{"operation":"document","citation":"CPF 520087002M","title":"BETA OFFSHORE — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-11-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(e)(1), 195.452(f)(4), 195.452(f)(7), 195.452(f)(8), 195.452(h)(1), 195.452(l)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520087002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520087002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520087002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520087002M","body":"Notice of Amendment involving BETA OFFSHORE. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(f)(4),  195.452(f)(7),  195.452(f)(8),  195.452(h)(1),  195.452(l)(1). The case was opened on 2008-11-14 and is reported as closed as of 2009-06-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520087002M_notice of amendment_11142008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520087002M/520087002M_notice%20of%20amendment_11142008.pdf\n\n520087002m_notice of amendment_11142008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520087002M/520087002m_notice%20of%20amendment_11142008_text.pdf\n\n520087002M_operator_response_03052009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520087002M/520087002M_operator_response_03052009.pdf\n\n520087002m_notice of amendment_11142008_text.pdf\n\nU. S Department\nof Transportation\nPtpelltne and\nHazardous Maferlells Safety\nAdmmjrjitsfrafmon\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OP AMKXDMKNT\nNovember 14, 2008\nMr Robert Pyle\nManager, Pipehne and Marine Logistics\nPacific Energy Resources, Ltd\n111 West Ocean Blvd, Suite 1240\nLong Beach, CA 90802\niCPF 5-2008-7002M\nDear Mr Pyle\nOn May 19-22, 2008, representatives of the Pipehne and Hazardous Materials Safety\nAdministration (PHMSA) and the Cahfornia State Fire Marshal (CSFM), pursuant to Chapter\n601 of 49 United States Code, mspected Pacific Energy Resources, Ltd. 's (PERL) procedures\nand supporting implementation records for their Integrity Management Program (IMP) in Long\nBeach, Cahfornia\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPERL's plans or procedures, as described below\n(f) An operator must include, at mimmum, each of the following elements in its\nwritten integrjlty management program:\n(8) A process for review of integrity assessment results and information ana]lysis by\na person quahfied to evaluate the results and information (see paragraph (h)(2) of\nthis section).\n\n\n\nThe PERL procedures are inadequate for ensuring the quahfication of the IMP reviewers\nand evaluators. Currently, the procedures require documentation of the IMP team\nmembers, however, the procedures do not specify the level of quahfications the IMP\nreviewers must have to adequately review and analyze the assessment results\nThe PERL procedures do not specify what the in-hne inspection (ILI) vendors'\nquahfications must be. The PERL procedures do not ensure through contractual means\nor otherwise, that their ILI tool vendor performs integrity assessments and information\nanalysis in accordance with Part 195. 452(f) (4)\n(h) What actions must an operator take to address integrity issues'\n(I) General requirements. An operator must take prompt action to address all\nanomalous conditions the operator discovers through the integrity assessment or\ninformation analysis. Ln addressing all conditions, an operator must evaluate all\nanomalous conditions and remediate those that could reduce a pipehne's integrity.\nAn operator must be able to demonstrate that the remediation of the condition will\nensure the condition is unhkely to pose a threat to the long-term integrity of the\npipeline. An operator must. comply with g 195. 422 when making a repair.\n(i) Temporary pressure reduction. An operator must notify PHMSA, in accordance\nwith paragraph (m) of this section, if the operato~ cannot meet the schedule for\nevaluation and remediation required under paragraph (h)(3) of this section and\ncannot provide safety through a temporary ~eduction in operating pressure.\n(ii) ILong-term pressure reduction. When a pressure reduction exceeds 365 days, the\noperator must notify PHMSA in accordance with paragraph (m) of this section and\nexplain the reasons for the delay. An operator must also take further remedial\naction to ensure the safety of the pipeline.\n(3) Schedule for evaluation and remediation. An operator must complete\nremediation of a condition according to a schedule that pnoritizes the conditions\nfor evaluation and remediation. Yf an operator cannot meet the schedule For any\ncondition, the operator must justify the reasons why it cannot meet the schedule\n\n\n\nand that the changed scheduie wild not jeopardize pubiic safety or environmental\nprotection. An operator must notify OPS if the operator cannot meet the schedule\nand can not provide safety through a temporai y reduction in operating pressure.\nAn operator must send the notice to the address specified in paragraph (m) of this\nsection.\n(m) Where does an opeII ator send a notification T An operator must send any\nnotification required by this section to the Information Resources Manager, Office\nof Pipeline Safety, Research and Speciall Programs Administration, U. S.\nDepartment of Yransportation, Room 7I28, 400 Seventh Street SW, Washington\nBC 20590, or to the facsimIle number (202) 366-7I28.\nThe PERL IMP procedures do not ensure the operator cannot exceed 365 days without\nmaking a formal notification to the PHMSA The procedures also do not specify what\nadditional safety measures will be used to ensure long term safety\nThe PERL procedures do not consider the risks associated with alternate modes of\noperation of their pipeluies, e. g. startup, shutdown, shut-in, slack hne, pressure cychng,\netc In addition, the PERL procedures do not consider hkely risk factors and threats on\ntheir pipehne, e g the risk for corrosion needs to be more threat specific for each type of\ncondition or environment\n(f) An oper ator must include, at minimum, each of the foWowing elements in its\nwritten integrity management program:\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection)\n\n\n\nPERL's root cause analysis was not adequately integrated mto their IM program. The\nanalysis currently used by the PERL is not referenced in its IMP to ensure a process for\nan effective root cause analysis and lessons learned\nThe PERL IMP procedures do not include a document retention pohcy that ensures key\ndocuments, as described in Part (195 452 (1), are retained for the hfe of the pipehne\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U S. C ) 60108(a) and 49 C. F R ( 190 237 Enclosed as\npart of this Notice is a document entitled Response 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 pubhcly available. If you beheve that any portion of your responsive material quahfies\nfor confidential treatment under 5 U S. C. 552(b), along with the complete origmal document\nyou must provide a second copy of the document with the portions you beheve quahfy for\nconfidential treatment redacted and an explanation of why you beheve the redacted information\nquahfies for confidential treatment under 5 U. S. C 552(b) If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations m this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged m\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 contestmg this Notice, we propose that you submit your\namended procedures to my office withm 60 days of receipt of this Notice This period may be\nextended by written request for good cause Once the inadequacies identified herem have been\naddressed in your amended procedures, this enforcement action will be closed\nIn correspondence concerning this matter, please refer to CPF 5-2008-7002M and, for each\ndocument you submit, please provide a copy m electronic format whenever possible\nSincerel,\nis a\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc PHP-60 Comphance Registry\nPHP-500 H. Monfared (0120746)\nEnclosure' Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":8206}