{"operation":"document","citation":"CPF 42025008NOA","title":"SHELL PIPELINE CO., L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-12-02","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.571.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025008noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025008noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025008noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025008NOA","body":"Notice of Amendment involving SHELL PIPELINE CO., L.P.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.571. The case was opened on 2025-12-02 and is reported as closed as of 2026-02-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025008NOA_Closure Letter_02252026_(25-329710).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025008NOA/42025008NOA_Closure%20Letter_02252026_(25-329710).pdf\n\n42025008NOA_Closure Letter_02252026_(25-329710)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025008NOA/42025008NOA_Closure%20Letter_02252026_(25-329710)_text.pdf\n\n42025008NOA_Notice of Amendment_12022025_(25-329710).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025008NOA/42025008NOA_Notice%20of%20Amendment_12022025_(25-329710).pdf\n\n42025008NOA_Notice of Amendment_12022025_(25-329710)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025008NOA/42025008NOA_Notice%20of%20Amendment_12022025_(25-329710)_text.pdf\n\n42025008NOA_Operator Response to Notice_12192025_(25-329710).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025008NOA/42025008NOA_Operator%20Response%20to%20Notice_12192025_(25-329710).pdf\n\n42025008NOA_Notice of Amendment_12022025_(25-329710)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: sean.guillory@shell.com\nDecember 2, 2025\nSean Guillory\nPresident / Chief Executive Officer\nShell Pipeline Company, L.P.\nWoodcreek Building A, 4th Floor\n150 N. Dairy Ashford Rd\nHouston, Texas 77079\nCPF 4-2025-008-NOA\nDear Mr. Guillory:\nFrom February 24 through June 13, 2025, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected Shell Pipeline Company L.P.’s (SPLC) Corrosion Control\nInspection and Maintenance Manual in Houston, Texas.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within SPLC’s\nplans or procedures. The item inspected and the inadequacy is described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(c) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the\nfollowing to provide safety during maintenance and normal\noperations:\n(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in\naccordance with each of the requirements of this subpart and\nsubpart H of this part.\n§ 195.571 What criteria must I use to determine the adequacy of\ncathodic protection?\n\n\n\nCathodic protection required by this Subpart must comply with one or\nmore of the applicable criteria and other considerations for cathodic\nprotection contained in paragraphs 6.2 and 6.3 of NACE SP 0169\n(incorporated by reference, see § 195.3).\nSPLC’s written procedures for conducting operations and maintenance activities, specifically\ncorrosion control, were inadequate to provide for safe operation of a pipeline facility in accordance\nwith § 195.402(c)(3). Specifically, SPLC’s Corrosion Control Inspection and Maintenance\nManual (09/01/2024), and SPLC’s 27TG-007 Field Testing on Cathodically Protected Pipelines\nand Tanks (05/2024), procedures are too general and lack detailed guidance on calculating and\napplying the target potential to determine the adequacy of cathodic protection in situations where\ncurrent on the pipeline cannot be interrupted, in accordance with § 195.571.\nSection 5.4.1 of 27TG-007 Field Testing on Cathodically Protected Pipelines and Tanks states\nthat for measuring structure-to-electrolyte potentials to determine the adequacy of cathodic\nprotection, the measured potential “may be either a direct measurement of the polarized potential\nor a current applied potential. Interpretation of the current-applied measurement requires\nconsideration of the significance of voltage drops in the earth and metallic paths.” Paragraph 2 of\nSection 5.4.1 of 27TG-007 further states that “there are situations where all the current on the\npipeline may not be interrupted. In these cases, the IR must be accounted for in the measurement.\nThe most common application of this is with the use of a Target Potential. An interrupted survey\nis taken on average of every 3 years and used to calculate what the potential shift would be required\nto maintain the -850 polarized potential criterion.” The procedure provides neither a definition for\nthe term “target potential” nor a methodology or process for calculating the target potential, which\nis used to measure structure-to-electrolyte potential when current to the pipeline cannot be\ninterrupted.\nTherefore, PHMSA proposes that SPLC revise its manual of written procedures to include the\ndefinition of a target potential, as well as specific actions for calculating and applying target\npotentials when measuring current applied structure-to-electrolyte potentials.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 CFR § 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 SPLC maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n4-2025-008-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Deborah Price, Integrity and Regulatory Services Manager, Shell Pipeline Company,\nL.P., deborah.price@shell.com\n3\n\n42025008NOA_Closure Letter_02252026_(25-329710)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration VIA ELECTRONIC MAIL TO: sean.guillory@shell.com\nFebruary 25, 2026\nSean Guillory\nPresident/Chief Executive Officer\nShell Pipeline Company, L.P.\nWoodcreek Building A, 4th Floor\n150 N. Dairy Ashford Rd.,\nHouston, Texas 77079\n8701 S. Gessner, Suite 630\nHouston TX 77074\nCPF 4-2025-008-NOA\nDear Mr. Guillory:\nFrom February 24 through June 13, 2025, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), inspected Shell Pipeline Company L.P.’s (SPLC) Corrosion Control\nInspection and Maintenance Manual in Houston, Texas.\nAs a result of the inspection, on December 2, 2025, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), issued to Shell Pipeline Company,\nL.P., a Notice of Amendment in the above-referenced case.\nOn January 20, 2026, Shell Pipeline Company, L.P., submitted its amended procedures. My staff\nreviewed the amended procedures, and it appears that the inadequacy outlined in this Notice of\nAmendment has been corrected.\nThis letter is to inform you that no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Deborah Price, Integrity and Regulatory Services Manager, Shell Pipeline Company,\nL.P., deborah.price@shell.com","truncated":false,"body_characters":9368}