOA and, for each\ndocument you submit, please 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","truncated":false,"body_characters":10129}