{"operation":"document","citation":"CPF 520075014M","title":"CENEX PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-04-04","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(1), 195.452(f)(2), 195.452(f)(3), 195.452(f)(4), 195.452(f)(5), 195.452(f)(6), 195.452(f)(8).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075014m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075014m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075014m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520075014M","body":"Notice of Amendment involving CENEX PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(1),  195.452(f)(2),  195.452(f)(3),  195.452(f)(4),  195.452(f)(5),  195.452(f)(6),  195.452(f)(8). The case was opened on 2007-04-04 and is reported as closed as of 2008-11-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520075014M_Notice Letter_04042007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075014M/520075014M_Notice%20Letter_04042007.pdf\n\n520075014M_operator response to notice_11152007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075014M/520075014M_operator%20response%20to%20notice_11152007.pdf\n\n520075014M_Notice Letter_04042007.pdf\n\n@\nU.S. Deponment\nof Tronsporfollon\nPlp.tlno ond\nHozorlout mqil.dab Sctfify\nAdmlnbrrotlon\n123{n W. Dakota Ave., Suite 110\nLakewood, CO g)228\nNOTICE OF AMENDMENT\nCERTIFIEI} MAIL . RETURN RECEIPT REOTIESTED\nApril4,2007\nMr. Dan Knepper\nVP Energy Operations\nCHS Inc.\n803 Highway 212 South\nLaurel, MT 59044\nSnNr ro CouplrRNcr Rsgsrny\nHardcopy - Electronicailyy'\n# of Copiesl toatet/llto'l\ncPF 5-2007-5{114M\nDear Mr. Knepper:\nOn August 28 through 31,2006 a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nCHS Inc.'s procedures for integrity management in Laurel, Montana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCHS's plans or procedures, as described below:\n1. 5195.452 Pipeline integrity management in high consequence arees.\n$ rilhat are the elements of an integrity management program? An integrity\nmanagement program begrns with the initial framework An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area;\n(2) A baseline assessment plan meeting the requirements of paragraph (c)\nof this section;\n(3) An analysis that integrates all available information about the integrity\n\n\n\nof the entire pipeline and the consequences of a failure (see paragraph (g\nof this section);\n(4) Criteria for remedial actions to address integrity issues raised by the\nassessment methods and information analysis (see paragraph (h) of this\nsection);\n(5) A continual process of assessment and evaluation to maintain a\npipeline's integrity (see paragraph (i) of this section);\n(6) Identilication of prwentive and mitigative measures to protect the high\nconsequence area (see paragraph (i) ofthis section);\n(8) A prlocess for review of integrity assessment results and information\nanalysis by a person qualilied to evaluate the results and information (see\nparagraph (hX2) of this section).\no Item 1.A: $1es.4s2(D(r)\nCHS's Integrity Management Program (IMP) does not contain enough detail regarding the\napplication of airborne toxicity buffers in determining which pipeline segments could affect\nHCAs.\no ltem 1.8: Sl95 452(0(1)\nCHS's IMP does not contain the process used by CHS to analyze the overland flow of liquids\nreleased from potential pipeline failtres. This process must have sufficient detail to ensure\nrepeatability including the assumptions used for spill volume, the buffer size and the effects of\ntopography.\no Item l.C: 9r95.452(fxl)\nCHS's IMP does not document the technical justification used for excluding tank volumes in\ntheir detennination of facilifies and adjacent piping that may impact HCAs.\nr Item l.D: gl95 452(fX2)\nCHS's Baseline Assessment Plan has no provisions for assessing an each pipeline segment's\nsusceptibility to SCC. CHS stated thal they address SCC threats by performing magnetic\nparticle testing for all excavations involving repairs to dents and gouge type anomalies.\no Item l.E: 9195 452(fX3)\nCHS's IMP does not contain a risk analysis that specifically addresses facilities and their\nuique attributes.\nr Item l.F: 5195 452(fX4)\nCHS's IMP definition of \"discovery\" does not define a \"discovery\" process or provide\nrequirements regarding how much time can be taken to review information and declare\n\n\n\n\"discovery\" following receipt of vendor reports or other information that includes evidence of\nanomalies.\no ltem 1.G: 5195 452(D(4)\nCHS's IMP does not speciS that \"immediate\" repair conditions must be repaired as soon .ui\npossible.\no ltem l.If: Sl95 452(fX5)\nCHS's IMP defaults to five years for all reassessments without any justification.\nr ltem l.I: Sl95 452(D(5)\nCHS's IMP does not contain a process for 1) examining causes of incidents, leaks, and near-\nmisses, 2) making recommendations for corrective actions, and 3) providing those lessons\nlearned to appropriate company employees.\no Item 1.J: 5195 452(fX6)\nCHS's IMP does not describe a process for performing a leak detection evaluation as required\nby $195.452(iX3). It is expected that such a leak detection process would include a\ndocumented basis for all operator reactions credited in the leak detection evaluation.\no ltem l.K: 5195 452(fX6)\nCHS's IMP does not describe a process for evaluating the need for additional EFRDs\nincluding consideration of the factors required bV 195.a52(i)(a).\no ltem l.L: Sl95 452(D(8)\nAppendix I of CHS's IMP specifies that anomalies selected for validafion are chosen from\nanomalies in the \"Marcimum, Minimum, and Midrange\" (two from each). However, there was\nno definition regarding what these ranges represent.\no Item 1.M: gl95 452(fX8)\nCHS's IMP discusses how assessment results are integrated with pertinent pipeline risk-\ncondition information to discover integrity issues that might not be evident from the\nassessment data done. However, the IMP does not provide details and specificity regarding\nhow this analysis is to be performed.\no Item l.N: gf95 452(fX8)\nCHS's IMP does not contain a requirernent to document that an effective corrosion control\n\n\n\nprogmm is in place and that corrosion control is being effectively applied to segments where\nhydro tests are performed as assessments.\nResnonse to this Notice\nThis Notice is provided pnrsuant to 49 U.S.C. $ 60108(a) and 49 C.F.R. $ 190.237. Enclosed\nas part of this Notice is a document entitled Respowe Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 5520), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. $ 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence conceming this matter, please referto CPF 5-2007-5014M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nrual\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Optionsfor Pipeline Operators in Compliance Proceedings\noc: PHP-60 Compliance Registry\nPHP-500 G. Davis (#Il7712)","truncated":false,"body_characters":8396}