IDAHO PIPELINE CORP — Notice of Amendment

520085022m_notice of amendment_08222008_text.pdf, page 1Official PDFU. S Department of Transportation Pipelline and Hazardous Mateiriials Safety Admiiiriiistmtioirii 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 NOTICE OF AMKXOMKNT August 22, 2008 Mr. Robert Rose Idaho Pipelme Corporation P. 0 Box 35236 Sarasota, FL 34232 CPF 5-2008-5022M Dear Mr. Rose On March 3-7, 2008, a representative of the Pipehne and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your procedures for the Boise Aviation Fuel Pipehne in Boise, Idaho. On the basis of the inspection, PHMSA identified apparent inadequacies within Idaho Pipeline Corporation's plans or procedures as described below: $195. 222 Welders: Qualification of welders. (b) No welder may weld with a welding process unless, within the preceding 6 calendar months, the welder has— (1) Engaged in welding with that process; and (2) Had one welded tested and found acceptable under section 9 of API 1104 (ibr, see g 195. 3). At the time of this inspection, the Idaho Pipehne Corporation's (IPC) procedural manual did not address the requirement that, within the preceding 6 months, a welder must satisfy the requirements of subparagraphs (1) and (2), above#

520085022m_notice of amendment_08222008_text.pdf, page 22. $195. 228 Welds and welding inspection: Standards of acceptability. (a) Each operator shaH inspect the physical integrity of in-service atmospheric and low-pressure steel aboveground breakout tanks according to section 6 of API Standard 653. However, if structural conditions prevent access to the tank bottom the bottom integrity may be assessed according to a plan included in the operations and (b) 'The acceptability of a weld is determined according to the standards in Section 9 of API 1104. However, if a girth weld is unacceptable under those standards for a reason other than a crack, and if Appendix A to API 1104 (ibr, see g 195. 3) applies to the weld, the acceptability of the weld may be determined under that appendix. The IPC procedural manual did not include the mspection and acceptabihty requirements of subparagraphs (a) and (b), above. $195. 234 Welds: Nondestructive testing. (a) A weld may be nondestructively tested by any process that will clearly indicate any defects that may affect the integrity of the weld. (b) Any nondestructive testing of welds must be performed- (1) In accordance with a written set of procedures for nondestructive testing; and, (2) With personnel that have been trained in the established procedures and in the use of the equipment employed in the testing. (c) Procedures for the proper interpretation of each weld inspection must be estabhshed to ensure the acceptabiHty of the weld under $195. 228. (d) Buring construction, at least 10 percent of the girth welds made by each welder during each welding day must be nondestructively tested over the entire circumference of the weld. (e) AH girth welds installed each day in the following locations must be nondestructively tested over their entire circumference, except that when nondestructive testing is impracticable for a girth weld, it need not be tested if the number of girth weMs for which testing is impracticable does not exceed 10 percent of the girth welds installed that day: (1) At any onshore location where a loss of hazardous liquid could treasonably be expected to pollute any stream, river, lake, reservoir, or other body of water, and any offshore area; (2) Within railroad or public road rights-of-way; (3) At overhead road crossings and within tunnels; (4) Within the hmits of any incorporated subdivision of a State government; and, (5) Within populated areas, including, but not limited to, residential subdivisions, shopping centers, schools, designated commercial areas, industrial facilities, public institutions, and places of public assembly. (f) When installing used pipe, 100 percent of the old girth welds must be nondestructively tested. (g) At pipeline tie-ins, including tie-ins of replacement sections, 100 percent of the girth welds must be nondestructively tested.#

520085022m_notice of amendment_08222008_text.pdf, page 3The IPC procedural manual did not address any of the nondestructive testing requirements. $195. 571 What criteria must I use to determine the adequacy of cathodic protection?' Cathodic protection required by this subpart must comply with one or more of the applicable criteria and other considerations for cathodic protection contained in paragraphs 6. 2 and 6. 3 of SACK Standard RP 0169 (incorporated by reference, see $195. 3). The lPC procedural manual did not contam a requirement of comphance with any criteria or other considerations for cathodic protection contained m paragraphs 6. 2 and 6. 3 of NACE Standard RP 0169 $195. 573 What must I do to monitor external corrosion control? (e) Corrective actions as required by . 401(b) and, if IMP pipeline, 195. 452(h) The lPC procedural manual did not hst the requirement that whenever an operator discovers any condition that could adversely affect the safe operation of its pipehne system and that if the condition is of such a nature that it presents an immediate hazard to persons or property, IPC may not operate the affected part of the system until it has corrected the unsafe condition within a reasonable time. $195. 583 What must I do to monitor atmospheric corrosion control? (a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows: Then the frequency of inspection is: Onshore Offshore At least once every 3 calendar years, but with intervals not exceeding 39 months At least once each calendar year, but with intervals not exceeding 15 months The IPC procedural manual did not mclude the requirement that each pipehne or portion of the pipeline that is exposed to the atmosphere must be inspected for evidence of atmospheric corrosion#

520085022m_notice of amendment_08222008_text.pdf, page 4Res onse 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 Options for 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 bemg made pubhcly available. If you beheve that any pot%ion of your responsive material quahfies 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 beheve qualify for confidential treatment redacted and an explanation of why 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 Notice and authorizes the Associate Admmistrator for Pipehne Safety to find facts as alleged m this Notice without fuither notice to you and to issue a Fmal Order If, after opportunity for a hearmg, your 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, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written 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 matter, please refer to CFF 5-2008-5022M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, ~ C ris Hoidal Director, Western Region Pipehne and Hazardous Materials Safety Admmistration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc PHP-60 Compliance Registry PHP-500 J. Kenerson (0120695)#