{"operation":"document","citation":"CPF 520075015","title":"CENEX PIPELINE LLC — Notice of Probable Violation","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 probable violation citing 195.452(i)(1), 195.452(i)(3), 195.452(i)(4), 195.452(j)(2), 195.452(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520075015","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520075015","body":"Notice of Probable Violation involving CENEX PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(i)(1),  195.452(i)(3),  195.452(i)(4),  195.452(j)(2),  195.452(k). The case was opened on 2007-04-04 and is reported as closed as of 2009-05-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520075015_FinalOrder_08262008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075015/520075015_FinalOrder_08262008.pdf\n\n520075015_finalorder_08262008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075015/520075015_finalorder_08262008_text.pdf\n\n520075015_notice letter_04042007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075015/520075015_notice%20letter_04042007.pdf\n\n520075015_notice letter_04042007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075015/520075015_notice%20letter_04042007_text.pdf\n\n520075015_Operator_Response_to_Notice_and_Request_for_Extension_05012007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075015/520075015_Operator_Response_to_Notice_and_Request_for_Extension_05012007.pdf\n\n520075015_finalorder_08262008_text.pdf\n\nU S Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nt 200 New Jersey Ave S E\nWashington DC 20590\nG P6 2008\nMr. Dan Knepper\nVice President, Energy Operations\nCHS Inc.\nPO Box 909\nLaurel, MT 59044\nRe: CPF No. 5-2007-5015\nDear Mr. Knepper:\nEnclosed is the Final Order issued in the above-referenced case. It makes findings of violation\nand specifies actions that need to be taken by CHS Inc, to comply with the PHMSA pipeline\nsafety regulations. When the terms of the Compliance Order have been completed, as\ndetermined by the Director, Western Region, this enforcement action will be closed. Your receipt\nof this Final Order constitutes service of that document under 49 C. F, R ) 190. 5.\nThank you for your cooperation in this matter\nSmcerely,\nssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Chris Hoidal, P. E, ,\nWestern Region Director, PHMSA\nCERTIFIED MAIL — RETURN RECEIPT RE UESTED\n\n\n\nU. S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D. C. 20590\nIn the Matter of\nCHS Inc.\n,\nRespondent.\nCPF No. 5-2007-5015\nFINAL ORDER\nOn August 28 - 31, 2006, pursuant to 49 U. S. C. ( 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration, Office of Pipeline Safety (OPS), conducted an on-\nsite pipeline safety mspection of CHS Inc. 's (CHS or Respondent) Integrity Management\nProgram (IMP) in Laurel, Montana CHS operates approximately 1, 086 miles of hazardous\nliquid pipelines in Montana and North Dakota, much of which runs through environmentally\nsensitive areas, As a result of the mspection, the Director, Western Region, OPS (Director),\nissued to Respondent, by letter dated April 4, 2007, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C. F. R, $ 190. 207, the Notice proposed\nfinding that Respondent had violated various provisions of 49 C. F. R. $195. 452 and ordering\nRespondent to take certain measures to correct the alleged violations\nRespondent responded to the Notice by letter dated May 1, 2007 (Response). Respondent did\nnot contest the allegations of violations and indicated that it intended to complete the work\nidentified in the proposed Compliance Order by November 1, 2007. Respondent further\nrequested that in the event a Final Order should be issued prior to that date, an extension be\ngranted for Respondent to complete the work. As of the date hereof, Respondent has not\nprovided documentation showing completion of the work identified in the Compliance Order. In\nits Response, CHS did not request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nIn its Response, Respondent did not contest the allegations in the Notice that it violated\n49 C. F. R. Part 195, as follows'\nItem 1: Item 1 of the Notice alleged that Respondent violated various provisions of 49 C. F. R. $\n195. 452(i), which states, in relevant part:\ng 195. 452 Pipeline integrity management in high consequence areas.\n(a) \"\n(i) 8'hat preventive and mitigative measures must an operator take to protect\nthe high consequence area?\n\n\n\n(1) General requirements An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high\nconsequence area. These measures include conducting a risk analysis of the\npipeline segment to identify additional actions to enhance public safety or\nenvironmental protection. Such actions may include, but are not limited to,\nimplementing damage prevention best practices, better monitoring of cathodic\nprotection where corrosion is a concern, establishing shorter inspection intervals,\ninstalling EFRDs on the pipeline segment, modifying the systems that monitor\npressure and detect leaks, providing additional traming to personnel on response\nprocedures, conducting drills with local emergency responders and adopting other\nmanagement controls. . . .\n(3) Leak detection An operator must have a means to detect leaks on its\npipeline system. An operator must evaluate the capability of its leak detection\nmeans and modify, as necessary, to protect the high consequence area. An\noperator's evaluation must, at least, consider the following factors length and\nsize of the pipeline, type of product carried, the pipeline's proximity to the high\nconsequence area, the swiftness of leak detection, location of nearest response\npersonnel, leak history, and risk assessment results.\n(4) Emergency Flow Restrtcting Devices (EFRD) If an operator determines\nthat an EFRD is needed on a pipeline segment to protect a high consequence area\nin the event of a hazardous liquid pipeline release, an operator must install the\nEFRD. In making this determmation, an operator must, at least, consider the\nfollowing factors — the swiftness of leak detection and pipeline shutdown\ncapabilities, the type of commodity carried, the rate of potential leakage, the\nvolume that can be released, topography or pipeline profile, the potential for\nignition, proximity to power sources, location of nearest response personnel,\nspecific terrain between the pipeline segment and the high consequence area, and\nbenefits expected by reducing the spill size.\nItem 1(A): Item 1(A) of the Notice alleged that, as of the date of the inspection, Respondent had\nviolated ) 195 452(i)(1) by failing to take measures to prevent and mitigate the consequences of\na pipeline failure that could affect a high consequence area. Specifically, the Notice alleged that\nRespondent failed to conduct a risk analysis of its pipeline segments to identify additional\nactions to enhance public safety or environmental protection. CHS did not contest this allegation.\nAccordingly, based upon a review of the record, I find that Respondent violated 49 C. F. R. $\n194 452(i)(1)) by failing to have completed a risk analysis of its pipeline segments.\nItem 1(B): Item 1(B) of the Notice alleged that Respondent had violated 49 C. F. R. $\n195. 452(i)(3), as stated above, by failmg to complete, as of the date of the inspection, an\nevaluation of the leak detection capability of its pipeline system\nIn its Response, Respondent did not contest this allegation but indicated that it intended to\ncomply with the actions required under the proposed Compliance Order by November 1, 2007.\nAccordingly, based upon a review of the record, I find that Respondent violated 49 C. F R\n)195. 452(i)(3) by failing to have completed, as of the date of the inspection, an evaluation of the\nleak detection capabilities of its pipeline system.\n\n\n\nItem 1(C): Item 1(C) of the Notice alleged that Respondent had violated 49 C. F. R. ) 195. 452\n(i)(4), as stated above, by failing to complete, as of the date of the inspection, an evaluation to\ndetermine if there were a need for additional EFRDs on any segment of its pipeline system in\norder to protect a high consequence area in the event of a release. In its Response, CHS did not\ncontest the allegation but indicated that it intended to comply with the actions required under the\nproposed Compliance Order by November 1, 2007. Accordingly, based upon a review of the\nrecord, I find that Respondent violated 49 C. F. R. $195 452(i)(4) by failing to have completed, as\nof the date of the inspection, an evaluation to determine if there were a need for additional\nEFRDs on any segment of its pipeline system.\nItem 2(A): Item 2(A) of the Notice alleged that Respondent violated 49 C. F. R $ 195. 452(j)(2),\nwhich states:\ng 195. 452 Pipeline integrity management in high consequence areas.\n(a) \"\n(j) What rs a continual process of evaluation and assessment to maintain a pipeline's\nintegrity?\n(1) General After completing the baseline integrity assessment, an operator must\ncontinue to assess the line pipe at specified intervals and periodically evaluate the\nintegrity of each pipeline segment that could affect a high consequence area.\n(2) Evaluation An operator must conduct a periodic evaluation as frequently\nas needed to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified in\nparagraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments. . . .\nThe Notice alleged that Respondent had violated ( 195 452(j)(2) by failing to conduct, as of the\ndate of the inspection, an annual evaluation of its pipeline system, as required by Article 7 1 of\nCHS' integrity management program. In its Response, Respondent did not contest the allegation\nbut indicated that it intended to comply with the actions required under the proposed Compliance\nOrder by November 1, 2007. Accordingly, based upon a review of the record, I find that\nRespondent violated 49 C. F. R. $195. 452(j)(2) by failmg to have conducted, as of the date of the\ninspection, a periodic evaluation of the integrity of its pipeline system, as required by Article 7. 1\nof Respondent's IMP.\nItem 3(A): Item 3(A) of the Notice alleged that Respondent violated 49 C. F R. ) 195. 452(k),\nwhich states:\nf 195. 452 Pipeline integrity management in high consequence areas.\n(a) \"~\n(f) What are the elements of an integrity management program~\nAn integrity management program begins with the initial framework.\nAn operator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity assessments, and other\nmaintenance and surveillance data, and evaluation of consequences of a failure on\nthe high consequence area An operator must include, at minimum, each of the\nfollowing elements in its written integrity management program:\n\n\n\n(1) \"\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection). . .\n(k) 8'hat methods to measure program effecttveness must be used~ An\noperator's program must include methods to measure whether the program is\neffective in assessing and evaluating the integrity of each pipeline segment and in\nprotectmg the high consequence areas. See Appendix C of this part for guidance\non methods that can be used to evaluate a program's effectiveness.\nThe Notice alleged that Respondent had violated 49 C. F. R. $ 195 452(k) by failing to conduct\nongoing evaluations of the effectiveness of its IMP in assessing and evaluating the integrity of\neach pipeline segment and in protecting high consequence areas. Specifically, it alleged that\nCHS had failed to conduct an annual evaluation of its IMP, as required under Article 9. 1 of such\nplan. In its Response, Respondent did not contest the allegation but indicated that it intended to\ncomply with the actions required under the proposed Compliance Order by November 1, 2007.\nAccordingly, based upon a review of the record, I find that Respondent violated 49 C. F. R.\n$195. 452(k) by failing to have conducted, as of the date of the inspection, periodic evaluations of\nthe effectiveness of its IMP in assessing and evaluating the integrity of each pipelme segment\nand in protecting high consequence areas.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken agamst Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1(A), 1(B), 1(C), 2(A), and 3(A)\nin the Notice for violations of 49 C. F. R. $( 195 452(i)(1, 3, and 4), 195. 452(j)(2), and\n195. 452(k). Under 49 U. S. C. ) 60118(a), each person who engages in the transportation of\nhazardous liquids, or who owns or operates a pipeline facility, is required to comply with the\napplicable safety standards established under Chapter 601 Pursuant to the authority of 49\nU, S. C. $ 60118(b) and 49 C. F. R. $ 190. 217, Respondent is ordered to take the following actions\nto ensure compliance with the pipeline safety regulations applicable to its operations\nWith respect to Notice Iteml(A) pertaining to preventive and mitigative\nmeasures, Respondent must perform a preventive and mitigative analysis, using a\nrisk analysis of its pipeline segments to identify additional actions to enhance\npublic safety or environmental protection. Such actions may include, but are not\nlimited to, implementing damage prevention best practices, improving monitoring\nof cathodic protection where corrosion is a concern, establishing shorter\ninspection intervals, installing EFRDs on pipeline segments, modifying systems\nthat monitor pressure and detect leaks, providing additional training to personnel\non response procedures, conducting drills with local emergency responders, and\nadopting other management controls.\nWith respect to Notice Item 1(B) pertaining to evaluation of leak detection\ncapabilities, Respondent must evaluate the capability of its leak detection methods\nand modify the methods, as necessary, to protect the high consequence areas.\nThis evaluation must, at least, consider the following factors: the length and size\n\n\n\nof the pipeline, the type of product transported, the proximity of the pipeline to\nhigh consequence areas, the swiftness of leak detection, the location of nearest\nresponse personnel, the pipeline's leak history, and the pipeline risk assessment\nresults.\nWith respect to Notice Item 1(C) pertaming to evaluatmg EFRDs, Respondent\nmust evaluate its EFRDs. This evaluation must, at least, consider the following\nfactors. the swiftness of leak detection and pipeline shutdown capabilities, the\ntype of commodity carried, the rate of potential leakage, the volume that can be\nreleased, the topography or pipeline profile, the potential for igmtion, the pipeline\nproximity to power sources, the location of nearest response personnel, the\nspecific terrain between the pipeline segment and the high consequence areas, and\nthe benefits expected by reducing the spill size. If Respondent determines that\nany pipeline segment requires an EFRD to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, Respondent must install the EFRD.\nWith respect to Notice Item 2(A) pertaining to periodic evaluations of integrity\ninformation, Respondent must conduct a periodic evaluation to ensure pipeline\nintegrity. This evaluation must consider the results of the baseline and periodic\nintegrity assessments, an information analysis as required under )195. 452(g),\ndecisions about remediation, and preventive and mitigative actions as required\nunder $195. 452(h) and (i). This analysis must also include the basis for\ndetermimng the frequency of future evaluations. Respondent must determine this\nfrequency according to the evaluation of risk factors specific to its pipeline,\nincluding the factors specified in paragraph (195 452(e).\nWith respect to Notice Item 3(A) pertaming to periodic evaluations of the\neffectiveness of an IMP, Respondent must evaluate its IMP's effectiveness in\nassessing and evaluating the integrity of each pipeline segment and in protecting\nhigh consequence areas,\nRespondent shall maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit them to the Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration, 12300\nW. Dakota Avenue, Suite 110, Lakewood, CO 80228 Costs shall be reported in\ntwo categories; 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses; and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure\nWithin 30 days of receipt of the Final Order, Respondent must complete the items\nlisted above and submit appropriate documentation showing their completion to\nthe Director, Western Region, Pipeline and Hazardous Materials Safety\nAdministration, 12300 W. Dakota Avenue, Suite 110, Lakewood, CO 80228.\n\n\n\nThe Director may grant an extension of time to comply with any of the items set forth above\nupon a written request timely submitted by the Respondent demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in administrative assessment of civil penalties not\nto exceed $100, 000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nUnder 49 C. F. R. $ 190. 215, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be received within 20 days of Respondent's receipt of this\nFinal Order and must contain a brief statement of the issue(s). The terms of the order, including\nany required corrective action, shall remain in full force and effect unless the Associate\nAd inistrator, upon request, grants a stay. The terms and conditions of this Final Order shall\neco e effective upon receipt.\ng6 p 6 2008\nDate Issued\nJ ffr D. iese\n'\nssoc ate A\ns rator\nipeline Safety\n\n520075015_notice letter_04042007_text.pdf\n\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF PROBABLK VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 4, 2007\nMr. Dan Knepper\nVP Energy Operations\nCHS Inc.\n803 Highway 212 South\nLaurel, MT 59044\nSENT TO COMPLIANCE REGISTRY\nHardcopy Electronical y +\n¹ of Copies'/ Date Of\nCPF 5-2007-5015\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\nyour integrity management program in Laurel, Montana.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n$195. 452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins 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(6) Identification of preventive and mitigative measures to protect the\nhigh consequence area (see paragraph (i) of this section);\n\n\n\n~ Item 1. A: $195. 452(i)(1)\nCHS stated at the time of this inspection that they had not completed any preventive\nand mitigative analysis on their pipeline system.\n~ Item 1. B: $195. 452(i)(3)\nCHS stated at the time of this inspection that they had not completed an evaluation of\nleak detection capability of their pipeline system. CHS stated that a leak detection\ncapability evaluation is ongoing and should be completed in 2007.\n~ Item 1. C: $195. 452(i)(4)\nCHS stated at the time of this inspection that they had not completed an evaluation to\ndetermine if there is a need for additional EFRDs.\n2. $195. 452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity assessments,\nand other maintenance and surveillance data, and evaluation of\nconsequences of a failure on the high consequence area. An operator must\ninclude, at minimum, each of the following elements in its written integrity\nmanagement program:\n(5) A continual process of assessment and evaluation to maintain a\npipeline's integrity (see paragraph (j) of this section);\n~ Item 2. A: $195. 452(j)(2)\nThough CHS's IM program Article 7. 1 calls for an annual evaluation of its pipeline\nsegments to assure pipeline integrity CHS stated at the time of this inspection that they\nhad not completed any such evaluations.\n3. $195. 452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity assessments,\nand other maintenance and surveillance data, and evaluation of\nconsequences of a failure on the high consequence area. An operator must\ninclude, at minimum, each of the following elements in its written integrity\n\n\n\nmanagement program:\n(7) Methods to measure the program's effectiveness (see paragraph\n(k) of this section);\n~ Item 3. A: $195. 452(k)\nThough CHS's IM program Article 9. 1 calls for an annual evaluation of its IM\nprogram's effectiveness CHS stated at the time of this inspection that they had not\nperformed any program evaluations.\nPro osed Com liance Order\nPursuant to 49 United States Code $ 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to CHS. Please refer to the Proposed\nCompliance Order that is enclosed and made a part of this Notice.\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Compliance Proceedings. Please refer to this document and note the response\noptions. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U. S. C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U. S. C. 552(b). If you do not\nrespond within 30 days of receipt of this Notice, this constitutes a waiver of your right to\ncontest the allegations in this Notice and authorizes the Associate Administrator for Pipeline\nSafety to find facts as alleged in this Notice without further notice to you and to issue a Final\nOrder.\nIn your correspondence on this matter, please refer to CPF 5-2007-5015 and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Davis (¹117712)\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code $ 6011S, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to CHS a Compliance Order incorporating the\nfollowing remedial requirements to ensure the compliance of CHS with the pipeline safety\nregulations:\nIn regard to Item Number 1. A. of the Notice pertaining to preventative and\nmitigative measures, CHS must perform a preventative and mitigative analysis\nusing their risk analysis of their pipeline segments to identify additional actions\nto enhance public safety or environmental protection. Such actions may\ninclude, but are not limited to, implementing damage prevention best practices,\nbetter monitoring of cathodic protection where corrosion is a concern,\nestablishing shorter inspection intervals, installing EFRDs on the pipeline\nsegment, modifying the systems that monitor pressure and detect leaks,\nproviding additional training to personnel on response procedures, conducting\ndrills with local emergency responders and adopting other management\ncontrols.\nIn regard to Item Number I. B. of the Notice pertaining to evaluation of leak\ndetection capabilities, CHS must evaluate the capability of its leak detection\nmeans and modify, as necessary, to protect the high consequence area. This\nevaluation must, at least, consider the following factors: the length and size of\nthe pipeline, the type of product transported, the proximity of the pipeline to\nhigh consequence areas, the swiftness of leak detection, the location of nearest\nresponse personnel, the pipeline leak history, and the pipeline risk assessment\nresults.\nIn regard to Item Number 1. C. of the Notice pertaining to evaluation EFRDs\nCHS must make an evaluation of EFRDs and this evaluation must at least,\nconsider the following factors: the swiftness of leak detection and pipeline\nshutdown capabilities, the type of commodity carried, the rate of potential\nleakage, the volume that can be released, the topography or pipeline profile, the\npotential for ignition, the pipeline proximity to power sources, the location of\nnearest response personnel, the specific terrain between the pipeline segment\nand the high consequence area, and the benefits expected by reducing the spill\nsize. If CHS determines that an EFRD is needed on any pipeline segment to\nprotect a high consequence area in the event of a hazardous liquid pipeline\nrelease, CHS must install the EFRD.\nIn regard to Item Number 2. A. of the Notice pertaining to periodic evaluations\nof integrity information, CHS must conduct a periodic evaluation to assure\npipeline integrity. This evaluation must consider the results of the baseline and\nperiodic integrity assessments, information analysis as required under\n$195. 452(g), and decisions about remediation, and preventive and mitigative\nactions as required under $195. 452(h) and (i). This analysis must also include\nthe basis for for the determination for the frequency of future evaluations and\nthis frequency must be based on the evaluation on risk factors specific to its\npipeline, including the factors specified in paragraph $195. 452(e).\n\n\n\nIn regard to Item Number 3. A. of the Notice pertaining to periodic evaluations\nof the effectiveness of an IM program, CHS evaluate the must evaluate the\neffectiveness of their IM program in assessing and evaluating the integrity of\neach pipeline segment and in protecting the high consequence areas.\nWithin 30 days of receipt of the Final Order CHS must complete the items\nlisted and submit appropriate documentation showing completion of the above\nitems.\nCHS shall maintain documentation of the safety improvement costs associated\nwith fulfilling this Compliance Order and submit the total to Chris Hoidal,\nDirector, Western Region, Pipeline and Hazardous Materials Safety\nAdministration. Costs shall be reported in two categories: I) total cost\nassociated with preparation/revision of plans, procedures, studies and analyses,\nand 2) total cost associated with replacements, additions and other changes to\npipeline infrastructure.","truncated":false,"body_characters":27850}