{"operation":"document","citation":"CPF 520207001M","title":"DCOR, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-02-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(3), 195.452(j)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520207001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520207001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520207001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520207001M","body":"Notice of Amendment involving DCOR, LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(3),  195.452(j)(2). The case was opened on 2020-02-03 and is reported as closed as of 2020-04-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520207001M_Closure Letter_04022020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520207001M/520207001M_Closure%20Letter_04022020.pdf\n\n520207001M_Closure Letter_04022020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520207001M/520207001M_Closure%20Letter_04022020_text.pdf\n\n520207001M_Notice of Amendment_02032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520207001M/520207001M_Notice%20of%20Amendment_02032020.pdf\n\n520207001M_Notice of Amendment_02032020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520207001M/520207001M_Notice%20of%20Amendment_02032020_text.pdf\n\n520207001M_Operator Response to Notice_03132020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520207001M/520207001M_Operator%20Response%20to%20Notice_03132020.pdf\n\n520207001M_Closure Letter_04022020_text.pdf\n\nVIA E-MAIL TO MR. ROBERT L. GARCIA\nApril 2, 2020\nMr. Robert L. Garcia\nVice-President, Facilities & Process Engineering\nDCOR, LLC\n290 Maple Court, Suite 290\nVentura, CA 93003-3517\nCPF 5-2020-7001M\nClosure Letter\nDear Mr. Garcia:\nFrom August 26 through 28, 2019, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected and reviewed\nDCOR LLC’s (DCOR) procedures for the crude oil transmission pipeline system that serves your\noffshore Platform A and the Rincon Onshore Separation Facility (RSOF) in Ventura, California. As a\nresult of the inspection, DCOR was issued a Notice of Amendment on February 3, 2020, which proposed\namendment of your procedures.\nDCOR submitted its amended procedures on March 13, 2020. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for your\ncooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 N. Cruz (#166309)\n\n520207001M_Notice of Amendment_02032020_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 3, 2020\nMr. Andrew Prestridge\nPresident\nDCOR LLC\n290 Maple Court, Suite 290\nVentura, CA 93003\nCPF 5-2020-7001M\nDear Mr. Prestridge:\nOn August 26 through 28, 2019, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nand reviewed DCOR LLC’s (DCOR) procedures for the crude oil transmission pipeline system\nthat serves your offshore Platform A and the Rincon Onshore Separation Facility (ROSF) in\nVentura, California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nDCOR’s plans or procedures, as described below:\n1. § 195.452 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\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\n\n\n\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) . . .\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\nsection); …\nDCOR’s written integrity management program (IMP-HL Section 6) failed to include written\nprocedures for an analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure that includes all the information set forth in\n§195.452(g).1 Specifically, Section 6.2 of DCOR’s IMP only notes that data must be current\nand accurate, but fails to specifically describe what this data should consist of (e.g., ILI\nassessments, cathodic protection surveys, etc.) and how it is integrated in its risk analysis.2\n2. § 195.452 Pipeline integrity management in high consequence areas.\n(a) …\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline’s integrity?\n(1) …\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified in\nparagraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments, information analysis (paragraph (g)\nof this section), and decisions about remediation, and preventive and mitigative\nactions (paragraphs (h) and (i) of this section).\nDCOR’s written integrity management program (IMP-HL Section 6) did not have adequate\nwritten procedures for conducting a periodic evaluation, as frequently as needed, to assure\npipeline integrity. Specifically, DCOR failed to specify the frequency of evaluation based on\nrisk factors specific to its pipeline. Instead, Section 6.2 of its IMP states that the “risk analysis\nwill be updated when information on these dominant risk factors changes significantly.” Not\nonly is the periodic evaluation interval undefined, but DCOR’s IMP does not clarify what\ndominant risk factors are, or what a significant change to them might be.\n1 49 C.F.R. §195.452(g) requires that an operator analyze all available information about the integrity of the entire\npipeline and consequences of a failure, including information critical to determining the potential for, and\npreventing, damage due to excavation, including current and planned damage prevention activities, and\ndevelopment or planned development along the pipeline segment; data gathered through the integrity assessment\nrequirements of 195.452; data gathered in conjunction with other inspections, tests, surveillance and patrols\nrequired by Part 195, including, corrosion control monitoring and cathodic protection surveys; and information\nabout how a failure would affect the high consequence area, such as location of the water intake.\n2 Historical data, in addition to current data, is critical to analyzing the integrity of the entire pipeline and\nconsequences of a failure.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 60 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that DCOR LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to Dustin Hubbard, Director, Western Region,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 5-2020-7001M and, for each document you submit, please provide\na copy in electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 N. Cruz (#166309)\n3","truncated":false,"body_characters":9270}