# SFPP, LP — Warning Letter

**Citation:** CPF 420085010W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2008-04-02

CLOSED warning letter citing 195.308, 195.505, 195.583(b).

## Document text

Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulations as 195.308,  195.505,  195.583(b). The case was opened on 2008-04-02 and is reported as closed as of 2008-04-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420085010W_warning_04022008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085010W/420085010W_warning_04022008.pdf

420085010w_warning_04022008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085010W/420085010w_warning_04022008_text.pdf

420085010w_warning_04022008_text.pdf

U. S. Department
of Transponatian
Is)pet)no and
Hazardous itttaterlats safely
Administration
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WARNING LETTER
CERTIFIED IIAIL - RETURN RECEIPT REQUESTED
April 2, 2008
Mr. Ron McClain
Vice Presiderit of Operations
SFPP, L. P.
500 Dallas Street, Suite 1000
Houston, TX 77002
CPF 4-2008-501 0W
Dear Mr. McClain:
On April 22-27, 2007, and July 10-12, 2007, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected a portion of your SFPP Pipeline system in Texas and New Mexico and the control
center in Orange, California.
As a result of the inspection, 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 violation(s) are:
1. 195. 308 Pipe associated with tie-ins must be pressure tested, either with the
section to be tied in or separately
195. 404 (a) Each operator shall maintain current maps and records of its pipeline
systems that include at least the following information;
(4) The diameter, grade, type and nominal wall thickness of all pipe.
The operator has records showing that a pressure test for several numbered joints of pipe was
certified by the California State Fire Marshall's office and these joint numbers have been
recorded on the inside of the pipes held as pre-tested pipe inventory at locations on the pipeline
system. However, the operator could not produce records that tie the pre-tested pipe inventory



to a mill specification or original purchase order showing the pipe characteristics, including
diameter, wall thickness, and yield strength.
2. 195. 505 Each operator shall have and follow a written qualification program. The
program shall include provisions to: (b) Ensure through evaluation that
individuals performing covered tasks are qualified;
The operator presented records showing that atmospheric corrosion inspections for the above-
ground valve components were performed as part of the mainline valve inspections. However,
according to the SFPP operator qualification program records, the valve inspector was not
qualified to perform atmospheric corrosion inspections.
3. 195. 583 (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.
A partially buried valve at Lordsburg Maintenance Building (MP 159) had a loose wrap at the
air/soil interface exposing the metal to the soil. Also, the supporting span crossing the Rio
Grande River had peeling paint and evidence of corrosion.
Under 49 United States Code, g 60122, you are subject to a civil penalty not to exceed
$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000
for any related series of violations. 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 correct the item(s) identified
in this letter. Failure to do so will result in SFPP being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2008-5010W. Be advised that ail material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420085010W>
- Source ID: `phmsa-enforcement`
- SHA-256: `2a437c4b13ef0eb1c05827361951ec33f41899faebd07f391cb25b02bc351b1f`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T21:05:14.941Z
- Document slug: `phmsa-enforcement-420085010w`

### Source metadata

```json
{
  "cpf": "420085010W",
  "operator": "SFPP, LP",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.308",
    "195.505",
    "195.583(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "420085010W_warning_04022008.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420085010W/420085010W_warning_04022008.pdf",
      "bytes": 218581,
      "category": "agency_document"
    },
    {
      "name": "420085010w_warning_04022008_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420085010W/420085010w_warning_04022008_text.pdf",
      "bytes": 876705,
      "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": "SFPP, LP"
}
```
