OMIMEX CANADA, LTD. — Notice of Amendment

party submissionOfficial PDF520075005M_operator response_10052007.pdf#

520071005M_Notice of Amendment_05142007.pdf, page 1Official PDF- t - , \t U.S. Deporfment of Tronsportotion Plp.llne ond tlozonlour morrlatt Admlnbtfofilon 12300w. DakotaAve., suib 110 Lakewood, CO 80228 Sot fy Snxr m ConarurANcE Rscnmy Hardcopy- Elechonicaly\ # of CopiesLl pateS-lto? NOTICE OF AMEI\DMENT CERTIX'IED MAIL - RETT]RN RECEIPT REOT]ESTED May 14,2007 Mr. Clark Storms Vice President Land and Legal Omimex Canad4 LTD 2001 Beach Street" Suite 810 Fort Worth, TX 76103 cPx' 5-2007-1005M Dear Mr. Storms: On February 26 to March 1, 2007, a reprresentative of the Pipeline and Hazardous Materials Safety Administation @HMSA) pursuant to Chapter 601 of 49 United States Code inspected Omimex procedures for the integrity management program at your Battle Creek compressor station in Montana. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Omimex's integnty management plan, as described below: 1. $192.911 What are the elements of an integrity management program? An operatorrs initial integrity management program begins with a framework (see $ 192.907) and evolves into a more detailed and comprehensive integrity management program, as information is gained and incorporated into the program. An operator must make continual improvements to its program. The initial program framework and subsequent program must, at minimum, contain the following elements. (When indicated, refer to ASME/ANSI831.85 (ibr, see $ 192.7) for more detailed information on the listed element.)#

520071005M_Notice of Amendment_05142007.pdf, page 22. (p) A pnocess for identilication and assessment of newly-identified high consequeuce areas. (See $ 192.905 and $ 192.921.) Item 1.A: $r92.905(e) and $192.905(b) Omimex Integnty Management Programos (IMP) process for identiffing new high consequence areas (HCAs) does not have sufficient detail either under; Section A- Identification of HCAs or Section G-Process for Identification . Item 1.B: $f92.905(c) Omimex's IMP does not contain a description and time line for actions to be taken as soon as an HCA is identified. Item 1.C: 5192.903 Omimex's IMP does not state how the Potential Impact Radius (PIR) is to be applied to the pipeline to determine if a pipeline has an HCA. $192.91f What are the elements of an integrity management program? (i) A performance plan as outlined in ASME/AII{SI831.85, section 9 that includes performance measures meeting the requirements of $ 192.945 o ltem 2.A: $f92.945 Though Omimex has not yet found there to be any HCAs along their pipeline right-of- way, their IMP does not have a process for submitting semi-annual reviews to reflect that there are no HCAs along their pipeline. Additionally, Omimex's IMP does not have a process for submitting the four overall performance measures for HCAs specified in ASME/ANSI B3l.8S, section 9.4, and the specific measures for each identified threat specified in ASME/ANSI 83l.8S, Appendix A, if they do establish there is an HCA along a pipeline segment. Resoonse to this Notice This Notice is provided pursuant to 49 U.S.C. $ 60108(a) and 49 C.F.R. $ 190.237. Enclosed as part of this Notice is a document entitled Response Optionsfor 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 qualifu for confidential teatment redacted and an explanation ofwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). 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#

520071005M_Notice of Amendment_05142007.pdf, page 3Notice and authorizes the Associate Administator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, yow 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. $ 190.237). If you are not contesting this Notice, $/e propose that you submit your amendd procedures to my office within 30 days of receipt of this Notice. This period may be extended by witten request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. In correspondence concerning this mafter, please refer to CPF 5-2007-1005M and, for each document you submit, please provide a copy in electonic format whenever possible. ru% Directoq Westem Region Pipeline and Hazardous Materials Safety Adminishation Enclosnre: Response Options far Pipeline Operators in Compliance Proceedings cc: PIIP-60 Compliance Registry PHP-500 G. Davis (#119073)#