# EASTON ENERGY PIPELINES LLC — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

42021014NOA_Closure Letter_06112021_(20-187765).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Closure%20Letter_06112021_(20-187765).pdf

42021014NOA_Closure Letter_06112021_(20-187765)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Closure%20Letter_06112021_(20-187765)_text.pdf

42021014NOA_Notice of Amendment_03182021_(20-187765).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021014NOA/42021014NOA_Notice%20of%20Amendment_03182021_(20-187765).pdf

42021014NOA_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

42021014NOA_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

42021014NOA_Closure Letter_06112021_(20-187765)_text.pdf

ELECTRONIC 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

NOTICE 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.



Easton’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



release 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.



It 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
- **truncated:** false
- **body characters:** 10129