CPN PIPELINE COMPANY — Notice of Amendment

party submissionOfficial PDF520140002M_Operator_Response to Notice_12092014.pdf#

520140002M_closure letter_12292014_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED December 29, 2014 Mr. Lyle Fedje Director, Pipeline Operations CPN Pipeline Company 60 River Road Rio Vista, CA 94571 CPF 5-2014-0002M Dear Mr. Fedje: On May 5-9, 2014, June 9-12, 2014, and July 21-25, 2014, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of CPN Pipeline Company’s Operation and Maintenance (O&M) and Integrity Management Program (IMP) procedures in Rio Vista, CA. As a result of the inspection, CPN Pipeline Company was issued a Notice of Amendment on November 12, 2014, which proposed amendment of your procedures. CPN Pipeline Company submitted its amended procedures on December 9, 2014. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case (CPF 5-2014-0002M) is now closed. Please note that the Notice of Probable Violation, CPF 5-2014-0006, is still being processed. Thank you for your cooperation. Sincerely, Chris Hoidal, Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 C. Ishikawa (#145425)#

520140002M_notice of amendment_11122014_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED November 12, 2014 Mr. Lyle Fedje Director, Pipeline Operations CPN Pipeline Company 60 River Road Rio Vista, CA 94571 CPF 5-2014-0002M Dear Mr. Fedje: On May 5-9, 2014, June 9-12, 2014, and July 21-25, 2014, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected CPN Pipeline Company’s Operation and Maintenance (O&M) and Integrity Management Program (IMP) procedures in Rio Vista, CA. On the basis of the inspection, PHMSA has identified an apparent inadequacy within CPN Pipeline Company’s IMP procedures, as described below: 1. §192.921 How is the baseline assessment to be conducted? (a) Assessment methods. An operator must assess the integrity of the line pipe in each covered segment by applying one or more of the following methods depending on the threats to which the covered segment is susceptible. An operator must select the method or methods best suited to address the threats identified to the covered segment (See § 192.917). (1) Internal inspection tool or tools capable of detecting corrosion, and any other threats to which the covered segment is susceptible. An operator must follow ASME/ANSI B31.8S (incorporated by reference, see § 192.7), section 6.2 in selecting the appropriate internal inspection tools for the covered segment.#

520140002M_notice of amendment_11122014_text.pdf, page 2(2) Pressure test conducted in accordance with subpart J of this part. An operator must use the test pressures specified in Table 3 of section 5 of ASME/ANSI B31.8S, to justify an extended reassessment interval in accordance with §192.939 (3) Direct assessment to address threats of external corrosion, internal corrosion, and stress corrosion cracking. An operator must conduct the direct assessment in accordance with the requirements listed in § 192.923 and with, as applicable, the requirements specified in § § 192.925, 192.927 or 192.929; (4) Other technology that an operator demonstrates can provide an equivalent understanding of the condition of the line pipe. An operator choosing this option must notify the Office of Pipeline Safety (OPS) 180 days before conducting the assessment, in accordance with §192.949. An operator must also notify a State or local pipeline safety authority when either a covered segment is located in a State where OPS has an interstate agent agreement, or an intrastate covered segment is regulated by that State. CPN Pipeline Company’s IMP procedures lacked specific details of the method(s) used for evaluating in-line inspection tools used to perform its pipeline assessments. The IMP procedures must describe a technical basis for determining the effectiveness of its in-line inspection tool performance on a pipeline segment. Response 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 being made publicly available. If you believe that any portion of your responsive material qualifies 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 believe 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 Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, 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 sixty days (60) 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. It is requested (not mandated) that CPN Pipeline Company maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment#

520140002M_notice of amendment_11122014_text.pdf, page 3(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2014-0002M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal, Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 C. Ishikawa (#145425)#