{"operation":"document","citation":"CPF 42021024NOA","title":"HOLLY ENERGY PARTNERS - OPERATING, L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-03-25","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.583(a), 195.583(b), 195.583(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021024noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021024noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021024noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021024NOA","body":"Notice of Amendment involving HOLLY ENERGY PARTNERS - OPERATING, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.583(a),  195.583(b),  195.583(c). The case was opened on 2021-03-25 and is reported as closed as of 2021-05-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021024NOA_Closure Letter_05112021_(20-172601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021024NOA/42021024NOA_Closure%20Letter_05112021_(20-172601).pdf\n\n42021024NOA_Closure Letter_05112021_(20-172601)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021024NOA/42021024NOA_Closure%20Letter_05112021_(20-172601)_text.pdf\n\n42021024NOA_Notice of Amendment_03252021_(20-172601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021024NOA/42021024NOA_Notice%20of%20Amendment_03252021_(20-172601).pdf\n\n42021024NOA_Notice of Amendment_03252021_(20-172601)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021024NOA/42021024NOA_Notice%20of%20Amendment_03252021_(20-172601)_text.pdf\n\n42021024NOA_Operator Response to Notice_04162021_(20-172601).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021024NOA/42021024NOA_Operator%20Response%20to%20Notice_04162021_(20-172601).pdf\n\n42021024NOA_Closure Letter_05112021_(20-172601)_text.pdf\n\nVIA ELECTRONIC MAIL TO: mark.cunningham@hollyenergy.com\nMay 11, 2021\nMark Cunningham\nSenior Vice President, Engineering & Technical Services\nHolly Energy Partners-Operating, L.P.\n2828 N Hardwood, Suite 1300\nDallas, Texas 75201\nCPF 4-2021-024 NOA\nDear Mr. Cunningham:\nFrom March 9, 2021 to September 25, 2020, a representatives of the Office of Pipeline Safety\n(OPS), Southwest Region, pursuant to Chapter 601 of 49 United States Code, conducted a pipeline\nsafety inspection of Holly Energy Partners-Operating, L.P.’s (HEP) operations and maintenance\nprocedures for its facilities in Utah, Texas, New Mexico, and Oklahoma via video teleconference.\nAs a result of the inspection, PHMSA issued a Notice of Amendment to HEP on March 25, 2021,\nwhich proposed amendments to its procedures.\nHEP submitted its amended procedures on April 16, 2021. PHMSA 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\ncc: Lori Coupland, Director, Compliance & EHS, Holly Energy,\nlori.coupland@hollyenergy.com\nBridgette Taylor, Pipeline Regulatory Manager, Holly Energy,\nbridgette.taylor@hollyenergy.com\n\n42021024NOA_Notice of Amendment_03252021_(20-172601)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nMarch 25, 2021\nMark Cunningham\nSenior Vice President of Operations\nHolly Energy Partners Operating, L.P.\n2828 North Harwood, Suite 1300\nDallas, Texas 75201\nCPF 4-2021-024-NOA\nDear Mr. Cunningham:\nFrom March 9, 2020 through September 25, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Holly Energy Partners-Operating, L.P.’s (HEP) operations and maintenance (O&M)\nprocedures for its facilities in Utah, Texas, New Mexico, and Oklahoma via video teleconference.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy found within HEP’s\nplans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a)…\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations.\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§ 195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\n\n\n\nIf the pipeline is\nlocated: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but with intervals not\nexceeding 39 months.\nOffshore At least once each calendar year, but with intervals not exceeding\n15 months.\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe\nsupports, in splash zones, at deck penetrations, and in spans over water.\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by §195.581.\nHEP’s written O&M procedure, HEP O&M-195.583 Monitoring Atmospheric Corrosion\nof its HEP-A-195.000 Pipeline Safety Manual (last reviewed by HEP on 5/22/2020), is\ninadequate because it does not provide guidance for how to monitor for atmospheric\ncorrosion as required by § 195.583. The HEP O&M-195.583 Monitoring Atmospheric\nCorrosion states, “The HEP Atmospheric Inspection Process shall be followed. (Refer to\nthe atmospheric Inspection process).” During the PHMSA inspection, HEP personnel\ninformed PHMSA representatives that the procedure was inaccurate and included a\ntypographical error. Specifically, HEP stated that it does not have a document called\n“atmospheric Inspection process.”\nAdditionally, HEP’s “Atmospheric Corrosion Form” in the O&M procedure contains a\nlegend section that is inadequate because it does not provide threshold guidance for the\n“good,” \"fair,\" and \"poor\" categories when recording an atmospheric corrosion inspection.\nHEP must amend its O&M procedures for monitoring atmospheric corrosion to include a\nprocess for conducting atmospheric inspections and provide guidelines in the “good,”\n\"fair,\" and \"poor\" categories to include clear thresholds for determining the grading of a\npipeline coating condition.\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).\n2\n\n\n\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 Holly Energy Partners-Operating, L.P. maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2021-024-NOA and, for each document you submit,\nplease 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\n3","truncated":false,"body_characters":8605}