{"operation":"document","citation":"CPF 520186016M","title":"IDAHO PIPELINE CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-10-10","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(12), 195.402(c)(13), 195.402(c)(2), 195.402(c)(3), 195.402(c)(5), 195.402(e)(1), 195.402(e)(2), 195.402(e)(3), 195.402(e)(4), 195.402(e)(5), 195.402(e)(6), 195.402(e)(7), 195.402(e)(9), 195.402(f), 195.505(b), 195.505(c), 195.505(f).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186016m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186016m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186016m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520186016M","body":"Notice of Amendment involving IDAHO PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(12),  195.402(c)(13),  195.402(c)(2),  195.402(c)(3),  195.402(c)(5),  195.402(e)(1),  195.402(e)(2),  195.402(e)(3),  195.402(e)(4),  195.402(e)(5),  195.402(e)(6),  195.402(e)(7),  195.402(e)(9),  195.402(f),  195.505(b),  195.505(c),  195.505(f). The case was opened on 2018-10-10 and is reported as closed as of 2025-04-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520186016M_Closure Letter_04022025_(17-155733S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Closure%20Letter_04022025_(17-155733S).pdf\n\n520186016M_Closure Letter_04022025_(17-155733S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Closure%20Letter_04022025_(17-155733S)_text.pdf\n\n520186016M_Notice of Amendment_10102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Notice%20of%20Amendment_10102018.pdf\n\n520186016M_Notice of Amendment_10102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Notice%20of%20Amendment_10102018_text.pdf\n\n520186016M_Operator Response to Notice_09172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Operator%20Response%20to%20Notice_09172019.pdf\n\n520186016M_Order Directing Amendment_08082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Order%20Directing%20Amendment_08082019.pdf\n\n520186016M_Order Directing Amendment_08082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186016M/520186016M_Order%20Directing%20Amendment_08082019_text.pdf\n\n520186016M_Closure Letter_04022025_(17-155733S)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com\nApril 2, 2025\nMr. Robert Rose\nPresident\nIdaho Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 5-2018-6016M\nClosure Letter\nDear Mr. Rose:\nDuring the weeks of September 5 through 8 and September 18 through 21, 2017, representatives\nfrom the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to\nChapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Idaho\nPipeline Corporation’s procedures in Boise, Idaho. As a result of the inspection, Idaho Pipeline\nCorporation was issued a Notice of Amendment on October 10, 2018, which proposed\namendment of your procedures. A Final Order Directing Amendment was issued on August 8,\n2019. Idaho Pipeline submitted a response, received by PHMSA on September 18, 2019.\nPHMSA has determined that given the passage of time, it would be prudent to review the items\nidentified in the NOA and Final Order during a future inspection rather than to continue the\ncurrent proceeding. PHMSA will address any remaining items with Idaho Pipeline Corporation\nat that time. Accordingly, this case is now closed.\nAccordingly, PHMSA has determined no other action is necessary and this case is now closed.\nThank you for your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\n\n\n\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#17-155733S)\n\n520186016M_Order Directing Amendment_08082019_text.pdf\n\nAugust 8, 2019\nMr. Robert Rose\nPresident\nIdaho Pipeline Corporation\nP.O. Box 15653\nBoise, Idaho 83715\nRe: CPF No. 5-2018-6016M\nDear Mr. Rose:\nEnclosed please find the Order Directing Amendment issued in the above-referenced case. It\nmakes findings of inadequate procedures and requires that Idaho Pipeline Corporation amend\ncertain operations, maintenance, and emergencies procedures. When the amendment of\nprocedures is completed, as determined by the Director, Western Region, this enforcement action\nwill be closed. Service of the Order Directing Amendment by certified mail is effective upon the\ndate of mailing, as provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Dustin Hubbard, Director, Western Office, Office of Pipeline Safety, PHMSA\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nIdaho Pipeline Corporation, ) CPF No. 5-2018-6016M\n)\n)\n)\nRespondent. )\n____________________________________)\nORDER DIRECTING AMENDMENT\nFrom September 5 through 8, 2017, and September 18 through 21, 2017, pursuant to 49 U.S.C.\n§ 60117, representatives of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of\nIdaho Pipeline Corporation’s Boise Aviation Fuel Pipeline (IDPC or Respondent), plans and\nprocedures. The IDPC’s Boise Aviation Fuel Pipeline is an 8-inch and 4-inch pipeline system\ntotaling 2.69 miles.\nAs a result of the inspection, the Director, Western Region, OPS (Director), issued to\nRespondent, by letter dated October 10, 2018, a Notice of Amendment (NOA). In accordance\nwith 49 C.F.R. § 190.206, the Notice alleged certain inadequacies in Respondent’s Operating and\nMaintenance (O&M) Manual and proposed requiring IDPC to amend its procedures to comply\nwith the provisions of 49 C.F.R. § 195.402.1\nRespondent failed to respond within 30 days of receipt of service of the NOA. To date,\nRespondent has not acknowledged or responded to the Notice. Such failure to respond\nconstitutes a waiver of IDPC’s right to contest the allegations in the NOA and authorizes the\nAssociate Administrator, without further notice, to find facts as alleged in the NOA and to issue\nan Order Directing Amendment.\nAccordingly, I find that IDPC’s procedures are inadequate to ensure safe operation of its pipeline\nsystem. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206, IDPC is ordered to make the\nfollowing revisions to its procedures:\n1. Amend its O&M procedures to include the steps or processes IDPC will follow\nfor the gathering of data needed for reporting accidents in a timely and effective\nmanner, in accordance with § 195, Subpart B.\n1 The NOA was issued in conjunction with a separate Notice of Probable Violation (CPF No. 5-2018-6015). A Final\nOrder in that case is being issued separately.\n\n\n\n5-2018-6016M\nPage 2\n2. 3. 4. 5. 6. 7. 8. 9. Amend its O&M procedures for the inspection of in-service breakout tanks in\naccordance with 49 C.F.R. § 195.432(a). At a minimum, IDPC’s procedures\nshould include all steps, based on its system, which would be followed to perform\nroutine in-service inspections of breakout tanks.\nEstablish adequate written procedures for analyzing the causes of pipeline\naccidents, in accordance with § 195.402(c)(5).\nEstablish adequate written procedures for establishing and maintaining liaison\nwith fire, police, and other appropriate public officials to learn the responsibility\nand resources of each government organization that may respond to a hazardous\nliquid pipeline emergency and acquaint the officials with IDPC’s ability in\nresponding to a hazardous liquid pipeline emergency and means of\ncommunication, in accordance with § 195.402(c)(12).\nAmend its O&M procedures for periodically reviewing the work done by its\npersonnel to determine the effectiveness of the procedures used in normal O&M,\nand take corrective action where deficiencies are found, in accordance with\n§ 195.402(c)(13). Rather than paraphrasing code requirements, IDPC procedures\nshould set forth the steps or processes in which it will achieve compliance\nspecifically for its system. For example, who would perform the review, how\noften, the method of evaluating the procedure for effectiveness, and\ndocumentation of review.\nAmend its emergency procedures to include steps or a process for receiving,\nidentifying, and classifying notices of events which need immediate response by\nIDPC or notice to fire, police, or other appropriate public officials and\ncommunicating this information to appropriate IDPC personnel for corrective\naction, in accordance with § 195.402(e)(1).\nAmend its emergency procedures to include steps or a process for prompt and\neffective response to a notice of each type of emergency, including fire or\nexplosion occurring near or directly involving a pipeline facility, accidental\nrelease of hazardous liquid from a pipeline facility, operation failure causing a\nhazardous condition, and natural disaster affecting pipeline facilities, in\naccordance with § 195.402(e)(2).\nEstablish adequate written emergency procedures for having personnel,\nequipment, instruments, tools and material available, as needed, at the scene of an\nemergency, in accordance with § 195.402(e)(3).\nEstablish adequate written emergency procedures for the process of taking\nnecessary action, such as emergency shutdown or pressure reduction, to minimize\nthe volume of hazardous liquid that is released from any section of IDPC’s\npipeline in the event of a failure, in accordance with § 195.402(e)(4).\n\n\n\n5-2018-6016M\nPage 3\n10. Establish adequate written emergency procedures on controlling the release of\nhazardous liquid at an accident scene to minimize the hazards, including possible\nintentional ignition in the cases of flammable highly volatile liquid, in accordance\n§ 195.402(e)(5).\n11. Establish adequate written emergency procedures on how to minimize the public\nexposure to injury and probability of accidental ignition, in accordance with\n§ 195.402(e)(6).\n12. Amend its emergency procedures to include steps or a process for notifying fire,\npolice, and other appropriate public officials of hazardous liquid pipeline\nemergencies, and coordinating with them preplanned and actual responses during\nan emergency, including additional precautions necessary for an emergency\ninvolving a pipeline system transporting a highly volatile liquid, in accordance\nwith § 195.402(e)(7).\n13. Amend its emergency procedures to include steps or a process for providing a\npost-accident review of employee activities to determine whether the procedures\nwere effective in each emergency and taking corrective action where deficiencies\nare found, in accordance with § 195.402(e)(9).\n14. Amend its O&M procedures to include steps or a process for enabling personnel\nwho perform operation and maintenance activities to recognize conditions that\npotentially may be safety-related conditions that are subject to the reporting\nrequirements of § 195.55, in accordance with § 195.402(f).\n15. Amend its emergency response training procedures to include steps or a process\nfor how IDPC will conduct a training program to instruct emergency response\npersonnel, in accordance with § 195.403(a)(1)-(5).\n16. Amend its emergency response training procedures to include steps or a process\non how IDPC will make appropriate changes to the emergency response training\nprogram, as necessary, to ensure that the training is effective, in accordance with\n§ 195.403(b)(2).\n17. Amend its emergency response procedures to include an explanation of how\nIDPC will require and verify that its supervisors maintain a thorough knowledge\nof the emergency response procedures for which they are responsible to ensure\ncompliance, in accordance with § 195.403(c).\n18. Amend its O&M procedures for operating, maintaining, and repairing the pipeline\nin accordance with § 195.402(c)(3). In particular, IDPC must establish adequate\nwritten procedures regarding protection against ignitions for above-ground\nbreakout tanks required by § 195.405(a) and API RP 2003, which is incorporated\nby reference. In the alternative, IDPC must establish adequate written procedures\n\n\n\n5-2018-6016M\nPage 4\nthat explain why compliance with all or certain provisions of API RP 2003 is not\nnecessary for the safety of a particular breakout tank.\n19. Establish adequate written procedures for operating, maintaining, and repairing\nthe pipeline in accordance with § 195.402(c)(3). Specifically, IDPC must\nestablish written procedures regarding the review and consideration of potentially\nhazardous conditions, safety practices, and procedures for above ground breakout\ntanks found in API Pub 2026, pursuant to § 195.405(b).\n20. Amend its written damage prevention program procedures in accordance with\n§ 195.442(a). Specifically, IDPC must clearly define its Damage Prevention\nProgram, and address the regulatory requirements listed in § 195.442.\n21. Establish an adequate written Operator Qualification (OQ) program to ensure\nthrough evaluation that individuals performing covered tasks are qualified, in\naccordance with § 195.505(b). Specifically, IDPC must establish a process or\nprocedures for establishing evaluation methods for initial and subsequent\nqualification, and pass/fail criteria for written test and/or performance evaluations.\n22. Establish adequate written OQ program procedures that include provisions to\nallow individuals who are not qualified pursuant to Part 195, Subpart G, to\nperform a covered task if directed and observed by an individual who is qualified,\nin accordance with § 195.505(c).\n23. Establish adequate written OQ program procedures that include provisions for\ncommunicating changes that affect covered tasks to individuals performing those\ntasks, in accordance with § 195.505(f).\n24. Establish adequate written procedures for operating, maintaining, and repairing\nthe pipeline in accordance with § 195.402(c)(3). Specifically, IDPC must amend\nits corrosion control procedures for maintaining current records or maps as\nrequired by § 195.589(a). IDPC must also establish procedures that require\ncurrent maps/and or records to show the location of cathodically protected\npipelines, cathodic protection facilities (including galvanic anodes, installed at\nJanuary 28, 2002), and neighboring structures bonded to cathodic protection\nsystems.\n25. Submit the amended procedures to the Director within 30 days following receipt\nof this Order.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in administrative assessment of civil penalties not\nto exceed $213,268, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each\n\n\n\n5-2018-6016M\nPage 5\nday the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nUnder 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept petitions received no later than 20 days after receipt of service of this Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays the payment of\nany civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all\nother terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nAugust 8, 2019\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n520186016M_Notice of Amendment_10102018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 10, 2018\nMr. Robert Rose\nPresident\nIdaho Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 5-2018-6016M\nDear Mr. Rose:\nOn September 5 through 8, and September 18 through 21, 2017, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected Idaho Pipeline Corporation’s (IDPC) procedures for operations and maintenance in\nBoise, Idaho.\nBased on the inspection, PHMSA has identified apparent inadequacies found within IDPC’s plans or\nprocedures. Preliminarily, PHMSA noted during the inspection that many of IDPC’s procedures\nrepeat or paraphrase the regulatory text, instead of providing instruction or a process for how to\nimplement the regulatory requirement, as further described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at\nintervals not exceeding 15 months, but at least once each calendar year, and appropriate\nchanges made as necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and appropriate parts\nshall be kept at locations where operations and maintenance activities are conducted.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) . . .\n(2) Gathering of data needed for reporting accidents under subpart B of this part in a\n\n\n\ntimely and effective manner.\nIDPC’s procedural manual for operations, maintenance and emergencies (O&M) did not include\nadequate procedures for the gathering of data needed for reporting accidents in accordance with 49\nC.F.R. §195, Subpart B. Although Section 3.3 of IDPC’s O&M Manual mentions reporting accidents,\nIDPC did not have a detailed procedure for gathering necessary data for reporting accidents in a timely\nand effective manner. Instead, IDPC’s O&M only paraphrased the code requirements, and did not set\nforth the steps or processes the operator will follow to achieve the code requirements. For example, a\nprocedure could identify what information should be gathered for reporting accidents, who is\nresponsible for completion of this task, and deadlines to ensure the data is received in a timely\n1\nmanner.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nIDPC’s O&M did not include adequate written procedures for the inspection of in-service breakout\ntanks in accordance with §195.432(a).2 At the time of the inspection, IDPC’s O&M failed to have a\nwritten procedure describing the methods for performing routine in-service atmospheric and low-\npressure steel above-ground breakout tank inspections, including specification of an interval to comply\nwith the regulatory deadline. At a minimum, IDPC’s procedure should include all steps, based on the\noperator’s system that would be followed to perform routine in-service inspections of breakout tanks.\nThis procedure could include, but not be limited to, inspection information on evidence of leaks, shell\ndistortions, conditions of the foundations, and paint coatings.\n3. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n1 This example, or any example included in this Notice, is not an inclusive list of possible revisions to IDPC’s\nwritten procedures. All written procedures developed in response to this Notice should be specific to the operator’s\nsystem and not solely reliant on the limited proposed revisions PHMSA may suggest in this Notice.\n2 See 49 C.F.R. §195.432(a) (requiring operators, at intervals not exceeding 15 months, but at least once each\ncalendar year, to inspect each in-service breakout tank except for breakout tanks covered in (b) and (c) of that\nsection).\n2\n\n\n\n(1) . . .\n(5) Analyzing pipeline accidents to determine their causes.\nIDPC did not establish adequate written procedures for analyzing the causes of pipeline accidents in\naccordance with §195.402(c)(5). At the time of the inspection, IDPC’s O&M Manual did not have a\nsection or a procedure for analyzing pipeline accidents to determine their causes.\n4. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) . . .\n(12) Establishing and maintaining liaison with fire, police, and other appropriate public\nofficials to learn the responsibility and resources of each government organization that\nmay respond to a hazardous liquid or carbon dioxide pipeline emergency and acquaint\nthe officials with the operator's ability in responding to a hazardous liquid or carbon\ndioxide pipeline emergency and means of communication.\nIDPC did not establish adequate written procedures for establishing and maintaining liaison with fire,\npolice, and other appropriate public officials to learn the responsibility and resources of each\ngovernment organization that may respond to a hazardous liquid or carbon dioxide pipeline emergency\nand acquaint the officials with the operator's ability in responding to a hazardous liquid or carbon\ndioxide pipeline emergency and means of communication in accordance with §195.402(c)(12). At the\ntime of the inspection, IDPC did not have a procedure in place to explain how it establishes and\nmaintains liaison with emergency response personnel.\n5. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) . . .\n(13) Periodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and taking\ncorrective action where deficiencies are found.\nIDPC did not establish adequate written O&M procedures to periodically review the work done by its\npersonnel to determine the effectiveness of the procedures used in normal operation and maintenance,\nand take corrective action where deficiencies are found in accordance with §195.402(c)(13). At the\ntime of the inspection, it was noted that IDPC’s O&M manual did not have a procedure for\nperiodically reviewing the work done by operator personnel to determine the effectiveness of the\nprocedures. Instead, IDPC’s O&M only paraphrased the code requirements, and did not set forth the\nsteps or process in which the operator will achieve the code requirements, such as who would perform\nthe review and how often, the method of evaluating the procedure for effectiveness (i.e., direct\nobservation, near miss data, employee feedback, etc.), and documentation of the review.\n6. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a)…\n(e) Emergencies. The manual required by paragraph (a) of this section must include\n3\n\n\n\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) Receiving, identifying, and classifying notices of events which need immediate\nresponse by the operator or notice to fire, police, or other appropriate public officials\nand communicating this information to appropriate operator personnel for corrective\naction.\nIDPC did not establish adequate written emergency procedures for receiving, identifying and\nclassifying notices of events which need immediate response by the operator or notice to fire, police,\nor other appropriate public officials and communicating this information to appropriate operator\npersonnel for corrective action in accordance with §195.402(e)(1). At the time of the inspection,\nIDPC’s emergency operations, Section 3.0 of the O&M Manual, failed to have a procedure for\nreceiving, identifying, and classifying notices of events which need immediate response and providing\nnotice to operator personnel or to fire, police or other appropriate officials, as appropriate, for\ncorrective action. Instead, IDPC’s O&M only paraphrased the code requirements, and did not set\nforth the steps or process the operator will take to achieve the code requirements.\n7. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) . . .\n(2) Prompt and effective response to a notice of each type emergency, including fire or\nexplosion occurring near or directly involving a pipeline facility, accidental release of\nhazardous liquid or carbon dioxide from a pipeline facility, operational failure causing a\nhazardous condition, and natural disaster affecting pipeline facilities.\nIDPC did not establish adequate written emergency procedures for prompt and effective response to a\nnotice of each type emergency in accordance with §195.402(e)(2). At the time of the inspection,\nIDPC’s emergency operations, Section 3.0 of the O&M Manual, failed to have a procedure for making\na prompt and effective response to a notice of a fire, explosion, accidental release of a hazardous\nliquid, operational failure causing a hazardous condition, or natural disaster affecting the\npipeline. Instead, IDPC’s O&M only paraphrased the code requirements, and did not set forth the\nsteps or process it will take to achieve the code requirements including, for example, how it will\naccomplish a “prompt and effective” response to these emergencies.\n8. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) . . .\n(3) Having personnel, equipment, instruments, tools, and material available as needed at\nthe scene of an emergency.\nIDPC did not establish adequate written emergency procedures for having personnel, equipment,\ninstruments, tools and material available at the scene of an emergency in accordance with\n§195.402(e)(3). At the time of the inspection, IDPC’s emergency plan failed to include a procedure to\nensure the availability of personnel, equipment, instruments, tools, and materials as needed at the\nscene of an emergency.\n4\n\n\n\n9. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) . . .\n(4) Taking necessary action, such as emergency shutdown or pressure reduction, to\nminimize the volume of hazardous liquid or carbon dioxide that is released from any\nsection of a pipeline system in the event of a failure.\nIDPC did not establish adequate written emergency procedures for taking necessary action to\nminimize the volume of hazardous liquid releases in accordance with §195.402(e)(4). At the time of\nthe inspection, IDPC’s emergency plan failed to include a procedure for taking necessary action, such\nas an emergency shutdown or pressure reduction, to minimize the volume released from any section of\na pipeline system in the event of a failure.\n10. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) . . .\n(5) Control of released hazardous liquid or carbon dioxide at an accident scene to\nminimize the hazards, including possible intentional ignition in the cases of flammable\nhighly volatile liquid.\nIDPC did not establish adequate written emergency procedures on how to control the release of\nhazardous liquid at an accident scene in accordance with §195.402(e)(5). At the time of the inspection,\nIDPC’s emergency plan failed to include a procedure for controlling the release of liquid at an\naccident scene to minimize the hazards, including possible intentional ignition in the cases of\nflammable highly volatile liquid.\n11. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) . . .\n(6) Minimization of public exposure to injury and probability of accidental ignition by\nassisting with evacuation of residents and assisting with halting traffic on roads and\nrailroads in the affected area, or taking other appropriate action.\nIDPC did not establish adequate written emergency procedures on how to minimize the public\nexposure to injury and probability of accidental ignition in accordance with §195.402(e)(6). At the\ntime of the inspection, IDPC’s emergency plan failed to include a procedure for minimizing public\nexposure to injury and probability of accidental ignition by assisting with evacuation, assisting with\nhalting traffic on roads and railroads, or taking other appropriate action.\n12. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n5\n\n\n\n(1) . . .\n(7) Notifying fire, police, and other appropriate public officials of hazardous liquid or\ncarbon dioxide pipeline emergencies and coordinating with them preplanned and actual\nresponses during an emergency, including additional precautions necessary for an\nemergency involving a pipeline system transporting a highly volatile liquid.\nIDPC did not establish adequate written emergency procedures for notifying fire, police, and other\nappropriate public officials of hazardous liquid or carbon dioxide pipeline emergencies, and\ncoordinating with them preplanned and actual responses during an emergency, including additional\nprecautions necessary for an emergency involving a pipeline system transporting a highly volatile\nliquid, in accordance with §195.402(e)(7). At the time of the inspection, IDPC’s emergency plan failed\nto include a procedure for notifying fire, police, and other appropriate public officials of hazardous\nliquid emergencies and coordinating with them preplanned and actual responses during an emergency.\nInstead, IDPC’s O&M only paraphrased the code requirements, and did not set forth the steps or\nprocess in which it will achieve the code requirements.\n13. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) . . .\n(9) Providing for a post accident review of employee activities to determine whether the\nprocedures were effective in each emergency and taking corrective action where\ndeficiencies are found.\nIDPC did not establish adequate written emergency procedures for providing a post-accident review of\nemployee activities to determine the effectiveness of the procedures and to take corrective action\nwhere deficiencies are found in accordance with §195.402(e)(9). At the time of the inspection, IDPC’s\nemergency plan failed to include a procedure for providing for a post-accident review of employee\nactivities to determine whether the procedures were effective in each emergency and taking corrective\naction where deficiencies are found. IDPC’s O&M only paraphrased the code requirements, and did\nnot set forth the steps or process in which it will achieve the code requirements.\n14. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(f) Safety-related condition reports. The manual required by paragraph (a) of this section\nmust include instructions enabling personnel who perform operation and maintenance\nactivities to recognize conditions that potentially may be safety-related conditions that\nare subject to the reporting requirements of § 195.55.\nIDPC did not establish adequate written safety-related condition reports procedures in accordance with\n§195.402(f). At the time of the inspection, IDPC’s O&M Manual, Section 3.4 - Safety Related\nCriteria, simply paraphrased the code requirements, and did not set forth the steps or process in which\nIDPC will achieve the code requirements.\n15. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at\nintervals not exceeding 15 months, but at least once each calendar year, and appropriate\n6\n\n\n\nchanges made as necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and appropriate parts\nshall be kept at locations where operations and maintenance activities are conducted.\nIDPC did not establish adequate written emergency response training procedures in accordance with\n§195.403. At the time of the inspection, it was noted that IDPC’s O&M, Section 3.2 - Emergency\nResponse Training, page 11 and 12, only paraphrased the code requirements, and did not set forth the\nsteps or process in which IDPC will conduct a training program to instruct emergency response\npersonnel as required by §195.403(a)(1-5).\n16. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at\nintervals not exceeding 15 months, but at least once each calendar year, and appropriate\nchanges made as necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and appropriate parts\nshall be kept at locations where operations and maintenance activities are conducted.\nIDPC did not establish adequate written emergency response training procedures on how to make\nappropriate changes to the emergency response training program as necessary to ensure that it is\neffective in accordance with §195.403(b)(2). At the time of the inspection, it was noted that IDPC’s\nO&M, Section 3.2.2, page 12, only paraphrased the code requirements, and did not set forth a process\nor procedure on how IDPC would ensure that its emergency response training program is effective.\n17. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at\nintervals not exceeding 15 months, but at least once each calendar year, and appropriate\nchanges made as necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and appropriate parts\nshall be kept at locations where operations and maintenance activities are conducted.\nIDPC did not have adequate written procedures to carry out the emergency procedures established\nunder §195.402(e) in violation of §195.402(a), which requires that each operator prepare and follow a\nwritten set of procedures for emergencies. Specifically, IDPC’s written procedures failed to explain\nhow it would require and verify that its supervisors maintain a thorough knowledge of the emergency\nresponse procedures for which they are responsible to ensure compliance pursuant to §195.403(c).\n18. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(1) . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nIDPC did not establish adequate written procedures for operating, maintaining, and repairing the\npipeline in accordance with subpart F in violation of §195.402(c)(3). Specifically, IDPC failed to have\n7\n\n\n\nsufficient written procedures regarding protection provided against ignitions for above-ground\nbreakout tanks in accordance with §195.405(a). At the time of the inspection, IDPC’s O&M Manual,\nSection 6.5.1 - Breakout Tank Procedures, page 26, paraphrased the code requirements, and did not set\nforth the steps or process in which IDPC would achieve the code requirements in accordance with API\nRP 2003.3\n19. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance\nand normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nIDPC did not establish adequate written procedures for operating, maintaining, and repairing the\npipeline in accordance with in violation of §195.402(c)(3). Specifically, IDPC failed to have\nsufficient written procedures regarding potentially hazardous conditions, safety practices, and\nprocedures in API Pub 2026 for above-ground breakout tanks in accordance with §195.405(b). At the\ntime of the inspection, IDPC failed to mention this regulatory requirement in its O&M Manual.\n20. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at\nintervals not exceeding 15 months, but at least once each calendar year, and appropriate\nchanges made as necessary to insure that the manual is effective. This manual shall be\nprepared before initial operations of a pipeline system commence, and appropriate parts\nshall be kept at locations where operations and maintenance activities are conducted.\nIDPC did not establish an adequate written damage prevention program in accordance with\n§195.442(a). At the time of the inspection, it was noted that IDPC’s Damage Prevention Program was\nnot clearly defined. The requirements of the program and procedures were vague and it appeared that\nIDPC was confusing with the requirements for damage prevention with the requirements of a public\nawareness program under §195.440. Further, IDPC’s Damage Prevention Program did not have\nprovisions for most of the regulatory requirements listed in §195.442.\n21. §195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The program shall\ninclude provisions to:\n(a) . . .\n(b) Ensure through evaluation that individuals performing covered tasks are qualified.\nIDPC did not establish an adequate written Operator Qualifications (OQ) progr","truncated":true,"body_characters":46239}