# CITGO PIPELINE CO — Notice of Probable Violation

**Citation:** CPF 420075010  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-04-02

CLOSED notice of probable violation citing 195.128, 195.406(b), 195.410(a)(1), 195.412(a), 195.420(c), 195.432(b), 195.573(d), 195.579(a).

## Document text

Notice of Probable Violation involving CITGO PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.128,  195.406(b),  195.410(a)(1),  195.412(a),  195.420(c),  195.432(b),  195.573(d),  195.579(a). The case was opened on 2007-04-02 and is reported as closed as of 2012-09-10. Proposed civil penalty: $94,000. Assessed civil penalty: $32,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075010_Closure_09102012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_Closure_09102012.pdf

420075010_Closure_09102012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_Closure_09102012_text.pdf

420075010_Decision on Reconsideration_12292011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_Decision%20on%20Reconsideration_12292011.pdf

420075010_Decision on Reconsideration_12292011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_Decision%20on%20Reconsideration_12292011_text.pdf

420075010_FinalOrder_04142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_FinalOrder_04142011.pdf

420075010_FinalOrder_04142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_FinalOrder_04142011_text.pdf

420075010_Petition for Reconsideration_06102011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/420075010_Petition%20for%20Reconsideration_06102011.pdf

CPF 4-2007-5010 Citgo Pipeline Company NOPV PCP PCO.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/CPF%204-2007-5010%20Citgo%20Pipeline%20Company%20NOPV%20PCP%20PCO.pdf

cpf 4-2007-5010 citgo pipeline company nopv pcp pco_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/cpf%204-2007-5010%20citgo%20pipeline%20company%20nopv%20pcp%20pco_text.pdf

CPF 4-2007-5010 Citgo request for hearing_05042007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075010/CPF%204-2007-5010%20Citgo%20request%20for%20hearing_05042007.pdf

420075010_Closure_09102012_text.pdf

CERTIFIED MAIL – RETURN RECEIPT REQUESTED
September 10, 2012
Mr. Jim Sanders
General Manager, Terminal and Pipelines
CITGO Petroleum Corporation
1293 Eldridge Parkway
Houston, TX 77077
CPF 4-2007-5010
Dear Mr. Sanders
On April 14, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to CITGO Petroleum Corporation a Final Order in the above reference case. This order
included a Compliance Order and Civil Penalty assessment. Based on our review of the
documentation you provided and confirmation of payment of the civil penalty, it has been
determined that you have complied with terms of this order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Curtis L. Craig; Vice President & General Counsel, Explorer Pipeline

420075010_Decision on Reconsideration_12292011_text.pdf

DEC 29 2011
Mr. Jim Sanders
General Manager, Terminal and Pipelines
CITGO Petroleum Corporation
1293 Eldridge Parkway
Houston, TX 77077
Re: CPF No. 4-2007-5010
Dear Mr. Sanders:
Enclosed please find the Decision on Reconsideration issued in the above-referenced case. It
grants your Petition for Reconsideration, in part. Service of the Decision by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Rod Seeley, Director, Southwest Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Bruce Oakley, Partner, Hogan Lovells US LLP, 700 Louisiana Street,
Suite 4300 Houston, TX 77002
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [71791000164203033168]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
______________________________
)
In the Matter of )
)
CITGO Pipeline Company, ) CPF No. 4-2007-5010
)
Petitioner. )
______________________________)
DECISION ON RECONSIDERATION
In an April 14, 2011 Final Order, I found that CITGO Pipeline Company (CITGO or Petitioner)
had committed several violations of the hazardous liquid pipeline safety regulations. I assessed
Petitioner a civil penalty of $82,000 and ordered the company to complete certain remedial
actions for committing those violations. On June 10, 2011, after receiving an extension of the
20-day filing deadline in 49 C.F.R. § 190.215(a), CITGO submitted this timely Petition for
Reconsideration (Petition).
Petitioner seeks reconsideration of two of the findings of violation and associated civil penalties
and compliance items in the Final Order. First, CITGO argues that I erred in finding that the
company violated 49 C.F.R. § 195.412(a) by failing to perform adequate inspections of the right-
of-way (ROW) for the Eagle Pipeline. Petitioner further argues that even if the evidence
substantiates that violation, the terms of the resulting compliance order are unlawful, and that its
sale of the Eagle Pipeline to Explorer Pipeline Company (Explorer) on October 31, 2007, has
rendered that aspect of this case moot. Second, CITGO argues that I erred in finding that it
violated 49 C.F.R. § 195.573(d) and (e) by failing to have adequate cathodic protection for the
aboveground breakout tanks at its Sour Lake Tank Farm. Petitioner asks that this finding of
violation be withdrawn, and that the associated $50,000 civil penalty be rescinded.
I am denying CITGO’s request for reconsideration of the finding that it violated the ROW
inspection requirements of 49 C.F.R. § 195.412(a). However, I am granting Petitioner’s request
for reconsideration of the finding that it violated the cathodic protection requirements of
49 C.F.R. § 195.573(d) and (e). The $50,000 civil penalty and associated compliance items for
that violation are withdrawn for lack of sufficient evidence.
Background
From February to June 2006, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of
CITGO’s facilities and records in Texas and Oklahoma. As a result that inspection, the Director,



3
Southwest Region, OPS (Director), issued to Petitioner, by letter dated April 2, 2007, a Notice of
Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice).
The Notice alleged that CITGO had committed several violations of the hazardous liquid
pipeline safety regulations. Two of those violations related to Petitioner’s failure to comply with
the ROW inspection requirements of 49 C.F.R. § 195.412(a) and cathodic protection
requirements in 49 C.F.R. § 195.573(d) and (e). The Notice proposed assessing the company a
total civil penalty of $94,000 and ordering Petitioner to perform certain remedial measures for
committing those violations. The Notice further proposed finding that CITGO had committed
certain other probable violations of 49 C.F.R. Part 195 and warning the company to take
appropriate corrective action to address them or be subject to future enforcement action.
Petitioner responded to the Notice by letters dated May 4, 2007 (Response) and June 25, 2007
(Supplemental Response). CITGO contested several of the alleged violations and the proposed
civil penalty amounts and compliance activities. Petitioner also requested a hearing, which was
held on July 24, 2007, at the PHMSA Southwest Region Office in Houston, Texas. Mr.
Christian A. Garza represented Petitioner as counsel. CITGO later submitted post-hearing
material for the record by letter dated August 23, 2007 (Closing).
On April 14, 2011, I issued the Final Order in this case. I found that Petitioner had committed all
but two of the alleged violations, assessed the company a reduced civil penalty of $84,000, and
ordered CITGO to take certain actions to comply with the hazardous liquid pipeline safety
regulations. On April 21, 2011, Petitioner’s new counsel, Mr. Bruce D. Oakley, asked for an
extension of the 20-day deadline for seeking reconsideration of the Final Order. 49 C.F.R. §
190.215. That request was granted, and on June 10, 2011, CITGO filed this timely Petition.
Petitioner seeks reconsideration of two of the findings of violation and associated civil penalties
and compliance activities in the Final Order. First, CITGO argues that I erred in finding that the
company violated 49 C.F.R. § 195.412(a) by failing to perform adequate inspections of the Eagle
Pipeline ROW. Petitioner further argues that even if the evidence substantiates that violation, the
compliance activities imposed in the Final Order are unlawful and, have become moot as a result
of its sale of the Eagle Pipeline to Explorer on October 31, 2007. Second, CITGO argues that I
erred in finding that the company violated 49 C.F.R. § 195.573(d) and (e) by failing to have
adequate cathodic protection for the aboveground breakout tanks at its Sour Lake Tank Farm.
Petitioner asks that this finding of violation be withdrawn, and that the associated $50,000 civil
penalty be rescinded. CITGO included a number of exhibits with its Petition in support of these
arguments.
Standard of Review
A respondent may petition the Associate Administrator for reconsideration of a final order.
Reconsideration is not a right of appeal or to seek a de novo review of the record.1
It is an
opportunity to present the Associate Administrator with previously unavailable information or to
request that any errors in the final order be corrected. Requests for consideration of additional
facts or arguments must be supported by a statement of reasons as to why those facts or
1 49 C.F.R. § 190.215(a)-(e).



4
arguments were not presented prior to the issuance of the final order. Repetitious information or
arguments will not be considered.
Analysis
I. Request for consideration of additional facts or arguments under
49 C.F.R. § 190.215(b).
Section 190.215(b) of the Pipeline Safety Regulations states that “[i]f the respondent requests the
consideration of additional or arguments, the respondent must submit the reasons they were not
presented prior to issuance of the final order.” CITGO included 26 exhibits with its Petition. Six
of those exhibits consist of materials submitted prior to the issuance of the Final Order in this
case, i.e., Petitioner’s Response, Supplemental Response, Closing, and certain attachments. Two
other exhibits contain documents related to the actions of Explorer, the operator who purchased
the Eagle Pipeline after the July 2007 hearing. The remaining exhibits contain a variety of
materials not submitted prior to the issuance of the Final Order, including:
• Excerpts from CITGO’s Non-Refining Operations Manual, dated February 2, 2006;
• A blank CITGO surface inspection report;
• ROW inspection logs from 2006 and 2007;
• An undated CITGO Pipeline Compliance List with information on its ROW inspection
program;
• Documents related to a September 2004 ROW maintenance contract between CITGO and
a third party, J B L Plant Services;
• An August 2005 service contract between CITGO and J B L Plant Services;
• Additional documentation, dated July and August 2006, on the ROW maintenance
contract between CITGO and J B L Plant Services.
• Invoices, purchase orders, and emails for ROW maintenance from J B L Plant Services to
CITGO from 2007;
• Work orders for ROW maintenance and clearing from June 2006 to August 2007;
• A May 10, 2011 third-party analysis of the cathodic protection program for the breakout
tanks at the Sour Lake Tank Farm;
• November 13, 2003, December 2, 2004, July 26, 2005, and September 26, 2006 facility
surveys for the Sour Lake Tank Farm; and
• Additional information, including prior inspection and operating reports, for the rectifier
at the Sour Lake Tank Farm.
With the exception of the two exhibits related to the activities of Explorer, CITGO did not
provide any explanation as to why the new exhibits submitted with its Petition should be
considered at this stage of the proceeding. Such an explanation is required under § 190.215(b).
Accordingly, I find that Petitioner did not comply with the requirements of § 190.215(b) and am
excluding Exhibits 1, 5, 6A-6B, 7A-7G, 10, 11A-11D, and 12A-12B from the record.
II. Request for reconsideration of the finding that CITGO violated the ROW
inspection requirements in 49 C.F.R. § 195.412(a).



5
CITGO seeks reconsideration of the finding that the company failed to perform adequate
inspections of the Eagle Pipeline ROW as required under 49 C.F.R. § 195.412(a). Specifically,
Petitioner contends that I erred in concluding that it was not contesting that allegations in the
Notice, and that I failed to require that PHSMA meet its burden of proof in sustaining that
finding of violation. CITGO further argues that I failed to consider all of the relevant
exculpatory and mitigating evidence, and that the company did not receive adequate notice of the
specific basis for its alleged violation of § 195.412(a). Petitioner also argues that even if the
evidence substantiates that allegation, the compliance activities imposed in the Final Order are
unlawful, and that its sale of the Eagle Pipeline on October 31, 2007, to Explorer Pipeline
Company renders the compliance order moot.
CITGO has not presented a persuasive basis for withdrawing this finding of violation. The
Pipeline Safety Regulations state, in relevant part:
§ 190.211 Hearing.
(a) A request for a hearing provided for in this part must be accompanied by a
statement of the issues that the respondent intends to raise at the hearing. The
issues may relate to the allegations in the notice, the proposed corrective action
(including a proposed amendment, a proposed compliance order, or a proposed
hazardous facility order), or the proposed civil penalty amount. A respondent's
failure to specify an issue may result in waiver of the respondent's right to raise
that issue at the hearing. . . .
In its hearing request, Petitioner did not object to the allegation that it violated the ROW
inspection requirements in 49 C.F.R. § 195.412(a). Rather, CITGO acknowledged in its
Response that “[t]he issue cited is that large trees overhanging the right-of-way obscure it from
aerial surveillance,” and “agree[d] that this is an important issue and will undertake a focused
inspection of its rights-of-way from the air to identify any areas that actually obscure the right-
of-way from aerial surveillance.” Petitioner also stated in its Supplemental Response that it was
“assessing its current canopy trimming program to reduce problem areas.” Such statements,
particularly in a document submitted by counsel, indicate that CITGO agreed with the merits of
the allegation of violation, not that the company disputed it.
Moreover, even if Petitioner intended to raise such an objection, the evidence of record supports
the finding of violation. As noted in the Violation Report, the OPS inspector observed areas of
overgrowth on the Eagle Pipeline ROW that would prevent the performance of adequate aerial
inspections, and CITGO’s employees stated those areas would be subject to ground surveillance
in the future. The OPS inspector also submitted photographic evidence of obstructed areas of the
Eagle Pipeline ROW near the North Arbuckle Block Valve, the West Trinity Block Valve,
Wynnewood Junction, the north Houston suburbs, and Milepost 87.6. Such evidence is more
than sufficient to sustain the alleged violation. Accordingly, I am denying Petitioner’s request
for reconsideration of the finding that it failed to perform adequate inspections of the Eagle
Pipeline ROW as required under 49 C.F.R. § 195.412(a).
With respect to CITGO’s remaining arguments, the terms of the compliance order do not
mandate that Petitioner perform aerial inspections of the Eagle Pipeline ROW. CITGO is merely
required to take certain steps, e.g., identification and clearing of overgrowth, to ensure that its
aerial inspections are being conducted in an appropriate manner. Nothing in the compliance



6
order precludes Petitioner from using other appropriate means of performing ROW inspections,
including ground surveillance.2
Nor has Petitioner’s sale of the Eagle Pipeline to Explorer Pipeline Company rendered the terms
of the compliance order moot. CITGO is the moving party and bears the burden of establishing
mootness,
3 i.e., that “[t]he controversy between the parties has thus clearly ceased to be ‘definite
and concrete’ and no longer ‘touch(es) the legal relations of parties having adverse legal
interests[,]’”4 and that it is “impossible . . . to grant ‘any effectual relief whatever’[.]”5 That is a
“heavy burden” where, as here, the allegation of mootness arises from the moving party’s own
voluntary conduct, i.e., Petitioner’s sale of the Eagle Pipeline.
6 In such a case, CITGO “bears
the formidable burden of showing that it is absolutely clear the allegedly wrongful behavior
could not reasonably be expected to recur[,]”7 and that “interim relief or events have completely
and irrevocably eradicated the effects of the alleged violation.”8
Petitioner states that it sold the Eagle Pipeline to Explorer on October 31, 2007, that CITGO no
longer has any authority to perform inspections of that pipeline ROW, and that Explorer has its
own program for complying with the requirements in § 195.412(a). Petitioner has also submitted
a September 30, 2009 letter from Explorer to OPS, which states that “Explorer has conducted an
aerial survey [of the Eagle Pipeline] to determine locations where ROW clearing needs to be
enhanced to facilitate weekly aerial patrol,” and that “[c]ertain ROW clearing has been
completed.”
The evidence provided is not sufficient to show that the sale of the Eagle Pipeline has
“completely and irrevocably eradicated the effects” of Petitioner’s violation of the ROW
inspection requirements. Explorer’s letter indicates that aerial inspections of the Eagle Pipeline
ROW are still being conducted, and that additional clearing of the ROW may be needed in
certain areas. This indicates that CITGO’s failure to comply with the requirements in
§ 195.412(a) is still adversely impacting the condition of the ROW. As important, the evidence
does not make “absolutely clear” that Petitioner has no obligation to ensure that these actions are
completed. The specific terms of CITGO’s transaction with Explorer are not of record in this
proceeding, including Petitioner’s obligations, if any, for conduct that arose prior to its sale of
2 PHMSA has broad discretion to ensure compliance with the Pipeline Safety Laws and Regulations, and in cases of
non-compliance such discretion can include requiring operators to take remedial actions that might not otherwise be
required in the absence of a violation. 49 U.S.C. § 60118.
3 Friends of the Earth v. Laidlaw, 528 U.S. 167, 189-90 (2000).
4 DeFunis v. Odegaard, 416 U.S. 312, 317 (1974) (per curiam) (quoting Aetna Life Ins. Co. v. Haworth, 300 U.S.
227, 240-41 (1937))
5 Church of Scientology of California v. U.S., 506 U.S. 9, 12 (1992) (quoting Mills v. Green, 159 U.S. 651, 653
(1895)).
6 Friends of the Earth, 528 U.S. at 189-190 (citing United States v. Concentrated Phosphate Export Assn., 393 U.S.
199 (1968); City of Mesquite v. Aladdin's Castle, Inc., 455 U.S. 283, 289 (1982)).
7 528 U.S. at 190.
8 Los Angeles County v. Davis, 440 U.S. 625, 631 (1979).



7
the Eagle Pipeline. Therefore, I find that CITGO has not met its heavy burden of establishing
that the terms of the compliance order are moot.
III. Request for reconsideration of the finding that CITGO violated the cathodic
protection requirements in 49 C.F.R. § 195.573(d) and (e).
CITGO requests reconsideration of the finding in the Final Order that it violated 49 C.F.R.
§ 195.573(d) and (e) by failing to have adequate cathodic protection for the aboveground
breakout tanks at its Sour Lake Tank Farm. Petitioner argues that OPS has not submitted the
evidence required to sustain that violation, i.e., that its case rests solely on the fact that one of the
four cathodic protection beds was out of service at the time of the inspection, but that the record
does not contain any evidence to show that the breakout tank was not receiving adequate
cathodic protection from the three remaining in-service beds.
I find CITGO’s arguments persuasive. OPS bears the burden of proof in an enforcement action
and must prove, by a preponderance of the evidence, that all of the elements necessary to sustain
a violation are present in a particular case.
that one of the four cathodic protection beds for the breakout tank at the Sour Lake Tank Farm
was out of service. However, the record does not contain any additional evidence, such as test
results or an expert opinion, to demonstrate that the breakout tank was not receiving adequate
cathodic protection from the three remaining beds. Accordingly, I am withdrawing the finding in
the Final Order that CITGO violated 49 C.F.R. § 195.573(d) and (e) by failing to have adequate
cathodic protection for the aboveground breakout tanks at its Sour Lake Tank Farm and
rescinding the $50,000 civil penalty for that violation.
9 As Petitioner notes, OPS’s case is based on the fact
RELIEF GRANTED
Based on the information provided in the Petition, a review of the relevant portions of the record,
and for the reasons stated above, I am withdrawing the finding in the Final Order that CITGO
violated 49 C.F.R. § 195.573(d) and (e) by failing to have adequate cathodic protection for the
aboveground breakout tanks at its Sour Lake Tank Farm and rescinding the $50,000 civil penalty
for that violation. The remainder of the Final Order is affirmed without modification.
This Decision is the final administrative action in this proceeding.
_____________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
9 In the Matter of Alyeska Pipeline Service Co., Decision on Reconsideration, CPF No. 5-2005-5023, p. 4-5 (Dec.
16, 2009); In the Matter of Butte Pipeline Co., Final Order, CPF No. 5-2007-5008, p. 2, n. 3 (Aug. 17, 2009); see
Schaeffer v. Weast, 546 U.S. 49, 56-58 (2005).

cpf 4-2007-5010 citgo pipeline company nopv pcp pco_text.pdf

U. S. Oepartment
of Transportation
Pipeline and
Hazardous Sttatertats Safety
Admtnistratlon
8701 South Gessner, Suite 1110
Houston. TX 7707S
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPI IANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 2, 2007
Jim Sanders
Vice President, Operations
Citgo Pipeline Company
1293 Eldridge Parkway
Houston, TX 77077
CPF 4-2007-5010
Dear Mr. Sanders:
During the weeks of February 6 — 10, March 6 - 10, April 3 — 7, and May 31 - June 2, 2006, a
representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
pursuant to Chapter 601 of 49 United States Code, inspected CITGO Pipeline Company's
(CITGO) operations and maintenance procedures, and records, and conducted field inspections
of your Sour Lake district pipelines and tank farm, the Eagle Line south pipeline unit, from
Houston to Arlington, TX, and the Eagle Line north pipeline unit from Arlington, TX to the
Drumrigrtt, OK area. An inspection of the Tulsa control center for the pipeline units was also
conducted as part of these standard inspections.
As a result of the inspections, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. rJ 195. 128 Station Piping
Any pipe to be installed in a station that is subject to system pressure must meet the
applicable requirements of this subpart.



The regulation requires that materials for permanent installation in facility piping be
suitable, and meet the requirements of referenced standards. ABME B31. 4 does not list
rubberized, braided hoses as suitable for permanent installation in pipeline service.
Drag Reducing Agent (DRA) is introduced at a number of pump stations on the OITGO
pipeline systems. The DRA is pumped into the station piping from permanently located
tank and pump assemblies, but is being introduced into the pipeline system through
braided, rubber covered hoses, casually laid on the ground between pump and the
pipeline.
In addition, the rubber hoses laid on the ground present a tripping, or snagging safety
hazard.
2. &tf &35A06 Maximuiim operating pressure
b. No operator may permit the pressure in a pipe!ine during surges or other
varialio&ss from nord!el operations to exse, . di 1I10 percent of tltie operating
pressure lllmit establlished under paragraph (al of this sect(on. I=aoh operator
must provid'e adequate controls and protectlive equ!pnaent to cir&ntrr&l the
priessure within thiis limit.
Pipeline must be protected against over pressures and surges that would exceed ';l10%
of the MOP established for the pipeline Adequate controls and protective equipment to
control the pressure within this limit must be prowded. CITGO was unable to provide
documentation that surge pressures have been car&side!ed:, . rtr that' t'lie pigsk!Ine is
adequately protected from surges.
3. &9 595A10 Line markers
(a!' Except ss providled' in pasagraph (9&]& of this section, sxach &rperatoi shall
place andi m&sintaiin line markers over eaclh buiried pi&pelfne In adcorr!;anccx with the
fallowing:
(0;I Markers midst be located at each put&lip road crossing, at each railroad
a&rossing, , snd In sufficient number along the r&areain der of. eacih buir led Itrte so that
its location is aiccurately known.
CITGO does not have sufficient markers along their pipelines in some areas. When
crossing cultivated agricultural fields, often the markers on the far side of the field could
not be seen. From Valve sites, looking in both directions, the next marker for i"e
pipeline could not be seen. The pipeline markers across Northgate Forest golf course
are flush mounted markers The markers are from Area Pipeline, and the phone
numbers on the markers are no longer valid.



4. It 195. 412 Inspection of Right of Way
(a) Each opet'ator shall. at iritel'va'Is not ettceefftpg 3 weeks, bgt at leakii 26 times
each calendar year, Inspect the sitrfaaa Condihiona gn or adjacent to qpgii pipeline
rightmf-way. Methodis of inspect!on !ncltttie vs(king, dr(vir&g, flyihg or other
appropriate mean of traver'sing the rigl;t-of vtra„.
In order to perform pipeline surveillance, the right of way must ". 8 i'naintained so that the
ROW is clearly visible by the means of surveillance employed. Aerial surveillance is the
primary method of pipeline patrolling used by CITQO. Many areas of Cl JGG's pipelines
have ROW areas that are lined with targe trees The treeS liave branches that overhang
the ROW, and form a canopy that obscures the pipeline ROW from observation by aerial
surveillance. Some areas are overgrown with deep brush and grass that should be
cleared to allow clear observation of the ROW during surveillance, and to allow visibilily
of pipe ine markers.
5. 4r 19. '5. 42ll Valjve Mainftenance
(c) IEacki operator shall provide protection for each valve from t!Nattfthorized
operatic. ni and fromm vandalism.
A number of the CITGO pipeline valves do not have protection from vandalism at the
sites. The valves were chained and locked to prevent unauthorized use, but these
ocations did not provide any deterrence against vandalism. I-ocal personn"-. did provi~
additional information regarding this issue.
During the inspections it was noted that CITG&&s preferred method of complying wit", I
195. 420(c) is to install locked chain link fencing around the valves. This was evident in
the three CITGO units that were inspected, where the majority of above ground valves
were located in locked fences.
Stime of the remaining valves in those units were located above ground with no fences.
i4 number of above ground valves that were observed without fences by the inspeclc~ FA'
the three Texas and Oklahoma units, and the lack of fencing was pointed out to C ITiiGO
personnel at the time of the inspections.
It should be pointed out that a of the unfenced valves were i tain locked and most. htfd'
steel barricade posts installed. A review of your procedures by our inspectors did'rL'hatt
reveal any alternative method of security for valve sites acceptable to you Ci!TiG&
should review their program, procedures, and facilities to ensure they are compliant with
this regulation.
6. g95:432 Breakout tar &ks.
(b) Each opetratnr shallins pi!. t. tie It, itysi cal intpgrtty of ln-a@vice atmoflPheric
arcr' Inw pass ue s: teel, atsvegrouna breako utltanirs according to akctton. 4, nf API
X'ttrrdtnt d653', Hnvever, . if;structural conditio nb' i prevent access to, i!he tat ik bottom,
3



the bottom integrity may be assessed according to a piap included in the
operations and maintenance manual uhider t)195. 402tc)(3).
(d) The intervals of inspection Speotfled by documents refehenqed in
paragraphs (b) and (c) of this seiction begin on May 3. 1999, or on the opargtor's
last recorded date of the inspection, whichiever' is cacti„r.
A number of tanks at the Sour Lake facility, Fauna Station, and Arlington Station have
items that are out of compliance with API-653. Most of these arise from items that are
being missed during monthly inspections The purpose of the monthly inspections is to
catch minor items, such as vegetation growing adjacent to tanks, wa'bouts of sttbegi'
from under tank bottom or animal burrows, cracks in concrete nng wall, leaks or diiba at
mixers or flanges, etc These items should be noted in the monthly inspections, sis well
as other items, as listed in the API-653 checklist. Once noted, the items should be
resolved prior to the next inspection, or a reason given for why the item was not
resolved.
Regulations require that the operator of pipeline breakout tanks adopt an API-653 Istql;
inspection schedule, and inspect breakout tanks on a frequency prescribed in the
standard. CITGO has adopted the API-653 tank inspection standard, but has not met
the required tank inspection frequency, as required by the standard and regulation.
Two tanks are overdue for their out of service internal inspections. Eight tanks have
been missed for the in-service external inspections, and it appeeii's that eight tanks have
been missed for their UT inspections. This information is based upon the operator's
records for 'enk inspections.
7, $1195. 573 Iitfhat must I do to itnociltror tecterntcj corrosion COntrolg
(d) Breaks. ut I;an)rs. 'You mus t (inspect eac'h sathcitfie prot~ttion, sysfpm used, to
co ntrol corresiorri on the bottom ctf an atto vegroutid' breakout (isnk to ensure that
operatjenn and maintenance ef the sya4ern are in accordance vyifh, API
Recomoxenided Pracfice 651. However, tltiis ittsspectktn is not requitiad ilf you note
in the crtrrositon contrctl procWurssx cstaitdtshecl uindeti, Sec. 1I94 402(iclt3) why
ciomp'liance wdhi alP or certain'. opettatiort and nItsettenance previsions of API
Recorntnended Pracfiice 651 is n~ol necessary forithy safety oftlltitsftank, ,
(e) Correct(ve action. Youi umst ccxrrwt any fdiritttified deficiency in corrosion
control as renviuiredl by Sec. . 1f!5401'(bx):. IRowever, ,
lf the dfjficiansy involves, a
pipeline ih an ibilegrity mar raacimctitt. procqract urtder Sec. 195. 452, you must
correct the deffciieincy as required by Siec. 1ic)5. 452tfti).
Regulation requires that the operator of pipeline breakout tanks maintain a cathodic
protection system on their breakout tanks which is in accordance with AF:. IMP-651. The
regulations also require that if there is an identified deficiency, it must be corrected
within a reasonable time.



Citgo discovered that tank farm rectifier/ground bed, Srbu'r' I ake ¹3, had failed in
October 2003. The records indicate that the system was failing as early as December
2002. As of the standard inspection conducted February 6 - 10, 2006, the Sour Lake
¹3 system was still down, and not providing Cathedic Protection to the tank farm. The
system has been failing or out of service for over -1 years, without correction.
8. II195. 579 What tnust I do to miticiate internal corrosion?
(a} General, . If you transport any llih", slrtlous liquid or carbon dig)ride '„habit would
coirroitie tbe pipeline, you must invesfi$Iate the corfos;ve effect rf the I)azardous
liquid or carbohi dioxide on the pipellihe arid take adequate steps fo mitigate
intertsali corrosion,
CIYGO Pipeline has not performed adequate investigations of the corrosivity of the
products on their pipelines and facilities. The operator has not performed inspections on
dead legs, low points, facility and non-piggable pipe, and downstream of supplier taps. The
operator also does not have adequate monitoring, and monitoring points that are insta led
are installed incorrectly.
Pro osed Civil Penalt
Under 49 Unifed' States Code, g 60122, you are subject to a civil penalty not to exceed
$100, 000 for each vio ation for each day the violations persists up to a maximum of $1, 000, 000
for any related series of violations. The Compliance Officer has reviewed the circumstances
and supporting documentatiori involved in the above probable wolation(s) anti
recommended that you be preliminanly assessed a civil penalty of $94, 000 as follows:
Item number
(1]
(6]
(7)
FEALTY
$:, '2:000]
$32, 000
$50, 000
W~il t
With respect to item 5 we have reviewed the circumstances and supporting documents involved
in this case and have decided not to conduct additional enforcement ai".
. Ibn or penal'y'
assessment proceedings at this time. We advise you to promptly cirrect these item(s).
advised that failure to do so may result in CITGO Pipeline Company being subject to additioi, al
enforcement action.
Pro osed Com liance Order
With respect to items 1, 2, 3, 4, 6, 7, and 6, pursuant to 49 United States 'Code g 60116 the
Pipe ine and Hazardous Materials Safety Administration propose '':4' I&'ue a' t'ompliance Ckder
to CITGO Pipeline Company. Please refer to the Proposed i. omp//ance Order whicn is
enclosed and made a part of this Notice.



Res onse to this Notice
Enclosed as part of this Notice is a document entitled Response O)5tlr)ns for Pipetirid Voerators
in Compliance Proceedings. Please refer to this document antj rioti' '. tie respor'5" offttons. Be
advised that all matenal you submit in response to this entorcement action is subject to b '
g
made publicly available If you believe that any portion of your responsive material qualifies fb'k
confidential treatment under 5 U. S. C. 552(b), along with the complete original documeri' ~c"j
must provide a second copy' df the document with the portions you believe qua', ify fo, '
confidential treatment redacted aih'd an explanation of why you believe the redacted inforiftgt'Gri
qualifies for confidential treatment under 5 U. S. C. 552(b). If you dC r)c&t I'espond 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, ieged in
this Notice without further notice to you and to issue a Final Order
In your correspondence on this matter, please refer to CPF 4~F7 I" O and for each document
you submit, please prowde a copy in electronic format whenever possib e.
Sincerely,
R trt, Saeley
Director, Southwest Region
Pipeline and Hazardous
Materials . efety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Comptrancr. ' P'oceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code g 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to CITGO Pipeline Company a Compliance Order
incorporating the following remedial requirements to ensure the compliance of ITGO Pipeline
Company with the pipeline safety regulations:
Regarding item Number 1 of the Notice, CITGO must inspect all of their pipeline
systems to locate areas using temporary hose/ piping in permanent Iodatiene.
Provide a plan to re-pipe the locations with piping that comply with standards,
recommended practices and regulations. Provide the results of the analysis to
PHMSA Based on the results, CITGO should implement any modifications
necessary to assure that the pipelines are compliant with (~95. 128.
In regard to Item Number 2 of the Notice, CITGO must perform the necessary
hydraulic analysis including the consideration of surges to insure that their pipelines
will not be over pressured during normal operations. Provide the results of the
analysis to PHKRSA. Based on the results, CITGO should implement any
modifications necessary to assure that the pipelines are compliant with $195. 406(b).
In regard to Item Number 3 of the Notice, pertaining to CITGO's pipeline systems,
perform an inspection of all pipelines to locate areas lacking sufficient markers. If
there are areas where it is impractical to place markers, or because the markers are
removed or plowed under by the landowner, an alternativia method of ensuring the
safety of the public and the pipeline should be developed. In areas where fhefe' are
insufficient markers, develop a plan and time table to place markers to ensure
Cl I GO is in compliance with $195. 410(a)(1).
In regard to Item Number 4 of the Notice, pertaining to CITGQ's pipeline systdmS,
perform an inspection of all pipelines to locate areas where ROW is over grown with
brush or tall grass, or areas where the ROW is overgil'owri by a canopy firWi
surrounding trees, preventing visibility from aerial surveila'fit. Develop a plan Nff@
time table to clear brush and canopy from ROW to ensure that C"-ITGO is in
compliance with $195, 412(a). Until the ROW can be clea'red' a'nd made suitable for
aerial surveillance, develop an alternative surveillance method for affected areas.
In Regard to Items Number 6 of the Notice, pertaining tc GITGO's pipeline systems,
review CITGO's Tank Inspection program, Develop a plan arid time tab e to inspect
tanks that have been missed, and ensure that inspections are performed according
to the required schedules in the future. Ensure that monthly inspections note items
as required by API 653, and that the items are addressed prior to sequential
inspections. Ensure that inspection report documentation )La eiotnplete, and tl at items
from all inspection reports are addressed, and documenrtedI, so that CITGO is in
compliance with II195. 432 and referenced API 653.
In regard to Item Number 7 of the Notice, pertaining to Cl I~~O's pipeline systems,
review C:ilTGO's CP data collection and evaluation to ensuire tliat if CP systems need
repair or replacement, they are addressed promptly and tltiant the pipelines and tarik~
are protected. Develop a plan and time table to replace iiin&dequate iCP systems to
bring CITGO into compliance with $195. 573.



7. In regard to Item Number 8 of the Notice, pertaining to CITGO's pipeline systems,
perform an assessment to fully determine the corrosive effect of the transported
products on pipelines and all facilities. If there are areas that would be susceptible to
internal corrosion, perform inspections, install monitoring, and if active corrosion is
determined, implement mitigation methods to ensure that CITGO is in compliance
with $195. 579.
8, CITGO shall maintain documentation of the safety improvement costs associated
with fulfilling this Compliance Order and submit the total to R. M. Seeley, Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration. Costs
shall be reported in two categones: 1) total cost associated with preparation/revision
of plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
9. Submit to the Director, Southwest Region, Pipeline and Hazardous Materials Safety
Administration, 8701 South Gessnei, Suite 1110, Houston, Texas 77074:
~ Results of surveys, assessments, and plans, with time table, must be
submitted within 30 days following the receipt of the Final Order
~ All items shall be completed within 180 days following the receipt of the Final
Order.

420075010_FinalOrder_04142011_text.pdf

APR 14 2011
Mr. Jim Sanders
General Manager, Terminal and Pipelines
CITGO Petroleum Corporation
1293 Eldridge Parkway
Houston, TX 77077
Re: CPF No. 4-2007-5010
Dear Mr. Sanders:
Enclosed please find the Final Order issued in the above-referenced case. It withdraws two of
the allegations of violation, makes other findings of violation, assesses a reduced civil penalty of
$82,000, and specifies actions that need to be taken by CITGO Pipeline Company to comply
with the pipeline safety regulations. The penalty payment terms are set forth in the Final Order.
When the civil penalty has been paid and the terms of the compliance order completed, as
determined by the Director, Southwest Region, this enforcement action will be closed. Service
of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Rod Seeley, Director, Southwest Region, PHMSA
Christian A. Garza, Corporate Counsel, CITGO Petroleum Corporation
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 1160 0001 0075 9169]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
______________________________
)
In the Matter of )
)
CITGO Pipeline Company, ) CPF No. 4-2007-5010
)
Respondent. )
______________________________)
FINAL ORDER
From February until June 2006, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline
and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of the facilities and records of CITGO Pipeline
Company (CITGO or Respondent), a subsidiary of CITGO Petroleum Corporation.1 The OPS
inspection included CITGO pipeline facilities in Louisiana, Texas and Oklahoma.
2
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated April 2, 2007, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the
Notice proposed finding that Respondent had committed various violations of 49 C.F.R. Part 195
and proposed assessing a civil penalty of $94,000 for the alleged violations. The Notice also
proposed ordering Respondent to take certain measures to correct the alleged violations. The
Notice further proposed finding that Respondent had committed another probable violation of 49
C.F.R. Part 195 and warning Respondent to take appropriate corrective action to address it or be
subject to future enforcement action.
1 CITGO Petroleum Corporation, a refiner, transporter and marketer of transportation fuels, lubricants,
petrochemicals and other industrial products, is owned by PDV America, Inc., an indirect, wholly-owned
subsidiary of Petroleos de Venezuela, S.A., the national oil company of Venezuela. See
http://www.citgo.com/AboutCITGO/CompanyHistory.jsp (last accessed December 13, 2010).
2 The OPS inspection included the following facilities: (1) the Sour Lake District facilities, including a 64-mile, 20-
inch pipeline that transports crude oil from a tank farm in Sour Lake, Texas, to Lake Charles, Louisiana, and a 100-
mile, 10- and 12-inch pipeline that transports propane and ethane from Lake Charles to Mount Belvieu, Texas; (2)
the Eagle Line South, including a 264-mile pipeline that transports petroleum products from a pump station in
Pasadena, Texas, to Arlington, Texas, and five other short pipelines in the Houston area; (3) the Eagle Line North,
including an 8-inch, 229-mile pipeline that transports petroleum products from Arlington to Drumright, Oklahoma;
and (4) a control center in Tulsa, Oklahoma.



2
CITGO responded to the Notice by letters dated May 4 and June 25, 2007 (collectively,
Response). Respondent contested several of the allegations and requested a hearing, which was
subsequently held on July 24, 2007, with an attorney from the Office of Chief Counsel, PHMSA,
presiding. At the hearing, Respondent was represented by counsel, Mr. Christian A. Garza.
After the hearing, CITGO provided additional written material for the record by letter dated
August 23, 2007 (Closing).
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.128, which states:
§ 195.128 Station piping.
Any pipe to be installed in a station that is subject to system pressure
must meet the applicable requirements of this subpart.
The Notice alleged that CITGO violated § 195.128 by installing pipe in a station that did not
meet the applicable requirements in Subpart C of Part 195. Specifically, the Notice alleged that
stations and had connected the tanks to its pipeline with rubberized braided hoses, an installation
that was not consistent with accepted industry standards (ASME B31.4) or Subpart C of 49
Respondent had installed permanent tanks for storing drag reducing agent (DRA)3 at its pump
C.F.R. Part 195, particularly the requirement that station piping be of steel construction.
In its Response and at the hearing, CITGO argued that the installation of its DRA injection
systems did not violate § 195.128. Specifically, Respondent stated that DRA is not a hazardous
liquid, and that it had equipped the attached hoses with steel check valves to ensure that they
would not experience system pressure. CITGO also stated that the pressure ratings of the hoses
exceeded the maximum pressure requirements for its pipeline system. Therefore, the
requirements in § 195.128 did not apply to this piping.
OPS countered that Respondent’s DRA injection systems were “fabricated assemblies” under 49
assemblies to its pipeline to comply with 49 C.F.R. §§ 195.100 and 195.112(a). Steel station
piping was required, OPS asserted, because the operating pressure of the DRA injection system
C.F.R. § 195.130,4 and that CITGO had to use steel station piping to connect the hoses in these
exceeded that of Respondent’s pipelines.
Section 195.128 only applies to station piping that is subject to system pressure. A “pipe” is
defined for purposes of 49 C.F.R. Part 195 as “a tube, usually cylindrical, through which a
hazardous liquid or carbon dioxide flows from one point to another.
”5
OPS argues that CITGO’s
3 DRA is a compound used to reduce friction and improve flow rate in petroleum pipelines.
4 Section 195.130 states: “Each fabricated assembly to be installed in a pipeline system must meet the applicable
requirements of [Subpart C of 49 C.F.R. Part 195].”
5 49 C.F.R. § 195.2.



3
DRA injection hoses are installed in pump stations and operate at a pressure higher than that of
its pipelines. Therefore, those hoses are station “pip[ing] . . . subject to system pressure” under
§ 195.128 and must be of steel construction to comply with the design requirements in Subpart C
of 49 C.F.R. Part 195, including §§ 195.100 and 195.112(a).
I do not find OPS’ position persuasive.6
CITGO’s DRA injection systems are “pipeline facilities” within the scope of the Pipeline Laws
and Regulations.
7 However, § 195.128 only applies to “pipe,” not all pipeline facilities, and, as
noted above, the term “pipe” is defined as “a tube, usually cylindrical, through which a
hazardous liquid or carbon dioxide flows from one point to another.” The evidence indicates
that the only product which flows through Respondent’s DRA injection systems “from one point
to another” is DRA, a compound that OPS has not argued is a hazardous liquid or carbon
dioxide.
8
Moreover, the fact that Respondent’s DRA injection hoses operate at a pressure higher than that
of its pipelines does not make those hoses “subject to system pressure” under § 195.128. In
order for that regulation to apply, station piping must be capable of experiencing or being
affected by the internal operating pressure of the pipeline system. That is not the case here, as
the evidence shows that CITGO has used independent pumps to provide the pressure for its DRA
injection systems and had installed steel check valves to isolate the hoses from the internal
pressure of its pipeline.
For these reasons, I find that Respondent’s DRA hoses are not station piping subject to system
pressure for purposes of § 195.128. Accordingly, based upon a review of all the evidence, I
hereby withdraw Item 1 of the Notice.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.406(b), which states:
§ 195.406 Maximum operating pressure.
(a) . . . .
6 OPS bears the burden of proof in an enforcement proceeding and must prove, by a preponderance of the evidence,
that an alleged violation occurred, i.e., that an operator had a legal duty to follow a particular regulation, and that it
breached that duty by engaging in conduct that did not meet the applicable requirements. In the Matter of Butte
Pipeline Co. (Butte), Final Order, CPF No. 5-2007-5008, p.2 (Aug. 17, 2009)
(http://primis.phmsa.dot.gov/comm/reports/enforce/documents/520075008/520075008_Final%20Order_08172009.p
df?nocache=1644); see also, Schaeffer v. Weast, 546 U.S. 49, 56-58 (2005).
7 49 C.F.R. § 195.2 defines the term pipeline facility as “new and existing pipe, rights-of-way and any equipment,
facility, or building used in the transportation of hazardous liquids or carbon dioxide.”
8 The term hazardous liquid is defined as “petroleum, petroleum products, or anhydrous ammonia.” The term
petroleum is defined as “crude oil, condensate, natural gasoline, natural gas liquids, and liquefied petroleum gas.”
The term petroleum product is defined as “flammable, toxic, or corrosive products obtained from distilling and
processing of crude oil, unfinished oils, natural gas liquids, blend stocks and other miscellaneous hydrocarbon
compounds.” Id.



4
(b) No operator may permit the pressure in a pipeline during surges or
other variations from normal operations to exceed 110 percent of the
operating pressure limit established under paragraph (a) of this section.
Each operator must provide adequate controls and protective equipment to
control the pressure within this limit.
The Notice alleged that CITGO violated § 195.406(b) by failing to provide “adequate controls
and protective equipment” to control the pressure of its pipeline within 110 percent of its
maximum operating pressure (MOP). Specifically, the Notice alleged that Respondent had no
records showing that it had considered “surge pressures” or that the pipeline was adequately
protected from surges whereby the pressure could exceed 110 percent of MOP.
In its Response and at the hearing, CITGO argued that a “surge analysis” was not the only means
of determining the adequacy of its pressure controls and protective equipment under
§ 195.406(b). Respondent stated that operating records could be used to show that a particular
pipeline had not previously experienced surges over 110 percent of MOP. The company also
included in its Response a brief analysis of its malfunction and abnormal operating condition
reports for the 2004, 2005, and 2006 calendar years; a description of the controls and protective
equipment it had installed on its pipeline system; and a 1996 memorandum describing the results
of a surge analysis of its Eagle South Pipeline. These documents, CITGO asserted, showed that
its pipelines had not experienced, and were not likely to experience, pressure surges over 110
percent of MOP. Notwithstanding its defense to the allegations, Respondent agreed to perform a
surge analysis to substantiate the adequacy of the controls and protective equipment on its
pipeline systems.
I do not find Respondent’s arguments convincing. None of the evidence in the record shows that
Respondent considered pressure surges before installing the controls and protective equipment
on its pipeline systems. CITGO did not complete its brief analysis of the reports from the 2004
to 2006 calendar years or its description of the protective equipment on its pipeline systems until
after the issuance of this Notice; the 1996 memorandum only covered the 10-inch Eagle South
Pipeline; and there is no evidence that Respondent could, or did, consider that memo in
determining the appropriate controls and protective equipment for its other pipelines.
9
Accordingly, based upon a review of all of the evidence, I find that Respondent violated
§ 195.406(b) by failing to provide adequate controls and protective equipment to control the
pressure of its pipeline within the limit established under paragraph (a) of that regulation.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.410(a), which states, in
relevant part:
§ 195.410 Line markers.
(a) Except as provided in paragraph (b) of this section, each operator
shall place and maintain line markers over each buried pipeline in
accordance with the following:
9 See, In the Matter of Kinder Morgan Energy Partners, L.P., C.P.F. 4-2006-5023 (Aug. 31, 2010).



5
(1) Markers must be located at each public road crossing, at each
railroad crossing, and in sufficient number along the remainder of each
buried line so that its location is accurately known.
The Notice alleged that CITGO violated § 195.410(a) by failing to install a sufficient number of
markers along its buried pipeline so that its location was accurately known. Specifically, the
Notice alleged that certain line markers could not be seen in either direction when crossing
cultivated agriculture fields and at valve sites.
In its Response and at the hearing, CITGO argued that pipeline markers need not provide “line-
of-sight” in all directions to comply with § 195.410(a)(1).
PHMSA acknowledges that while many operators follow the so-called “line-of-sight” test, as
applied in the Notice in this case, many others do not. Furthermore, the regulation does not
expressly require “line-of-sight.” In an effort to arrive at greater consensus on this and other
line-marking issues, PHMSA convened a public workshop in 2008 and is currently considering
whether to issue a notice of proposed rulemaking.10
Under such circumstances, I find it is appropriate to withdraw the allegation of probable
violation in Item 2 of the Notice. Such withdrawal neither constitutes an interpretation of
§ 195.410(a)(1) nor prejudices future potential enforcement action against Respondent or any
other operator.11
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.412(a), which states:
§ 195.412 Inspection of rights-of-way and crossings under navigable
waters.
(a) Each operator shall, at intervals not exceeding 3 weeks, but at
least 26 times each calendar year, inspect the surface conditions on or
adjacent to each pipeline right-of-way. Methods of inspection include
walking, driving, flying or other appropriate means of traversing the right-
of-way.
The Notice alleged that Respondent violated 49 C.F.R. § 195.412(a) by failing to inspect the
surface conditions on or adjacent to each pipeline right-of way (ROW) at the required intervals.
Specifically, the Notice alleged that large tree overhangs were allowed to grow and form a
canopy over the pipeline that obscured the surface conditions adjacent to the ROW from
observation by aerial surveillance, which is CITGO’s primary means of patrolling its pipelines.
Respondent did not contest this allegation. Accordingly, based upon a review of all the
10 The workshop was held on February 20-21, 2008, in Houston, Texas, to discuss, among other issues, the location
of line markers. Pipeline Safety: Workshop on Public Awareness Programs for Pipeline Operators and Location of
Line Markers, 73 Fed. Reg. 223 (Jan. 2, 2008).
11 The Notice also indicated that the line markers on the Northgate Forest Golf Course were flush-mounted and did
not list the correct operator name and phone number, an allegation that, if true, would constitute a violation of 49
C.F.R. § 195.410(a)(2)(ii). However, as the primary focus of Item 3 was the “line-of-sight” requirement and the
Notice did not specifically cite an alleged violation of subsection (a)(2)(ii), no further action regarding CITGO’s
potential non-compliance with § 195.410(a)(2)(ii) is appropriate.



6
evidence, I find that CITGO violated 49 C.F.R. § 195.412(a) by failing to inspect the surface
conditions on or adjacent to each pipeline ROW.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. §§ 195.432(b) and (d), which
state:
§ 195.432 Inspection of in-service breakout tanks.
(a) . . . .
(b) Each operator shall inspect the physical integrity of in-service
atmospheric and low-pressure steel aboveground breakout tanks according
to section 4 of API Standard 653. However, if structural conditions
prevent access to the tank bottom, the bottom integrity may be assessed
according to a plan included in the operations and maintenance manual
under Sec. 195.402(c)(3).
(c) . . . .
(d) The intervals of inspection specified by documents referenced in
paragraphs (b) and (c) of this section begin on May 3, 1999, or on the
operator's last recorded date of the inspection, whichever is earlier.
The Notice alleged that Respondent violated 49 C.F.R. §§ 195.432(b) and (d) by failing to
inspect the physical integrity of its breakout tanks in accordance with section 4 of API Standard
653 at the required intervals. Specifically, the Notice alleged that CITGO had not properly
identified or resolved certain API 653 compliance issues during its monthly inspections. The
Notice also alleged that CITGO’s tank inspection records showed that two tanks were overdue
for their out-of-service internal inspections; eight tanks missed their in-service external
inspections; and eight tanks missed their ultrasonic inspections.
In its Response, CITGO did not contest these allegations. It offered no information to defend the
adequacy of its monthly inspections, agreed that some of its breakout tanks had not received the
required external inspections and acknowledged that a review and revision of its procedures for
performing those inspections were in order. CITGO also provided an explanation as to why
some of the breakout tanks in the Sour Lake District had not been inspected at the required
intervals. Respondent provided similar information in its Closing.
Accordingly, based upon a review of all the evidence, I find that Respondent violated 49 C.F.R.
§§ 195.432(b) and (d) by failing to inspect the physical integrity of its breakout tanks in
accordance with section 4 of API Standard 653 at the required intervals.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. §§ 195.573(d) and (e), which
state:
§ 195.573 What must I do to monitor external corrosion control?
(a) . . . .
(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



7
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.
(e) Corrective action. You must correct any identified deficiency in
corrosion control as required by § 195.401(b). However, if the deficiency
involves a pipeline in an integrity management program under § 195.452,
you must correct the deficiency as required by § 195.452(h).
The Notice alleged the Respondent violated 49 C.F.R. §§ 195.573(d) and (e) by failing to have
an adequate external corrosion control program for its aboveground breakout tanks and to ensure
that operation and maintenance of its cathodic protection system was in accordance with API
Recommended Practice 651 (RP 651). Specifically, it alleged that the company failed to correct
an identified deficiency in corrosion control within “a reasonable time,” as required by
§ 195.401(b), because one of the ground beds at the Sour Lake Tank Farm had started failing in
December 2002, had completely failed by October 2003, and had remained out of service at the
time of the February 2006 OPS inspection.
In its submissions and at the hearing, CITGO argued that the Sour Lake Tank Farm had four
ground beds, that only one of those beds was out of service, and that the three remaining ground
beds provided adequate cathodic protection throughout the relevant period. The company further
stated that it had intended to replace the failed ground bed, if needed, and that it had done so in
the fall of 2006. OPS countered that the cathodic protection system for the Sour Lake Tank
Farm was designed to function as a unit, and that all four ground beds had to be operational for it
to be considered “adequate” under RP 651.
The evidence supports OPS’ position. CITGO installed a four-bed cathodic protection system at
the Sour Lake Tank Farm, and there is no evidence, aside from the company’s mere assertion in
response to the Notice, that the system was designed to provide adequate protection in the event
that one of the beds failed. Moreover, CITGO knew of the failed ground bed but did not correct
the deficiency for more than three years. Accordingly, based upon a review of all the evidence, I
find that Respondent violated 49 C.F.R. §§ 195.573(d) and (e) by failing to have an adequate
cathodic protection system for its aboveground breakout tanks and to correct an identified
deficiency in that system, as required by § 195.401(b)
Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 195.579(a), which states:
§ 195.579 What must I do to mitigate internal corrosion?
(a) General. If 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.
The Notice alleged that Respondent violated 49 C.F.R. § 195.579(a) by failing to investigate the
corrosive effects of a hazardous liquid on its pipeline and take adequate steps to mitigate internal
corrosion control. In particular, the Notice alleged that Respondent had not inspected certain
dead legs, low points, facility and non-piggable pipe, and areas downstream of supplier taps for



8
indications of internal corrosion. The Notice further alleged that Respondent did not have an
adequate program for monitoring internal corrosion, including proper corrosion monitoring
points.
In its submissions and at the hearing, CITGO stated that it only transported refined petroleum
products and crude oil imported via supertanker, neither of which is typically corrosive in a
pipeline. Respondent further stated that it monitored for internal corrosion through “top-of-the-
line” corrosion control coupons, and that the historical data from those coupons, including
corrosion probe readings, showed that its pipelines had not experienced any corrosion-related
problems.
I do not find CITGO’s arguments persuasive.
Respondent’s assertion that the products transported through its pipelines are not corrosive is
unsubstantiated. As PHMSA has stated,
“49 CFR 195.579(a) require[s] operators to determine if
the hazardous liquids they are transporting could corrode the pipeline and, if so, take adequate
steps to mitigate that corrosion potential.” 12 Furthermore, “in accordance with 49 CFR
195.589(c), [operators] must maintain a record of the above analysis required by 49 CFR
195.579(a) in sufficient detail to demonstrate the adequacy of corrosion control measures or that
corrosion control measures are not necessary[,] . . . these records [must be retained] for at least
five years[,] . . . [and they] must be readily available for inspection.”13
In this case, the record does not indicate that CITGO ever performed any type of analysis to
determine if the products being transported could be corrosive. Such analysis would require
consideration of such risk factors as commodity type, flow rate, velocity, and operating pressure;
the potential presence of foreign materials, contaminants, microbes, or other corrosive
substances; pipe configuration, design, and specifications; and operating conditions.14
In addition, the historical data that Respondent relied upon to establish the non-corrosive nature
of its products is inconclusive, i.e., the OPS inspector stated that CITGO’s corrosometer probes
were only capable of detecting severe corrosion in their present locations, and that the probes
themselves were susceptible to pitting corrosion, which could affect the accuracy of any resulting
readings. Therefore, Respondent should have used corrosometer probes in conjunction with
other methods to monitor internal corrosion.15
Moreover, the evidence indicates that CITGO’s corrosion control coupons were not located in all
areas where water and other corrosive components could potentially accumulate, including
facilities that were not amenable to inline inspection and areas of intermittent flow. Respondent
has not demonstrated whether, if corrosion did occur, it would be prepared to take adequate steps
to mitigate its effects, such as through the implementation of an inhibition program.
12 73 Fed. Reg. 71089-90 (Nov. 24, 2008).
13 Id.
14 Id.
15 See, In the Matter of Sunoco Pipeline, L.P., C.P.F. 4-2007-5040 (Dec. 16, 2010).



9
Accordingly, based upon a review of all the evidence, I find that Respondent violated 49 C.F.R.
§ 195.579(a) by failing to investigate the corrosive effects of a hazardous liquid on its pipeline
and to take adequate steps to mitigate internal corrosion control.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s
ability to pay the penalty and any effect that the penalty may have on its ability to continue doing
business; and the good faith of Respondent in attempting to comply with the pipeline safety
regulations. In addition, I may consider the economic benefit gained from the violation without
any reduction because of subsequent damages, and such other matters as justice may require.
The Notice proposed a total civil penalty of $94,000 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $12,000 for Respondent’s alleged violation of 49
C.F.R. § 195.128, for failing to install station piping that met the applicable requirements in
Subpart C. As noted above, I found that CITGO’s DRA injection hoses were not station piping
subject to system pressure for purposes of that regulation. Based upon the foregoing, I withdraw
the proposed penalty for violation of 49 C.F.R. § 195.128.
Item 6: The Notice proposed a civil penalty of $32,000 for Respondent’s violation of 49 C.F.R.
§§ 195.432(b) and (d), for failing to inspect the physical integrity of its breakout tanks in
accordance with section 4 of API Standard 653 at the required intervals. Specifically, the Notice
alleged that CITGO had not properly identified or resolved certain API 653 compliance issues
during its monthly inspections. The Notice also alleged that CITGO’s tank inspection records
showed that two tanks were overdue for their out-of-service internal inspections; eight tanks
missed their in-service external inspections; and eight tanks missed their ultrasonic inspections.
CITGO did not contest these alleged violations. Breakout tank inspections are designed to detect
corrosion, settlement, and other threats to the integrity of those facilities. When inspections are
not adequately performed or do not occur at the required intervals, these threats are more likely
to progress to the point of failure. The environmental consequences of such an event would be
significant, particularly given the large quantity of hazardous liquids stored in the tanks.
Moreover, the evidence shows that Respondent is fully culpable for failing to perform the
required inspections, and there is no allegation that payment of the proposed penalty would
impair its ability to continue doing business. Based upon the foregoing, I assess CITGO a civil
penalty of $32,000 for violating 49 C.F.R. §§ 195.432(b) and (d).



10
Item 7: The Notice proposed a civil penalty of $50,000 for Respondent’s violation of 49 C.F.R.
§§ 195.573(d) and (e), for failing to have an adequate cathodic protection system at the Sour
Lake Tank Farm and to correct an identified deficiency in that system. The record indicates that
CITGO was aware that one of the ground beds in that system had failed but took no steps to
address that deficiency for more than three years. In so doing, CITGO created an environment
where corrosion at the Sour Lake Tank Farm could progress to a critical phase and present a
significant risk to the safety of the public, property, and the environment. Furthermore, the
evidence shows that Respondent was fully culpable for failing to correct this deficiency. The
company has not presented any evidence or argument that would justify a reduction in the
proposed penalty. Based upon the foregoing, I assess CITGO a civil penalty of $50,000 for
violation of 49 C.F.R. §§ 195.573(d) and (e).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $82,000.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require this payment be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, OK 73125. The Financial
Operations Division’s telephone number is (405) 954-8893.
Failure to pay the $82,000 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1, 2, 3, 4, 6, 7 and 8 in the Notice
for violations of 49 C.F.R. §§ 195.128, 195.406(b), 195.410(a)(1), 195.412(a), 195.432 (b) and
(d), 195.573(d) and(e), and 195.579(a), respectively. Under 49 U.S.C. § 60118(a), each person
who engages in the transportation of hazardous liquids or who owns or operates a pipeline
facility is required to comply with the applicable safety standards established under chapter 601.
I have withdrawn Items 1 and 3, so there is no need to include compliance terms for those Items.
The remaining compliance requirements are set forth below.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is
ordered to take the following actions to ensure compliance with the pipeline safety regulations
applicable to its operations:
1. With respect to the violation of 49 C.F.R. § 195.406(b) (Item 2), Respondent must
perform an audit to ensure that it has adequate controls and protective equipment for



11
controlling the pressure of its pipeline within 110 percent of MOP. The audit must
include a hydraulic analysis of the effect of surges during normal operations. Respondent
must provide the Director with the results of that analysis and documentation of the
implementation of any required modification to its pipeline facilities or equipment.
2. With respect to the violation of 49 C.F.R. § 195.412(a) (Item 4), Respondent must
inspect all of its pipelines to locate areas where the ROW is overgrown with brush or tall
grass or is overgrown by a canopy from surrounding trees that prevents visibility from
aerial surveillance; develop a plan and schedule to clear brush and canopy from the
ROW; and a plan for alternative surveillance method for affected ROWs that are being
cleared and made suitable for aerial surveillance.
3. With respect to the violation of 49 C.F.R. §§ 195.432(b) and (d) (Item 6), Respondent
must review its program for inspecting breakout tanks; develop a plan and schedule for
inspecting any tanks that have missed any required periodic inspections; and provide
documentation showing that it takes note monthly of items required under API 653 and
any other matters from prior inspections that still require further action.
4. With respect to the violation of 49 C.F.R. §§ 195.573(d) and (e) (Item 7), Respondent
must review its cathodic protection program; determine whether any of its cathodic
protection systems are in need of repair or replacement; and develop a plan and schedule
for performing such repairs or replacements.
5. With respect to the violation of 49 C.F.R. § 195.579(a) (Item 8), Respondent must
perform a comprehensive assessment to fully determine the corrosive effect of the
transported products on pipelines and all facilities; provide documentation showing that
areas susceptible to internal corrosion are inspected and monitored; and provide
documentation showing that adequate steps to mitigate internal corrosion are
implemented on any areas of active corrosion.
6. Respondent is requested to maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration, 8701 South
Gessner, Suite 1110, Houston, Texas 77074. Costs shall be reported in two categories:
1) total cost associated with preparation/revision of plans, procedures, studies and
analyses, and 2) total cost associated with replacements, additions and other changes to
pipeline infrastructure.
7. Within thirty days (30) days of receipt of the Final Order, Respondent must submit all
required surveys, assessments, and plans with timetables, to the Director, Southwest
Region, Pipeline and Hazardous Materials Safety Administration, 8701 South Gessner,
Suite 1110, Houston, Texas 77074.
8. Within 180 days of receipt of the Final Order, Respondent must complete all actions
required by this Compliance Order and submit documentation of completion to the
Director.



12
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
WARNING ITEM
With respect to Item 5, the Notice alleged probable violations of Part 192 but did not propose a
civil penalty or compliance order for this item. Therefore, this is considered to be a warning
item. The warning was for:
49 C.F.R. § 195.420(c) (Notice Item 5) ─ Respondent’s alleged failure to protect
the valves on its pipeline systems from unauthorized operation and vandalism.
Although Respondent contested this item in its Response and at the hearing, it could not
demonstrate that it had developed or implemented an adequate, risk-based process for ensuring
valve protection. In particular, the evidence showed that CITGO had used various methods at
different sites without having a reasoned basis for making those distinctions.
Accordingly, having considered such information, I find, pursuant to 49 C.F.R. § 190.205, that
probable violations of 49 C.F.R. § 195.420(c) (Notice Item 5) have occurred and Respondent is
hereby advised to correct such conditions. In the event that OPS finds a violation of this
provision in a subsequent inspection, Respondent may be subject to future enforcement action.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420075010>
- Source ID: `phmsa-enforcement`
- SHA-256: `1ba64cb6d87055140ba3d568ae58df1cf2315f4a839951b59c34b712bc0861e0`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T09:37:15.420Z
- Document slug: `phmsa-enforcement-420075010`

### Source metadata

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