{"operation":"document","citation":"CPF 520097002M","title":"FREEPORT-MCMORAN OIL & GAS — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-01-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.452(c)(1), 195.452(f)(3), 195.452(g), 195.452(h)(3), 195.452(i)(2), 195.555, 195.56(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520097002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520097002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520097002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520097002M","body":"Notice of Amendment involving FREEPORT-MCMORAN OIL & GAS. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.452(c)(1),  195.452(f)(3),  195.452(g),  195.452(h)(3),  195.452(i)(2),  195.555,  195.56(b)(1). The case was opened on 2009-01-08 and is reported as closed as of 2009-04-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520097002M_notice of amendment_01082009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520097002M/520097002M_notice%20of%20amendment_01082009.pdf\n\n520097002M_notice of amendment_01082009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520097002M/520097002M_notice%20of%20amendment_01082009_text.pdf\n\n520097002M_notice of amendment_01082009_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 8, 2009\nMr. Bob Marsalek\nEnvironmental Advisor\nPlains Exploration & Production Company\n201 S. Broadway\nOrcutt, CA 93455\nCPF 5-2009-7002M\nDear Mr. Marsalek:\nOn April 21-25, 2008 and May 5-9, 2008, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your procedures in Orcutt, California, related to integrity management, operation and\nmaintenance of the hazardous liquid crude oil lines from the offshore platform Irene to the\nLompoc Gas Plant (LOGP) and the offshore platform Hermosa to the Gaviota Oil & Gas\nProcessing Facility for the Plains Exploration & Production (PXP) Company. The inspection\nteam also completed a field inspection of the platform Irene and associated crude oil pipeline\nduring this timeframe.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPXP’s plans or procedures, as described below:\n1. § 195.56 Filing safety-related condition reports.\n(b) The report must be headed “Safety-Related Condition Report” and provide the\nfollowing information:\n(1) Name and principal address of operator.\n\n\n\n(2) Date of report.\n(3) Name, job title, and business telephone number of person submitting the report.\n(4) Name, job title, and business telephone number of person who determined that\nthe condition exists.\n(5) Date condition was discovered and date condition was first determined to exist.\n(6) Location of condition, with reference to the State (and town, city, or county) or\noffshore site, and as appropriate nearest street address, offshore platform, survey\nstation number, milepost, landmark, or name of pipeline.\n(7) Description of the condition, including circumstances leading to its discovery,\nany significant effects of the condition on safety, and the name of the commodity\ntransported or stored.\n(8) The corrective action taken (including reduction of pressure or shutdown)\nbefore the report is submitted and the planned follow-up or future corrective\naction, including the anticipated schedule for starting and concluding such action\nThe O&M Manual, Procedure 1.02 does not specify the minimum criteria necessary to\nmeet the rule requirements of 195.56(b).\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nThe PXP procedures do not reflect or reference the tactical application of PXP’s\ncorrosion monitoring and mitigation strategies. PXP’s employs a relatively\ncomprehensive program to manage internal corrosion. Measures taken to mitigate the\neffects of internal corrosion include brush pig cleaning at weekly intervals, batch\ninjection and continuous injection of corrosion inhibitor. Monitoring includes the use of\nweight loss coupons, corrosion probes, beta foil measurements, corrosion inhibitor\nresiduals, microbiological cultures, UT measurements, chemical analysis, and ILI\nsurveys. Regardless, Section 6.02 of the O&M Manual, which addresses PXP’s strategy\nfor monitoring and mitigating the effects of internal corrosion, does not reference a\ncorrosion monitoring program plan or reflect the tactical approach PXP takes to meet the\ncorrosion control requirements of Part 195, Subpart H, as required by 195.402(c)(3).\n3. § 195.452 Pipeline integrity management in high consequence areas.\n(c) What must be in the baseline assessment plan?\n(1) An operator must include each of the following elements in its written baseline\nassessment plan:\n2\n\n\n\n(i) The methods selected to assess the integrity of the line pipe. An operator must\nassess the integrity of the line pipe by any of the following methods.\n(A) Internal inspection tool or tools capable of detecting corrosion and deformation\nanomalies including dents, gouges and grooves.\nNo tool tolerances were provided in the following ILI Assessment reports: Magpie PXP\nInternal Pipeline Inspection Report, 24\" Pipeline, Platform Hermosa to Gaviota Plant,\n11/7/06; and Magpie PXP Internal Pipeline Inspection Report, 20\" Pipeline, Platform\nIrene to LOGP, 10/30/07. Procedures must be revised to assure vendor ILI assessments\nare properly reviewed to confirm tool tolerances meet project specifications.\n4. § 195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? . . . . An operator\nmust include, at a minimum, each of the following elements in its written integrity\nmanagement program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area.\nThe Integrity Management Plan (IMP) Manual, Section 1.4, must be revised to reference\nthe Oil Spill Response Plan for the worst case release since this information may support\nidentification of pipeline segments that could affect high consequence areas.\n5. § 195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? . . . . An operator\nmust continually change the program to reflect operating experience. . . . An\noperator must include, at a minimum, each of the following elements in its written\nintegrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of failure.\nThe IMP Manual must be revised to specifically address consideration of the risks\nassociated with alternate modes of pipeline operation (e.g., startup, shutdown, shut-in,\nslack line, pressure cycling, etc.).\n6. § 195.452 Pipeline integrity management in high consequence areas.\n(g) What is an information analysis? In periodically evaluating the integrity of\neach pipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the\nconsequences of a failure.\nThe PXP IMP manual procedure for conducting a comprehensive information analysis is\ninadequate. IMP Manual, Section 3.6 only gives a high level overview of the integration\n3\n\n\n\nof other data with ILI assessment results. PXP needs to better describe the information\nanalysis process and the specific information considered such as what is included in\n195.452(g), including, previous assessment results; surveillance, testing, and other\nmonitoring data (e.g., internal corrosion coupon monitoring).\n7. § 195.452 Pipeline integrity management in high consequence areas.\n(h) What actions must an operator take to address integrity issues?\n(3) Schedule for evaluation and remediation. An operator must complete\nremediation of a condition according to a schedule prioritizing the conditions for\nevaluation and remediation. If an operator cannot meet the schedule for any\ncondition, the operator must explain the reasons why it cannot meet the schedule\nand how the changed schedule will not jeopardize public safety or environmental\nprotection. An operator must notify OPS if the operator cannot meet the schedule\nand cannot provide safety through a temporary reduction in operating pressure.\nPXP has inadequate notification procedures for reporting delays in remediating\nanomalies. On June 25, 2007, PXP made a notification to the CASFM for delay of 180\nday repairs on the San Vicente line and delay of an immediate repair (which has been\nrepaired) and for delay of immediate and 180 day repairs on the Packard line (repairs\nnow completed). PXP should have also made this notification to DOT per 195.452(h)(3)\nfor the lines under the CASFM jurisdiction. PXP issued the required notifications\nduring the inspection. The IMP Manual must be revised to clarify the notification\nrequirements.\n8. § 195.452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline release\noccurring and how a release could affect the high consequence area.\nThe IMP Manual does not meet the risk analysis requirements of 195.452(i)(2). The\nIMP Manual, Element 6, Section 6.2, states that: “the risk analysis shall focus on\nconsequences of release, rather than on the likelihood of releases as focused on in other\nparts of the IM program”.\n9. § 195.555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge of\nthat portion of the corrosion control procedures established under §195.402(c)(3)\nfor which they are responsible for insuring compliance.\nThe PXP procedures do not require or have verification processes to ensure that their\nsupervisors have thorough knowledge of the corrosion programs that they are\nresponsible for implementing. PXP needs to identify supervisory personnel who have\nresponsibility and accountability for ensuring contractor Corrosion Control Program\n4\n\n\n\nrecommendations are implemented. Procedures do not assure supervisors are adequately\ntrained in corrosion control as required by 195.555.\nResponse 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 publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), 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 information\nqualifies 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 in 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.\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 [number of days] days of receipt of this Notice. This\nperiod may be extended by written request for good cause. Once the inadequacies identified\nherein have been addressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 5-2009-7002M 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 K. Davis (#121332)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5","truncated":false,"body_characters":12303}