# NUSTAR LOGISTICS, L.P. — Notice of Amendment

**Citation:** CPF 420075005M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-02-15

CLOSED notice of amendment citing 195.555, 195.559, 195.569, 195.573(d), 195.579(a), 195.579(b), 195.583, 195.585(a), 195.585(b).

## Document text

Notice of Amendment involving NUSTAR LOGISTICS, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.555,  195.559,  195.569,  195.573(d),  195.579(a),  195.579(b),  195.583,  195.585(a),  195.585(b). The case was opened on 2007-02-15 and is reported as closed as of 2008-04-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075005M_Notice Letter_02152007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075005M/420075005M_Notice%20Letter_02152007.pdf

CPF 4-2007-5005M Valero - Response Letter to NOA.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075005M/CPF%204-2007-5005M%20Valero%20-%20Response%20Letter%20to%20NOA.pdf

420075005M_Notice Letter_02152007.pdf

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8701 South Gessner, Suite 1110
Houston, TX 77074
NOTICE OF AMENDMENT
CERTIFIED MAIL. RETURN RECEIPT REQUESTED
February 15,2007
Mr. Richard Bluntzer
Vice President, Pipeline Operations
Valero Logistics Operations, LP
One Valero Way
San Antonio, Texas 78249
GPF No.4-2007-5005M
Dear Mr. Bluntzer:
ln 2004, a team of representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an
onsite pipeline safety inspection of your Corrosion Control manuals, records and procedures at
your headquarters in San Antonio, Texas. In August 2A05 a follow up pipeline safety inspection
of your Corrosion Control manuals, records and procedures was conducted at the PHMSA
office in Houston, Texas.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Valero's plan or procedure and are descried below:
1. 5195.555 What are the qualifications for supervisors?
You must require and verify that supervisors maintain a thorough knowledge of
that portion of the corrosion control procedures established under Sec.
195.a02(c)(3) for which they are responsible for insuring compliance.
Valero corrosion control procedure manual needs to define which individuals are supervisors
and quantify their expertise.



2. 5195.559 What coating material may I use for external corrosion control?
Coating material for external corrosion control under Sec. 195.557 must--
(a) Be designed to mitigate corrosion of the buried or submerged pipeline;
(b) Have sufficient adhesion to the metal surface to prevent under film migration
of moisture;
(c) Be sufficiently ductile to resist cracking;
(d) Have enough strength to resist damage due to handling and soil stress;
(e) Support any supplemental cathodic protection; and
(f) lf the coating is an insulating type, have low moisture absorption and provide
high electrical resistance.
Valero corrosion control procedure manual does not address coating material requirements.
3. 5195.569 Do I have to examine exposed portions of buried pipelines?
Whenever you have knowledge that any portion of a buried pipeline is exposed,
you must examine the exposed portion for evidence of external corrosion if the
pipe is bare, or if the coating is deteriorated. lf you find external corrosion
requiring corrective action under Sec. 195.585, you must investigate
circumferentially and longitudinally beyond the exposed portion (by visual
examination, indirect method, or both) to determine whether additional corrosion
requiring remedial action exists in the vicinity of the exposed portion.
Valero corrosion control procedure manual does not indicate that examination of exposed
portions of buried pipelines is "to determine extent" of corrosion if found.
4. 5195.573 What must I do to monitor external corrosion control?
(d) Breakout tanks. You must inspect each cathodic protection system used to
control corrosion on the bottom of an aboveground breakout tank to ensure that
operation and maintenance of the system are in accordance with API
Recommended Practice 651. However, this inspection is not required if you note
in the corrosion control procedures established under Sec. 195.402(c)(3) why
compliance with all or certain operation and maintenance provisions of API
Recommended Practice 651 is not necessary for the safety of the tank.
Valero corrosion control procedure manual does not address tank bottom c.p. being in
accordance with API RP 651.
5. 5195.579 What must I do to mitigate internal corrosion?
a) General. lf you transport any hazardous liquid or carbon dioxide that would
corrode the pipeline, you must investigate the corrosive effect of the hazardous
liquid or carbon dioxide on the pipeline and take adequate steps to mitigate
internal corrosion.
Valero corrosion control procedure manual does not contain provisions for investigating and
taking appropriate steps where internal corrosive effects would corrode the pipeline.



6. 5195.579 What must I do to mitigate internal corrosion?
(b) Inhibitors. lf you use corrosion inhibitors to mitigate internal corrosion, you
must--
(1) Use inhibitors in sufficient quantity to protect the entire part of the pipeline
system that the inhibitors are designed to protect;
(2) Use coupons or other monitoring equipment to determine the effectiveness of
the inhibitors in mitigating internal corrosion; and
(3) Examine the coupons or other monitoring equipment at least twice each
calendar year, but with intervals not exceeding 7 1/2 months.
Valero corrosion control procedure manual does not contain provisions for internal corrosion
inhibitor and coupons or other monitoring equipment.
7. 5195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed to the
atmosphere for evidence of atmospheric corrosion, as follows:
lf the pipeline is located: Then the frequency of inspection is:
Onshore At least once every 3 calendar years, but with intervals not
exceeding 39 months
Offshore At least once each calendar year, but with intervals not exceeding 15
months
(b) During inspections you must give particular attention to pipe at soil-to-air
interfaces, under thermal insulation, under disbonded coatings, at pipe supports,
in splash zones, at deck penetrations, and in spans over water.
(c) lf you find atmospheric corrosion during an inspection, you must provide
protection against the corrosion as required by Sec. 195.581.
Valero corrosion control procedure manual does not contain a procedure for atmospheric
corrosion monitoring.
8. 5195.585 What must I do to correct corroded pipe?
(a) General corrosion. lf you find pipe so generally corroded that the remaining
wall thickness is less than that required for the maximum operating pressure of
the pipeline, you must replace the pipe. However, you need not replace the pipe if
you'-
(1) Reduce the maximum operating pressure commensurate with the strength of
the pipe needed for serviceability based on actual remaining wall thickness; or
(2) Repair the pipe by a method that reliable engineering tests and analyses show
can permanently restore the serviceability of the pipe.



Valero corrosion control procedure manual does not contain procedures to reduce MOP, or
repair/replace pipe if general corrosion has reduced the wall thickness.
9. 5195.585 What must I do to correct corroded pipe?
(b) Localized corrosion pifting. lf you find pipe that has localized corrosion pitting
to a degree that leakage might result, you must replace or repair the pipe, unless
you reduce the maximum operating pressure commensurate with the strength of
the pipe based on actual remaining wall thickness in the pits.
Valero corrosion control procedure manual does not contain procedures to reduce MOP, or
repair/replace pipe if localized corrosion has reduced the wall thickness.
Response to this Notice
lf, after notice and opportunity for a hearing, your procedures are found to be inadequate, you
may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. S
190.237).
This letter seryes as your notice of inadequate plans or procedures. Enclosed as part of this
Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings. Please refer to the Notice of Amendment portion of this document and note the
response options. lf 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.
lf you are not contesting this Notice, we propose that you submit your amended procedures to
my office within 30 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.
ln your correspondence on this matter, please refer to CPF 4-2007-5005 and for each document
you submit, please provide a copy in electronicformat whenever possible.
Sincerely,
Vtehe,4,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Material Safety Admin istration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420075005M>
- Source ID: `phmsa-enforcement`
- SHA-256: `062f0dd36761b5a51e86ac61a08a3708cd8c558661913b0bb6569dd3a116f537`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T08:24:28.361Z
- Document slug: `phmsa-enforcement-420075005m`

### Source metadata

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  "cpf": "420075005M",
  "operator": "NUSTAR LOGISTICS, L.P.",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.555",
    "195.559",
    "195.569",
    "195.573(d)",
    "195.579(a)",
    "195.579(b)",
    "195.583",
    "195.585(a)",
    "195.585(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
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  "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": "NUSTAR LOGISTICS, L.P."
}
```
