{"operation":"document","citation":"CPF 520145001M","title":"BELLE FOURCHE PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-02-19","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(9), 195.402(d), 195.402(d)(1), 195.402(d)(2), 195.402(d)(3), 195.402(d)(4), 195.446(a), 195.446(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520145001M","body":"Notice of Amendment involving BELLE FOURCHE PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(9),  195.402(d),  195.402(d)(1),  195.402(d)(2),  195.402(d)(3),  195.402(d)(4),  195.446(a),  195.446(b)(2). The case was opened on 2014-02-19 and is reported as closed as of 2014-06-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520145001M_closure letter_06022014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145001M/520145001M_closure%20letter_06022014.pdf\n\n520145001M_closure letter_06022014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145001M/520145001M_closure%20letter_06022014_text.pdf\n\n520145001M_notice of amendment_02192014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145001M/520145001M_notice%20of%20amendment_02192014.pdf\n\n520145001M_notice of amendment_02192014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145001M/520145001M_notice%20of%20amendment_02192014_text.pdf\n\n520145001M_Operator Response to Notice_03242014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145001M/520145001M_Operator%20Response%20to%20Notice_03242014.pdf\n\n520145001M_notice of amendment_02192014_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 19, 2014\nMr. Tad True\nVice President\nBelle Fourche Pipeline Company\n455 N Poplar St.\nCasper, WY 82602\nCPF 5-2014-5001M\nDear Mr. True:\nBetween November 14, 2011 and March 9, 2012, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code, investigated a November 14, 2011 release from your Sussex\nDiesel Pipeline System’s Davis Station southwest of Gillette, Wyoming. The release spilled\n1900 barrels of diesel onto the ground, causing contamination to the soil.\nSpill Investigation Findings:\nThe Sussex Diesel Line ships diesel fuel from ConocoPhillips's Seminoe pipeline to Belle\nFourche's Hawk Point tank facility. The 6-inch pipeline begins at the Tinsdale station\napproximately 58 miles south of Buffalo, WY. The pipeline then continues northeast to the\nSussex station and then to the Iberlin valve and pig launcher receiver site about 49 miles from\nthe Tisdale station. At Iberlin the line diameter reduces to 4 inches. The pipeline then continues\neast about 30 miles to the Hawk Point terminal facility approximately 18 miles south of Gillette,\nWY. Between Iberlin and Hawk Point there is one breakout tank at the Davis facility.\nPHMSA’s investigation revealed that multiple operation and maintenance factors contributed to\nthe occurrence and magnitude of the spill. The release occurred when a Belle Fourche Pipeline\nCompany (BFPL) controller attempted a diesel delivery to the Hawk Point Station on the\nevening of November 13, 2013. Just after the controller started the booster pump at the Iberlin\n\n\n\nStation, the pump shut down because it exceeded its high discharge pressure limit. The\ncontroller attempted a restart of the diesel delivery. The controller was unaware that he was\npumping against two closed valves near the Davis Station, one going to the Davis Station tank\nand the second on the mainline going towards the Hawk Point Station.\nPumping against the closed valves caused the pipeline to exceed its normal operating pressures.\nSometime between the first start up attempt and the restart, the flange gasket on the upstream\nside of the closed Davis mainline valve failed and resulted in the diesel fuel release. The\ncontroller was able to keep the Iberlin booster pump running by reducing incoming pressure. He\ndid this by stopping one of the mainline pumps at the upstream Sussex terminal. The Iberlin\npump discharge pressure was not exceeded since the diesel in the pipeline was escaping through\nthe ruptured flange on the Davis valve.\nFrom the investigation, PHMSA identified regulatory deficiencies that contributed to the\noccurrence and magnitude of the spill. The maintenance-related deficiencies are addressed in our\nWarning Letter, CPF 5-2014-5002W, dated February 19, 2014. PHMSA also identified apparent\ninadequacies within BFPL plans or procedures that contributed to the release, as described\nbelow:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations 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(9) In the case of facilities not equipped to fail safe that are identified under\n§195.402(c)(4) or that control receipt and delivery of the hazardous liquid or carbon\ndioxide, detecting abnormal operating conditions by monitoring pressure,\ntemperature, flow or other appropriate operational data and transmitting this data\nto an attended location.\nBFPL did not have adequate written procedures to provide safety during maintenance and\nnormal operations for the Sussex Diesel Pipeline. BFPL had not developed written procedures to\ninclude the specific steps that a controller must take to detect abnormal pipeline conditions by\nmonitoring pressure, temperature, flow or other appropriate operational data. While BFPL did\nhave general written operating procedures, they lacked the specifics needed to correctly monitor\nfor and detect abnormal operations on the pipeline system.\n2\n\n\n\nThe Hawk Point Station diesel deliveries are received into a tank. There is a meter and a gauge\ninside the tank, but the controller did not check the meter or the gauge to see if product was\nactually being received. During the investigation, company personnel alluded to the fact that\nthere are certain unwritten policies and procedures that personnel are supposed to understand and\nfollow. 49 CFR Part 195402 requires all procedures, for both normal and abnormal operations,\nto be written and followed.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(d) Abnormal operation. The manual required by paragraph (a) of this section\nmust include procedures for the following to provide safety when operating design\nlimits have been exceeded;\n(1) Responding to, investigating, and correcting the cause of;\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal\noperating limits;\n(iii) Loss of communications;\n(iv) Operation of any safety device;\n(v) Any other malfunction of a component, deviation from normal\noperation, or personnel error which could cause a hazard to persons\nor property.\nBFPL did not have specific written procedures for correctly responding to, investigating, and\ncorrecting the cause of any of the conditions listed in § 195.402(d)(1). BFPL’s written\nprocedures are a paraphrasing of code language and do not provide sufficient guidance to the\ncontroller as to specific actions required during and after an abnormal operation. Furthermore,\nthe procedures do not detail how to investigate and correct the cause of the abnormal operations.\nWhen the Iberlin booster pump went down on high discharge pressure, the controller simply\nreset the line and attempted a restart instead of responding to, investigating, and correcting the\ncause of the abnormal operation. During the investigation, company personnel alluded to the\nfact that there are certain unwritten policies and procedures that personnel are supposed to\nunderstand and follow. 49 CFR Part 195402 requires all procedures, including abnormal\noperations, to be written and followed.\n3. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(d) Abnormal operation. The manual required by paragraph (a) of this section\nmust include procedures for the following to provide safety when operating design\nlimits have been exceeded;\n(2) Checking variations from normal operation after abnormal operation\nhas ended at sufficient critical locations in the system to determine continued\nintegrity and safe operation.\n(3) Correcting variations from normal operation of pressure and flow\nequipment and controls.\n(4) Notifying responsible operator personnel when notice of an abnormal\noperation is received.\n3\n\n\n\nIt was abnormal for the booster pump to go down on high discharge pressure, however the\ncontroller did not have written procedures to check variations from normal operation after that\nabnormal operation had occurred. The procedures that the controller is to follow must check\nvariations from normal operations at sufficient critical locations in the system to determine\ncontinued integrity and safe operation. The controller also did not correct variations from\nnormal operation of pressure and flow equipment and controls. Furthermore, the controller did\nnot notify responsible operator personnel when an abnormal operation occurred. The controller\ninterviewed by PHMSA stated that the requirements for 195.402(d)(2), (3), and (4) are generally\n“unwritten” control room policy.\nFollowing the abnormal operation when the Iberlin pump went down on high discharge pressure,\nthe controller did not check the system at sufficient critical locations for the next seven (7) hours.\nWhen he finally checked the Hawk Point tank, he discovered there was no diesel delivered over\nthe previous evening. The operator does not have written procedures that are specific or timely\nenough to ensure compliance with 195.402(d)(2,3 and 4). These are needed to provide safety\nwhen design limits have been exceeded.\n4. §195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by § 195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section must\nbe implemented no later than October 1, 2011….\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(2) A controller's role when an abnormal operating condition is detected, even if the\ncontroller is not the first to detect the condition, including the controller's\nresponsibility to take specific actions and to communicate with others;\nAt the time of the pipeline failure on November 13, 2011, BFPL had not developed and\nimplemented adequate Control Room Management Procedures to define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating conditions,\nincluding the controller’s responsibility to take specific actions and to communicate with others\nwhen an abnormal operating condition is detected.\n4\n\n\n\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 for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust 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.\nIt is requested (not mandated) that BFPL maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 5-2014-5001M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 P. Katchmar (#136756)\n5\n\n520145001M_closure letter_06022014_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 2, 2014\nMr. Tad True\nVice President\nBelle Fourche Pipeline Company\nPO Drawer 2360\nCasper WY 82602\nRE: CPF 5-2014-5001M\nClose Case\nDear Mr. True:\nBetween November 14, 2011 and March 9, 2012, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code, investigated a November 14, 2011 release from your Sussex Diesel Pipeline System’s Davis\nStation southwest of Gillette, Wyoming. The release spilled 1900 barrels of diesel onto the ground\ncausing contamination to the soil.\nAs a result of the investigation, Belle Fourche Pipeline Company (BFPL) was issued a Notice of\nAmendment on February 19, 2014, which proposed amendment of your procedures. BFPL submitted\nrevised procedures for its Operations and Maintenance Manual and for its Control Room Manual on\nMarch 23, 2014, and April 23, 2014, respectively. My staff reviewed BFPL’s response and it appears that\nthe inadequacies outlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for your\ncooperation.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 P. Katchmar (#136756)\nKen Dockweiler via e-mail- <Ken.Dockweiler@Truecos.com>","truncated":false,"body_characters":15387}