{"operation":"document","citation":"CPF 42023028NOA","title":"TRUNKLINE GAS CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-03-03","effective_on":null,"summary":"CLOSED notice of amendment citing 192.481(b), 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023028noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023028noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42023028noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42023028NOA","body":"Notice of Amendment involving TRUNKLINE GAS CO. PHMSA's enforcement data identifies the cited regulations as 192.481(b),  192.605(b)(2). The case was opened on 2023-03-03 and is reported as closed as of 2024-05-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42023028NOA_Closure Letter_05302024_(22-239724).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023028NOA/42023028NOA_Closure%20Letter_05302024_(22-239724).pdf\n\n42023028NOA_Closure Letter_05302024_(22-239724)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023028NOA/42023028NOA_Closure%20Letter_05302024_(22-239724)_text.pdf\n\n42023028NOA_Notice of Amendment_03032023_(22-239724).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023028NOA/42023028NOA_Notice%20of%20Amendment_03032023_(22-239724).pdf\n\n42023028NOA_Notice of Amendment_03032023_(22-239724)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023028NOA/42023028NOA_Notice%20of%20Amendment_03032023_(22-239724)_text.pdf\n\n42023028NOA_Operator Response to Notice_03202023_(22-239724).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023028NOA/42023028NOA_Operator%20Response%20to%20Notice_03202023_(22-239724).pdf\n\n42023028NOA_Notice of Amendment_03032023_(22-239724)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL\nMarch 3, 2023\nEric Amundsen\nSenior Vice President, Operations\nTrunkline Gas Company\n1300 Main Street\nHouston, TX 77002\nCPF 4-2023-028-NOA\nDear Mr. Amundsen:\nFrom February 28 to August 25, 2022, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nTrunkline Gas Company’s (Trunkline) written procedures for controlling corrosion in Shaw, MS.\nBased on the inspection, PHMSA has identified the apparent inadequacies found within\nTrunkline’s procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following,\nif applicable, to provide safety during maintenance and operations.\n(1) . . . .\n(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of subpart I of this part.\n§ 192.481 Atmospheric corrosion control: Monitoring.\n(a) . . . .\n(b) During inspections the operator must give particular attention\nto pipe at soil-to-air interfaces, under thermal insulation, under\ndisbonded coatings, at pipe supports, in splash zones, at deck\npenetrations, and in spans over water.\n\n\n\nTrunkline’s written procedures for controlling corrosion were inadequate to assure safe operation\nof a pipeline facility in accordance with § 192.605(b)(2). Specifically, Trunkline’s atmospheric\ncorrosion inspection procedure, D.44 Atmospheric Corrosion Inspection, fails to require inspectors\nto give particular attention to pipe under disbonded coatings, as required by § 192.481(b). Section\n7.1 of this procedure instructs inspectors to inspect and give special attention “where damaged\ncoating is visible” but does not require inspectors to inspect underneath the damaged or disbonded\ncoating.\nTherefore, Trunkline’s written procedures for controlling corrosion were inadequate to assure safe\noperation of a pipeline facility in accordance with § 192.605(b)(2). Trunkline must revise its\nprocedures to specify that inspectors must inspect under disbonded coatings in accordance with\n§ 192.481(b).\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\na second 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 60 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 Trunkline Gas Company maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2023-028-NOA, and for each document you submit, please provide a copy in\nelectronic format whenever possible.\n\n\n\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Todd Nardozzi, Director Regulatory Compliance, todd.nardozzi@energytransfer.com\n\n42023028NOA_Closure Letter_05302024_(22-239724)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nMay 30, 2024\nThomas Long\nChief Executive Officer\nEnergy Transfer, LP\n8111 Westchester\nDallas, Texas 75225\nCPF 4-2023-028-NOA\nDear Mr. Long:\nFrom February 28, through August 25, 2022, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to chapter\n601 of 49 United States Code (U.S.C.), conducted an on-site pipeline safety inspection of\nTrunkline Gas Company, LLC’s (Trunkline) written procedures for controlling corrosion in Shaw,\nMississippi. As a result of the inspection, Trunkline was issued a Notice of Amendment (Notice)\non March 3, 2023, requiring amendment to its corrosion control procedure.\nTrunkline submitted its amended procedure on March 20, 2023, and its final amended procedure\nimplemented for company use on May 3, 2023. My staff reviewed the amended procedure, and\nit appears that the inadequacy outlined in this Notice has 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,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP,\ngreg.mcilwain@energytransfer.com\nEric Amundsen, Senior Vice President, Operations, Energy Transfer LP,\neric.Amundsen@energytransfer.com\nTodd Stamm, Senior Vice President, Operations, Energy Transfer LP,\ntodd.stamm@energytransfer.com\n\n\n\nJennifer Street, Senior Vice President, Operations Services, Energy Transfer LP,\njennifer.street@energytransfer.com\nKeegan Pieper, Assistant General Counsel, Energy Transfer LP,\nkeegan.pieper@energytransfer.com\nMatthew Stork, Vice President, Technical Services, Energy Transfer LP,\nmatthew.stork@energytransfer.com\nTodd Nardozzi, Director – DOT Compliance, Energy Transfer LP,\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director – DOT Compliance, Energy Transfer LP,\nsusie.sjulin@energytransfer.com","truncated":false,"body_characters":8252}