# TRANSMONTAIGNE OPERATING COMPANY L.P. — Warning Letter

**Citation:** CPF 420155010W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-04-13

CLOSED warning letter citing 195.573(c).

## Document text

Warning Letter involving TRANSMONTAIGNE OPERATING COMPANY L.P.. PHMSA's enforcement data identifies the cited regulation as 195.573(c). The case was opened on 2015-04-13 and is reported as closed as of 2015-04-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420155010W_Warning_04132015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155010W/420155010W_Warning_04132015.pdf

420155010W_Warning_04132015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155010W/420155010W_Warning_04132015_text.pdf

420155010W_Warning_04132015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 13, 2015
Mr. Edward Luebke
Vice President, Pipeline Operations
TransMontaigne Inc.
200 Mansell Court East, Suite 600
Roswell, GA 30076
CPF 4-2015-5010W
Dear Mr. Luebke:
On October 7-9, 2014, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United
States Code inspected your Diamondback Pipeline facilities in Brownsville, TX.
As a result of the inspection, it appears that you have committed a probable violation of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable
violation is:
1. §195.573 What must I do to monitor external corrosion control?
(c) Rectifiers and other devices. You must electrically check for proper performance each
device in the first column at the frequency stated in the second column.



Device Check Frequency
Rectifier……………………..
At least six times each calendar year,
but with intervals not exceeding 2 ½
months.
Reverse Current Switch,
Diode,
Interference bond whose failure would
jeopardize structural protection
Other interference bond ………… At least once each calendar year not to
exceed 15 months.
TransMontaigne did not inspect their Highway 281 rectifier at least six times each calendar
year with intervals not exceeding 2 ½ months. According to the TransMontaigne External
Corrosion Control Monitoring inspection report, in calendar year 2013 the rectifier was
inspected on February 28, June 28, November 15 and December 26 which did not meet the
required six inspections or the maximum interval of 2 ½ months between inspections.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per
violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed
$100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a 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 TransMontaigne Inc. 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
4-2015-5010W. Be advised that all 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).
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420155010W>
- Source ID: `phmsa-enforcement`
- SHA-256: `132f5bf871e07cb3fcd5e9af3365971fa2a9da73a442aa94d1f57776c7dd8469`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T18:59:22.995Z
- Document slug: `phmsa-enforcement-420155010w`

### Source metadata

```json
{
  "cpf": "420155010W",
  "operator": "TRANSMONTAIGNE OPERATING COMPANY L.P.",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.573(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "420155010W_Warning_04132015.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420155010W/420155010W_Warning_04132015.pdf",
      "bytes": 89935,
      "category": "agency_document"
    },
    {
      "name": "420155010W_Warning_04132015_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420155010W/420155010W_Warning_04132015_text.pdf",
      "bytes": 8367,
      "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": "TRANSMONTAIGNE OPERATING COMPANY L.P."
}
```
