{"operation":"document","citation":"CPF 520151005W","title":"KB PIPELINE — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-05","effective_on":null,"summary":"CLOSED warning letter citing 192.605(e), 192.619, 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520151005W","body":"Warning Letter involving KB PIPELINE. PHMSA's enforcement data identifies the cited regulations as 192.605(e),  192.619,  192.739(a). The case was opened on 2015-06-05 and is reported as closed as of 2015-06-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520151005W_Operator Response to Notice_07312015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151005W/520151005W_Operator%20Response%20to%20Notice_07312015.pdf\n\n520151005W_warning letter_06052015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151005W/520151005W_warning%20letter_06052015.pdf\n\n520151005W_warning letter_06052015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151005W/520151005W_warning%20letter_06052015_text.pdf\n\n520151005W_warning letter_06052015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 5, 2015\nMs. Kathy Davies\nManager KB Pipeline\nPortland General Electric\n121 SW Salmon Street, 3WTC0402\nPortland, OR 97204\nCPF 5-2015-1005W\nDear Ms. Davies:\nOn June 17-20, 2013, representatives of the Washington Utilities and Transportation\nCommission (WUTC) and the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected the Operations and\nMaintenance Manual and associated records of the Kelso-Beaver (KB) Pipeline in Clatskanie,\nOregon.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(e) Surveillance, emergency response, and accident investigation. The\nprocedures required by §§192.613(a), 192.615, and 192.617 must be included in\nthe manual required by paragraph (a) of this section\nThe Continuing Surveillance policy and procedures contained in Section 3 “Pipeline\nSurveillance” of the Operations and Maintenance Manual are not detailed enough in\n\n\n\naddressing the slope stability of the Hazen Dell side area or for monitoring the anomalies\nidentified through continuing surveillance (such as the 2010 ILI tool run, or other methods).\nSlope stability is a major issue for KB Pipeline, and the Operations and Maintenance Manual\nonly mentions \"ground movement\" in Section 3.4.2 (b) General Right of Way Surveillance.\nGround Movement is one of the highest level hazards to KB Pipeline. KB Pipeline conducts\nsignificant monitoring of the Hazen Dell Slide area for slope stability area every year.\nHowever, the KB Pipeline Operations and Maintenance Manual does not detail or mention the\nmonitoring methods or what long term planning is being done to mitigate the slope stability\nhazard. KB needs to include the procedures for monitoring slope stability as a part of the\nOperations and Maintenance Manual.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(e) Surveillance, emergency response, and accident investigation. The\nprocedures required by §§192.613(a), 192.615, and 192.617 must be included in\nthe manual required by paragraph (a) of this section\nThe Continuing Surveillance policy and procedures contained in Section 3 “Pipeline\nSurveillance” of the Operations and Maintenance Manual are not detailed enough in\naddressing the anomalies identified through continuing surveillance (such as the 2010 ILI tool\nrun, or other methods).\nThe 2010 ILI run identified several anomalies. Anomalies S6, S11 & S21 were identified as\nrequiring monitoring. S6 has calculated percent of OD deformation of 5.4% and Strain of\n0.89%. S11 has calculated percent of OD deformation of 1.6% and Strain of 5.4%. S21 has\ncalculated percent of OD deformation of 1.7% and Strain of 3.4%. The repair criteria is 6%\nfor OD deformation and strain. KB Pipeline has no process for determining the interval for\nexamining the pipeline with ILI tools (or other methods) in the Operations and Maintenance\nManual. KB needs to develop a plan and procedures to monitor the anomalies and include\nthis plan and procedures as a part of the Operations and Maintenance Manual. An integral part\nof this monitoring plan is to determine the examination interval by various methods such as\nILI tools.\n2\n\n\n\n3. §192.619 Maximum allowable operating pressure - Steel or plastic pipelines\n(a) No person may operate a segment of steel or plastic pipeline at a pressure that\nexceeds a maximum allowable operating pressure determined under paragraph\n(c) or (d) of this section, or the lowest of the following:\n(1) The design pressure of the weakest element in the segment, determined in\naccordance with subparts C and D of this part. However, for steel pipe in\npipelines being converted under §192.14 or uprated under subpart K of this part,\nif any variable necessary to determine the design pressure under the design\nformula (§192.105) is unknown, one of the following pressures is to be used as\ndesign pressure:\n(i) Eighty percent of the first test pressure that produces yield under section N5\nof Appendix N of ASME B31.8 (incorporated by reference, see §192.7), reduced\nby the appropriate factor in paragraph (a)(2)(ii) of this section; or\n(ii) If the pipe is 12¾ inches (324 mm) or less in outside diameter and is not tested\nto yield under this paragraph, 200 p.s.i. (1379 kPa) gage.\n(2) The pressure obtained by dividing the pressure to which the segment was\ntested after construction as follows:\n(i) For plastic pipe in all locations, the test pressure is divided by a factor of 1.5.\n(ii) For steel pipe operated at 100 p.s.i. (689 kPa) gage or more, the test pressure\nis divided by a factor determined in accordance with the following table:\nFactors (see Note)\nClass location Segment Installed\nBefore Nov.12,\n1970\nSegment Installed\nAfter Nov. 11,\n1970\nSegment\nConverted under\n§192.14\n1 1.1 1.1 1.25\n2 1.25 1.25 1.25\n3 1.4 1.5 1.5\n4 1.4 1.5 1.5\nNote: For offshore segments installed, or updated, or converted after July 31,\n1977, that are not located on an offshore platform, the factor is 1.25. For\nsegments installed, uprated, or converted after July 31, 1977 that are located on\nan offshore platform or on a platform in inland navigable waters (including a\npipe riser), the factor is 1.5\n3\n\n\n\nKB Pipeline failed to establish the Maximum Allowable Operating Pressure (MAOP) in\naccordance with §192.619. KB Pipeline provided an MAOP justification study conducted by\nTrigon Engineering Inc. (Trigon) in 1995. The 1995 Trigon study evaluates the original\npipeline system including the 1992 construction drawings of the pipeline and the hydrostatic\ntesting completed in 1992. Trigon determined that the pipe is the weakest element of the\npipeline system. The Trigon Study is vague on what other elements of the pipeline system\nwere evaluated. The KB Pipeline has undergone significant modification between 1995 and\n2013. Specifically, KB Pipeline has installed aboveground replacement pipe in two locations,\nconstructed a new lateral to the Port Westward Generating Plant, made modifications to\nBeaver Meter Station, and accepted responsibility of a segment of the Unit 8 lateral. All\napplicable elements required in an MAOP calculation were not adequately documented. KB\nPipeline needs to complete a new documented MAOP determination study and consider the\nentire pipeline system including above ground appurtenances.\n4. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\nPressure regulating station and its equipment must be subjected at intervals not\nexceeding 15 months, but at least once each calendar year, to inspections and\ntests to determine that it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nKB Pipeline failed to inspect and test the pressure regulating equipment on meter run 300/400\n(Unit 39935) in accordance with §192.739 “Pressure limiting and regulating stations:\nInspection and testing.” This meter run is currently valved out and locked out of service and\nKB considers the run abandoned. However, KB Pipeline needs to remove meter run 300/400\nand notify PHMSA that it is abandoned or conduct the required Inspection and Testing in\naccordance with §192.739.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\n4\n\n\n\nthe items identified in this letter. Failure to do so will result in KB Pipeline being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2015-1005W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChristopher Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Jason Dunphy\nWUTC\n5","truncated":false,"body_characters":10242}