{"operation":"document","citation":"CPF 520206002M","title":"WYOMING PIPELINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-12-30","effective_on":null,"summary":"CLOSED notice of amendment citing 195.202, 195.402(a), 195.402(c)(1), 195.402(c)(14), 195.402(c)(3), 195.402(d), 195.405(a), 195.432(b), 195.440(c), 195.442(c)(1), 195.442(c)(3), 195.452(b)(1), 195.452(f)(1), 195.452(f)(3), 195.452(f)(5), 195.452(f)(6), 195.555, 195.573(a)(2), 195.573(e), 195.575(e), 195.579(d), 195.587, 195.591.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520206002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520206002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520206002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520206002M","body":"Notice of Amendment involving WYOMING PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.402(a),  195.402(c)(1),  195.402(c)(14),  195.402(c)(3),  195.402(d),  195.405(a),  195.432(b),  195.440(c),  195.442(c)(1),  195.442(c)(3),  195.452(b)(1),  195.452(f)(1),  195.452(f)(3),  195.452(f)(5),  195.452(f)(6),  195.555,  195.573(a)(2),  195.573(e),  195.575(e),  195.579(d),  195.587,  195.591. The case was opened on 2020-12-30 and is reported as closed as of 2021-12-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520206002M_Closure Letter_12292021_(19-163167S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/520206002M/520206002M_Closure%20Letter_12292021_(19-163167S).pdf\n\n520206002M_Closure Letter_12292021_(19-163167S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520206002M/520206002M_Closure%20Letter_12292021_(19-163167S)_text.pdf\n\n520206002M_Notice of Amendment_12302020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520206002M/520206002M_Notice%20of%20Amendment_12302020.pdf\n\n520206002M_Notice of Amendment_12302020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520206002M/520206002M_Notice%20of%20Amendment_12302020_text.pdf\n\n520206002M_Operator Response to Notice_03302021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520206002M/520206002M_Operator%20Response%20to%20Notice_03302021.pdf\n\n520206002M_Closure Letter_12292021_(19-163167S)_text.pdf\n\nVIA E-MAIL TO MR. JOSEPH ISRAEL\nDecember 29, 2021\nMr. Joseph Israel\nPresident & CEO\nPar Pacific LLC\nPar Pacific Holdings, Inc.\n825 Town & Country Lane, Suite 1500\nHouston, TX 77024\nCPF 5-2020-6002M\nClosure Letter\nDear Mr. Israel:\nDuring the weeks of January 14 through 25, March 18 through 22, July 29 through August 2,\nSeptember 16 through 20, and December 9 through 12, 2019, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Ellsjet Terminal and Wyoming Crude Pipeline’s procedures for\nOperations and Maintenance, Emergency Response, Integrity Management, Time Dependent\nThreats, Damage Prevention, and Public Awareness. Ellsjet and Wyoming Crude Pipeline are\nsubsidiaries of Par Pacific Holdings, Inc. (collectively, “Par Pacific”) and use the same set of\nwritten procedures.\nAs a result of the inspection, Par Pacific was issued a Notice of Amendment on December 30,\n2020, which proposed amendment of your procedures.\nAfter requesting and receiving an extension of time to respond, Par Pacific responded in a letter\ndated March 30, 2021 (Response). A subsequent Inadequte Response was sent to Par Pacific on\nMay 10, 2021. Par Pacific submitted a subsequent response on May 27, 2021.\nAfter an informal meeting with Mat Ellman on November 22, 2021, Par Pacific resubmitted\nrevised procedures via email on December 9, 2021, to address outstanding Items #3, 20, and 21\nof the NOA. After a brief conversation with Mr. Ellman on December 15, 2021, Mr. Ellman\nfurther provided an amended procedure to clarify Item #3. This was received on December 17,\n2021, via email.\n\n\n\nMy staff has reviewed the amended procedures, and it appears that the inadequacies outlined in\nthis 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\nfor your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#19-163167S)\nMat Ellman, Par Pacific (Wyoming Pipeline)\n\n520206002M_Notice of Amendment_12302020_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MR. JOSEPH ISRAEL\nDecember 30, 2020\nMr. Joseph Israel\nPresident & CEO\nPar Pacific LLC\nPar Pacific Holdings, Inc.\n825 Town & Country Lane, Suite 1500\nHouston, TX 77024\nCPF 5-2020-6002M\nDear Mr. Israel:\nDuring the weeks of January 14 through 25, March 18 through 22, July 29 through August 2,\nSeptember 16 through 20, and December 9 through 12, 2019, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected Ellsjet Terminal and Wyoming Crude Pipeline’s procedures for\nOperations and Maintenance, Emergency Response, Integrity Management, Time Dependent\nThreats, Damage Prevention, and Public Awareness. Ellsjet and Wyoming Crude Pipeline are\nsubsidiaries of Par Pacific Holdings, Inc. (collectively, “Par Pacific”) and use the same set of\nwritten procedures.\nBased on the inspection, PHMSA has identified the apparent inadequacies/deficiencies found\nwithin your plans or procedures, as described below:\n\n\n\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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:\n1) Making construction records, maps, and operating history available as necessary\nfor safe operation and maintenance.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific does not have a procedure that requires applicable construction records\nto be maintained for the life of each pipeline pursuant to § 195.266. Par Pacific’s procedure for\npipeline repair contains applicable records and retention, but this does not apply to construction.\nPar Pacific must develop a written procedure to address this deficiency.\nIn addition to construction records, Par Pacific does not have a process in place for making maps\nand operating history available as necessary for safe operation and maintenance. Par Pacific must\ndevelop a procedure to address this deficiency.\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\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n1) Making construction records, maps, and operating history available as necessary\nfor safe operation and maintenance.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nWhile Par Pacific has a procedure to pressure test line pipe, a procedure for pressure testing\naboveground breakout tanks pursuant to §195.307(c) is not developed and/or documented,\nincluding the requirement to maintain these records.1 Par Pacific must develop a written\nprocedure to address this deficiency.\n3. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\n1 See 49 C.F.R. § 195.310 (requiring operators maintain pressure test records).\n2\n\n\n\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific failed to have a procedure that requires personnel, who perform or will\nperform inspections to ensure pipe or pipeline systems are installed in accordance with the\nrequirements of Subpart D of Part 195, are required to be trained and qualified in the phase of\nconstruction inspected or to be inspected, pursuant to §195.204. Par Pacific must develop a\nwritten procedure to address this deficiency.\n4. §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. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific does not have written procedures in place for the Management of\nChange (MOC) process, when it makes changes as necessary to ensure its manual of written\nprocedures for conducting normal operations and maintenance activities and handling abnormal\noperations and emergencies is effective as required by § 195.402(a). Par Pacific must develop a\nwritten procedure to address MOC.\n5. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(d) Abnormal operation. The manual required by paragraph (a) of this section must\ninclude procedures for the following to provide safety when operating design limits\nhave 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 operating limits;\n(iii) Loss of communications;\n(iv) Operation of any safety device;\n(v) Any other malfunction of a component, deviation from normal operation, or\npersonnel error which could cause a hazard to persons or property.\n(2) Checking variations from normal operation after abnormal operation has ended\nat sufficient critical locations in the system to determine continued integrity and safe\noperation.\n3\n\n\n\n(3) Correcting variations from normal operation of pressure and flow equipment\nand controls.\n(4) Notifying responsible operator personnel when notice of an abnormal operation\nis received.\n(5) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking\ncorrective action where deficiencies are found.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific does not have a written procedure detailing how they will respond to,\ninvestigate, and correct the cause(s) of any of the scenarios listed in § 195.402(d)(1)(i)-(v).\nAlthough Par Pacific has a form for documenting abnormal operations (Abnormal Operating\nEvent – no form number, date, or revision number), it does not have written procedures\ndescribing the process the company uses for responding to an abnormal event.\nFurther, Par Pacific does not have written procedures for checking variations from normal\noperation after abnormal operations have ended at sufficient locations in the system to determine\ncontinued integrity and safe operation. Par Pacific must develop a procedure to address this\ndeficiency.\nPar Pacific also does not have written procedures for correcting variations from normal operation\nof pressure and flow equipment and controls. Par Pacific must develop a procedure to address\nthis deficiency.\nFinally, Par Pacific does not have written procedures for periodically reviewing the response of\noperating personnel to determine the effectiveness of the procedures for controlling abnormal\noperation and taking corrective action where deficiencies are found. Par Pacific must develop a\nprocedure to address this deficiency.\n6. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.405 Protection against ignitions and safe access/egress involving floating\nroofs.\n(a) After October 2, 2000, protection provided against ignitions arising out of static\nelectricity, lightning, and stray currents during operation and maintenance\nactivities involving aboveground breakout tanks must be in accordance with API\nRP 2003 (incorporated by reference, see § 195.3), unless the operator notes in the\n4\n\n\n\nprocedural manual (§ 195.402(c)) why compliance with all or certain provisions of\nAPI RP 2003 is not necessary for the safety of a particular breakout tank.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures do not contain a reference to ignitions arising out\nof static electricity, lightning, and stray currents during operation and maintenance activities of\naboveground breakout tanks pursuant to API RP 2003, nor does its procedural manual (if\napplicable) explain why compliance is not necessary for the safety of particular tanks, pursuant\nto the requirements set forth in §195.405(a). Par Pacific must develop a procedure to address this\ndeficiency.\n7. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.405 Protection against ignitions and safe access/egress involving floating\nroofs.\n(a) …\n(b) The hazards associated with access/egress onto floating roofs of in-service\naboveground breakout tanks to perform inspection, service, maintenance, or repair\nactivities (other than specified general considerations, specified routine tasks or\nentering tanks removed from service for cleaning) are addressed in API Pub 2026\n(incorporated by reference, see §195.3). After October 2, 2000, the operator must\nreview and consider the potentially hazardous conditions, safety practices, and\nprocedures in API Pub 2026 for inclusion in the procedure manual (§195.402(c))\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific does not have a written procedure associated with safety practices in\nAPI Publication 2026, despite having numerous in-service aboveground breakout tanks with\nfloating roofs. Par Pacific must develop a procedure to address this deficiency, or explain to\nPHMSA how it reviewed and considered these procedures, and determined not to include them\nin its procedural manual.\n8. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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:\n5\n\n\n\n(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.408 Communications.\n(a) Each operator must have a communication system to provide for the\ntransmission of information needed for the safe operation of its pipeline system.\n(b) The communication system required by paragraph (a) of this section must, as a\nminimum, include means for:\n(1) Monitoring operational data as required by §195.402(c)(9);\n(2) Receiving notices from operator personnel, the public, and public authorities of\nabnormal or emergency conditions and sending this information to appropriate\npersonnel or government agencies for corrective action;\n(3) Conducting two-way vocal communication between a control center and the\nscene of abnormal operations and emergencies; and\n(4) Providing communication with fire, police, and other appropriate public officials\nduring emergency conditions, including a natural disaster.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific does not have a written procedure that addresses communication\nrequirements set forth in § 195.408. Par Pacific must develop a procedure to address\ncommunication systems to provide for the transmission of information needed for the safe\noperation of its pipeline system, including all the requirements set forth in § 195.408(b).\n9. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.412 Inspection of rights-of-way and crossings under navigable waters.\n(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times each\ncalendar year, inspect the surface conditions on or adjacent to each pipeline right-\nof-way. Methods of inspection include walking, driving, flying or other appropriate\nmeans of traversing the right-of-way.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s procedures for inspection of rights-of-way state that follow-up\nactivities associated with reportable observances shall be documented on Form LFM033-01.\nHowever, there is no reference or area on the form to document these required follow-ups.\n6\n\n\n\nAdditionally, the form dated August 27, 2017 indicates it to be Revision #1 but the revision log\nshows that Revision #2 was performed in 2013. Par Pacific must revise this procedure and form\nto ensure that the written procedures are accurately and effectively documented and followed on\nthe corresponding form. Furthermore, if this is a corporate procedure that applies to all Par\nPacific assets, the procedure should have ownership to prevent field changes without appropriate\nreview and approval.\n10. §195.440 Public awareness.\n(a) …\n(c) The operator must follow the general program recommendations, including\nbaseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why compliance\nwith all or certain provisions of the recommended practice is not practicable and\nnot necessary for safety.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written Public Awareness Program does not follow the general\nprogram recommendations of API RP 1162, nor does the company provide justification why\ncompliance is not practicable and necessary for safety. Specifically, Par Pacific’s program fails\nto address the pre-test effectiveness of materials and the sample size appropriate to draw general\nconclusions as recommended in API RP 1162. Par Pacific must develop procedures for these\nsubject areas in its public awareness program.\n11. §195.442 Damage prevention program.\n(a) . . . .\n(c) The damage prevention program required by paragraph (a) of this section must,\nat a minimum:\n(1) Include the identity, on a current basis, of persons who normally engage in\nexcavation activities in the area in which the pipeline is located.\n(3) Provide a means of receiving and recording notification of planned excavation\nactivities.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written damage prevention program does not address how reports of\nthird-party activity and the names of associated excavators are input into the mail-outs and\ncommunications with excavators near their system. Furthermore, the procedure does not specify\nhow reports of third-party damage are checked against one call tickets in the event of damage\nduring excavation activities. Par Pacific must develop a procedure to address these deficiencies.\n12. §195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(b) What program and practices must operators use to manage pipeline integrity?\nEach operator of a pipeline covered by this section must:\n7\n\n\n\n(1) Develop a written integrity management program that addresses the risks on\neach segment of pipeline in the first column of the following table no later than the\ndate in the second column:\nPipeline\nDate\nCategory 1\nMarch 31, 2002.\nCategory 2\nFebruary 18, 2003.\nCategory 3\n1 year after the date the\npipeline begins operation.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific's written Integrity Management program does not include procedures\nfor determining risk factors for establishing an assessment schedule that prioritizes segments for\nassessment pursuant to § 195.452(e) and (j). Par Pacific must develop a process that includes all\nrisk factors that reflect the risk conditions on each pipeline segment and must consider at a\nminimum all the factors set forth in §195.452(e)(1)(i)-(ix).\n13. 8195.452 Pipeline integrity management in high consequence areas.\n(a)....\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area;\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\n(5) A continual process of assessment and evaluation to maintain a pipeline's\nintegrity (see paragraph (j) of this section);\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific's written Integrity Management program did not provide the technical\njustification behind the quarter mile buffer zone in the IMP plan and the half mile buffer used in\nhe HCA identification.2 Par Pacific's procedure states that breakout tanks are calculated usıng\n2 See 49 C.F.R. § 195.452(I)(2) (requiring operators to maintain, for the useful life of the pipeline, \"documents to\nvariances, and actions taken to implement and evaluate each element of the integrity management program listed in\nsupport the decisions and analyses, including any modifications, justifications, deviations and determinations made,\nparagraph (f of this section\").\n8\n\n\n\nworst-case tank release volume but no other type of facility is listed. Par Pacific must develop\nwritten procedures in its IMP to determine the worst-case volume of commodity releases for the\nentire pipeline system.\nFurther, Par Pacific does not have written integrity management plan procedures that specifically\naddress facilities. Par Pacific must develop specific IM procedures for all of its facilities in\nHCAs or HCA could-affect areas pursuant to the requirements set forth in § 195.452(f).3\n14. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge of\nthat portion of the corrosion control procedures established under §195.402(c)(3)\nfor which they are responsible for insuring compliance.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.555. Par Pacific’s written procedures do not offer adequate detail on what\nit means to have a thorough knowledge of the portion of the corrosion control procedures for\nwhich its supervisors are responsible for ensuring compliance, nor do they contain a method to\nverify the required knowledge.4 Par Pacific must develop written procedures that offer sufficient\ndetail on what it means to have a thorough knowledge of the corrosion control procedures for\nwhich supervisors are responsible, as well as a method to verify the required knowledge.\n15. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n3 See 49 C.F.R. §§ 195.452(a) (noting that integrity management regulations apply to each hazardous liquid pipeline\nand carbon dioxide pipeline that could affect a high consequence area, including any pipeline located in a high\nconsequence area…) and 195.2 (defining the term “pipeline” as “all parts of a pipeline facility through which a\nhazardous liquid or carbon dioxide moves in transportation, including but not limited to line pipe, valves, and other\nappurtenances connected to line pipe, pumping units, fabricated assemblies associated with pumping units, metering\nand delivery stations and fabricated assemblies therein, and breakout tanks”).\n4 See 49 C.F.R. §§ 195.589(c) (requiring operators maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by subpart H in sufficient detail to\ndemonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist).\n9\n\n\n\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with §195.571:\n(1) . . .\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE SP 0169 (incorporated by reference, see §195.3).\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.573(a)(2). Par Pacific does not have criteria for when a close-interval\nsurvey will be conducted to accomplish the objectives of NACE SP 0169 Paragraph 10.1.1.3.\nPar Pacific must develop criteria in its written procedures to determine the circumstances in\nwhich a close-interval survey or comparable technology is practicable and necessary to\naccomplish the objectives of NACE SP 0169 Paragraph 10.1.1.3.\n16. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n10\n\n\n\n§195.573 What must I do to monitor external corrosion control?\n(a) . . .\n(e) Corrective action. You must correct any identified deficiency in corrosion control\nas required by §195.401(b). However, if the deficiency involves a pipeline in an\nintegrity management program under §195.452, you must correct the deficiency as\nrequired by §195.452(h).\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.573(e). Par Pacific’s corrosion control procedure for breakout tanks does\nnot require correction of deficiencies within the appropriate timeframes applicable under §§\n195.401(b) or 195.452(h). Further, Par Pacific’s corrosion control procedures do not address\ncorrecting deficiencies on corrosion control equipment. Par Pacific must amend its corrosion\ncontrol procedures to address the deficiencies noted above.\n17. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n(a) . . .\n(e) If a pipeline is in close proximity to electrical transmission tower footings,\nground cables, or counterpoise, or in other areas where it is reasonable to foresee\nfault currents or an unusual risk of lightning, you must protect the pipeline against\ndamage from fault currents or lightning and take protective measures at insulating\ndevices.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.575(e). Par Pacific’s procedure states that facilities will be protected from\nfault currents and lightning but does not state how it protects its pipelines.5 Par Pacific must\ndevelop written procedures explaining what protective measures the company will take to protect\n5 See 49 C.F.R. §§ 195.589(c) (requiring operators maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by subpart H in sufficient detail to\ndemonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist).\n11\n\n\n\npipelines in close proximity to electrical transmission tower footings, ground cables or\ncounterpoise, or in other areas where it is reasonable to foresee fault currents or an unusual risk\nof lightening, from these dangers.\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\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.579 What must I do to mitigate internal corrosion?\n(a) . . .\n(d) Breakout Tanks. After October 2, 2000, when you install a tank bottom lining in\nan aboveground breakout tank built to API Spec 12F (incorporated by reference,\nsee §195.3), API Std 620 (incorporated by reference, see §195.3), API Std 650\n(incorporated by reference, see §195.3), or API Std 650’s predecessor, Standard\n12C, you must install the lining in accordance with API RP 652 (incorporated by\nreference, see §195.3). However, you don’t need to comply with API RP 652 when\ninstalling any tank for which you note in the corrosion control procedures\nestablished under §195.402(c)(3) why compliance with all or certain provisions of\nAPI RP 652 is not necessary for the safety of the tank.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.579(d). Par Pacific’s procedure LOM022 Breakout Tanks (1/19/2017,\nRev. 3) fails to require that tank bottom linings built to API Spec 12F, API Std 620, API Std 650\nor its predecessor, Standard 12C, be installed in accordance with API RP 652, or why\ncompliance with all or certain provisions of API RP 652 is not necessary for the safety of the\ntank. Par Pacific must develop a written procedure to address the requirements of § 195.579(d)\nor demonstrate why compliance is not necessary for the safety of the tank.\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\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . . .\n12\n\n\n\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.587 What methods are available to determine the strength of corroded pipe?\nUnder §195.585, you may use the procedure in ASME/ANSI B31G (incorporated by\nreference, see §195.3) or in PRCI PR-3-805 (R-STRENG) (incorporated by\nreference, see §195.3) to determine the strength of corroded pipe based on actual\nremaining wall thickness. These procedures apply to corroded regions that do not\npenetrate the pipe wall, subject to the limitations set out in the respective\nprocedures.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.587. Par Pacific’s written procedures do not provide sufficient\ninformation and direction on measuring and documenting the actual remaining wall thickness to\ndetermine the strength of corroded pipe. Par Pacific must develop procedures to address this\ndeficiency.\n20. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.591 In-Line inspection of pipelines.\nWhen conducting in-line inspection of pipelines required by this part, each operator\nmust comply with the requirements and recommendations of API Std 1163, Inline\nInspection Systems Qualification Standard; ANSI/ASNT ILI-PQ, Inline Inspection\nPersonnel Qualification and Certification; and NACE SP0102-2010, Inline Inspection\nof Pipelines (incorporated by reference, see §195.3). An in-line inspection may also\nbe conducted using tethered or remote control tools provided they generally comply\nwith those sections of NACE SP0102-2010 that are applicable.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s written procedures for operating, maintaining, and repairing the\npipeline system in accordance with subpart H Corrosion Control do not sufficiently address the\nrequirements of § 195.591. Par Pacific’s procedures fail to address acceptance criteria, as\nrequired in NACE SP0102-2010 Section 5.1.5 Survey-acceptance criteria, for a successful ILI\nrun. Par Pacific must modify its written procedures to address this deficiency.\n13\n\n\n\n21. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(14) Taking adequate precautions in excavated trenches to protect personnel from\nthe hazards of unsafe accumulations of vapor or gas, and making available when\nneeded at the excavation, emergency rescue equipment, including a breathing\napparatus and, a rescue harness and line.\n§195.422 Pipeline Repairs\nEach operator shall, in repairing its pipeline systems, insure that the repairs are\nmade in a safe manner and are made so as to prevent damage to persons or\nproperty.\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific does not have a procedure which ensures that pipeline maintenance\nconstruction, repairs, and testing activities are made in a safe manner pursuant to the\nrequirements set forth in §§ 195.402(c)(14) and 195.422. Par Pacific must develop a written\nprocedure to address this deficiency.\n22. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\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(1) . . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.432 Inspection of in-service breakout tanks.\n(a) . . .\n(b) Each operator must inspect the physical integrity of in-service atmospheric and\nlow-pressure steel above-ground breakout tanks according to API Std 653 (except\nsection 6.4.3, Alternative Internal Inspection Interval) (incorporated by\nreference, see §195.3). However, if structural conditions prevent access to the tank\nbottom, its integrity may be assessed according to a plan included in the operations\nand maintenance manual under §195.402(c)(3). The risk-based internal inspection\nprocedures in API Std 653, section 6.4.3 cannot be used to determine the internal\ninspection interval.\n14\n\n\n\nPar Pacific does not have adequate procedures to assure safe operation of a pipeline facility.\nSpecifically, Par Pacific’s procedure, LOM022 Breakout Tanks (1/19/2017, Rev. 3), states that\nexternal inspections will be performed at intervals stated in API Std 653, Section 6.3.2; however,\nthe procedure fails to describe the process for determining which interval will be used. Since the\ninspection interval must be conducted at least every 5 years or RCA/4N years (where RCA is the\ndifference between the measured shell thickness and the minimum required thickness in mils,\nand N is the shell corrosion rate in mils per year) whichever is less, the procedure should\ndescribe how the operator will determine the interval.\nFurther, Par Pacific’s procedure, LOM022 Breakout Tanks (1/19/2017, Rev. 3), fails to require\nexternal, ultrasonic thickness inspections, and the required inspection intervals.\nPar Pacific’s procedure, LOM022 Breakout Tanks (1/19/2017, Rev. 3), also fails to require\nformal internal inspections of steel atmospheric or low pressure breakout tanks be done at a\nmaximum interval of 20 years. The process/procedure paraphrases the requirements in API 653,\nrather than having a detailed procedure how to determine minimum bottom plate thickness, and\nensuring the thickness is not less than the values indicated in API 653. Par Pacific must develop\nwritten procedures to address these deficiencies.\n23. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The","truncated":true,"body_characters":43187}