TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC — Notice of Amendment

party submissionOfficial PDF520195012M_Operator Response to Notice_12192019.pdf#

520195012M_Notice of Amendment_12052019_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED December 5, 2019 Mr. Hugh Harden V.P. Operations Engineering EHS Trans Mountain Pipeline (Puget Sound) LLC 300 5th Avenue SW Suite 2700 Calgary, Alberta T2P 5J2 Canada CPF 5-2019-5012M Dear Mr. Harden: On May 7 through 9, 2019, a representative of the Washington Utilities and Transportation Commission (UTC), on behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Trans Mountain Pipeline (Puget Sound) LLC’s procedures for Operations and Control Room Management in Bellingham, Washington. On the basis of the inspection, UTC has identified the apparent inadequacies found within Trans Mountain Pipeline (Puget Sound) LLC plans or procedures, as described below: 1. 195.446 Control Room Management (d) Fatigue mitigation. Each operator must implement the following methods to reduce the risk associated with controller fatigue that could inhibit a controller's ability to carry out the roles and responsibilities the operator has defined: (1) … (4) Establish a maximum limit on controller hours-of-service, which may provide for an emergency deviation from the maximum limit if necessary for the safe operation of a pipeline facility.#

520195012M_Notice of Amendment_12052019_text.pdf, page 2Section 3.5 entitled “Fatigue Mitigation Standard” located in Puget Sound’s Operations and Control Room Management procedures is inadequate because it did not establish a maximum limit on controller hours-of-service, which may provide for an emergency deviation from the maximum limit if necessary for the safe operation of a pipeline facility.1 Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If 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. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days 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 Trans Mountain Pipeline (Puget Sound) LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2019-5012M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dustin Hubbard 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 A. Ceartin (#166717) Sean Mayo, Pipeline Safety Director, Washington Utilities and Transportation Commission 1 The operator is encouraged, but not ordered, to consider the recommendations located in API Recommended Practice 1168, Section 7 on fatigue management. 2#

520195012M_Closure Letter_01272020_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED January 27, 2020 Mr. Hugh Harden V.P. Operations Engineering EHS Trans Mountain Pipeline (Puget Sound) LLC 300 5th Avenue SW Suite 2700 Calgary, Alberta T2P 5J2 Canada CPF 5-2019-5012M Closure Letter Dear Mr. Harden: On May 7 through 9, 2019, a representative of the Washington Utilities and Transportation Commission (UTC), on behalf of 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 Trans Mountain Pipeline (Puget Sound) LLC’s procedures for Operations and Control Room Management in Bellingham, Washington. As a result of the inspection, Trans Mountain Pipeline (Puget Sound) LLC was issued a Notice of Amendment on December 5, 2019, which proposed amendment of your procedures. Trans Mountain Pipeline (Puget Sound) LLC submitted its amended procedures on December 19, 2019. 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 is now closed. Thank you for your cooperation. Sincerely, Dustin Hubbard Director, Western Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 A. Ceartin (#166717) Sean Mayo, Pipeline Safety Director, Washington Utilities and Transportation Commission#