# PLAINS PIPELINE, L.P. — Warning Letter

**Citation:** CPF 420075001W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-01-17

CLOSED warning letter citing 195.420(c).

## Document text

Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulation as 195.420(c). The case was opened on 2007-01-17 and is reported as closed as of 2007-01-17. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075001W_Warning Letter_01172007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075001W/420075001W_Warning%20Letter_01172007.pdf

420075001W_Warning Letter_01172007.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
8701 South Gessner, Suite 11 10
Houston, TX 77074
WARNING LETTER
January 17,2007
Mr. Harry N. Pefannis
President
Plains Pipeline, LP
P.O. Box 4468
Houston, TX 7721 0
CPF NO. 4-2007-5001 W
Dear Mr. Pefannis:
During the months of September and November, 2006, representatives of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Southwest Region, pursuant to Chapter
601 of 49 United States Code, conducted a pipeline safety inspection of Plains Pipeline, LP
liquid pipeline systems facilities and records.
As a result of the inspections, it appears that you have committed probable violations as noted
below of pipeline safety regulations Title 49, Code of Federal Regulations, Part 195. The items
inspected and the probable violations are:
91 95.420 Valve maintenance
(c) Each operator shall provide protection for each valve from unauthorized
operation and from vandalism.
A number of the Plains Pipeline LP pipeline valves do not have protection from
vandalism at the sites. The valves were chained and locked to prevent unauthorized
use, but these locations did not provide any deterrence against vandalism. Local
personnel did provide additional information regardiqg this issue.
During the inspections it was noted that Plains' preferred method of complying with
195.420~ is to install locked chain link fencing around the valves. This was evident in the



three Plains units that were inspected, where the majority of above ground valves were
located in locked fences.
Some of the remaining valves in those units were located above ground with no fences.
The number of above ground valves that were observed without fences by the inspector on
the three Texas and Louisiana units exceeded seven, and the lack of fencing was pointed
out to Plains personnel at the time of the inspections. Several above ground valves were
also observed without fences by the inspector in the marsh of the Louisiana unit of Plains.
It should be pointed out that all of the unfenced valves were chair1 locked and most had
steel barricade posts installed. A review of your procedures by our inspectors did not
reveal any alternative method of security for valve sites acceptable to you. Plains should
review their program, procedures, and facilities to ensure they are compliant with this
regulation.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violations persists up to a maximum of $1,000,000
for any related series of violations. With respect to item 1 we have reviewed the circumstances
and supporting documents involved in this case and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time.
We advise you to promptly correct these item(s). Be advised that failure to do so may result in
Plains Pipeline LP being subject to additional enforcement action.
In your correspondence on this matter, please refer to CPF 4-2007-5001W and for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420075001W>
- Source ID: `phmsa-enforcement`
- SHA-256: `d484f4c9f500317fa268846ecc68596ae4886c50a45361688bfe266e41921ead`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T19:01:11.084Z
- Document slug: `phmsa-enforcement-420075001w`

### Source metadata

```json
{
  "cpf": "420075001W",
  "operator": "PLAINS PIPELINE, L.P.",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.420(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 1,
  "attachments": [
    {
      "name": "420075001W_Warning Letter_01172007.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420075001W/420075001W_Warning%20Letter_01172007.pdf",
      "bytes": 56257,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "PLAINS PIPELINE, L.P."
}
```
