# BIG WEST OF CALIFORNIA, LLC — Warning Letter

**Citation:** CPF 520080026W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2008-12-15

CLOSED warning letter citing 192.917(e)(5), 192.947(e).

## Document text

Warning Letter involving BIG WEST OF CALIFORNIA, LLC. PHMSA's enforcement data identifies the cited regulations as 192.917(e)(5),  192.947(e). The case was opened on 2008-12-15 and is reported as closed as of 2008-12-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520080026W_warning letter_12152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080026W/520080026W_warning%20letter_12152008.pdf

520080026w_warning letter_12152008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080026W/520080026w_warning%20letter_12152008_text.pdf

520080026w_warning letter_12152008_text.pdf

U S. Department
of Transportation
Pipslline and
Hdzmdovs Materidlis Safety
Administrdition
12300 W Dakota Ave, Suite 110
Lakewood, CO 80228
WA~ING KKTTKR
December 15, 2008
Mr Gene Cotton
Vice President Refining/Plant Manager
Big West of Cahfornia, LLC
6451 Rosedale Highway
Bakersfield, CA 93308
CPF 5-2008-0026M
Dear Mr. Cotton
On April 1 and July 22-23, 2008, a representative of the Pipehne and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected
Big West of Cahfornia, LLC's (Big West) integrity Management Program (IMP) procedures
and records Our inspection was conducted at your offices in Bakersfield, Cahfornia
As a result of the inspection, it appears you have committed probable violations of the Pipeluie
Safety Regulations, Title 49, Code of Federal Regulations The items mspected and the
probable violations are
(e) Actions to address partjlcullar threats. Lf an operator identifies any of the
following threats, the operator must take the following actions to address the
threat.



Big West identified external and internal corrosion threats but had not developed a
written program to address these threats Big West's eight-inch diameter pipeline has
previously been ui liquid service The gas it currently transports contains hydrogen
sulfide These commodities are potentially corrosive
Regarding external corrosion, Big West is plannmg to make eleven (11) excavations at
immediate mdications based on Mears' ECDA supplemental assessment Also, Big
West plans to use UT guided wave on the pipe adjacent to these excavations to
evaluate internal corrosion at those locations Big West will then conduct further
analyses to determine how best to evaluate the risks from the internal corrosion tlireat.
Baker Hughes has been contacted to perform internal corrosion calculations and
modehng to determine the locations most likely for internal corrosion. Regardless of
these planned activities, the operator had not estabhshed a written program to comply
with 192 917 (e)(5)
Evidence: The hne has previously been in hquid service transporting potentially
corrosion causing products. It has not as yet determmed the presence of any internal
corrosloli
Big West does not have a documented training program for individuals with
responsibihties for Big West's IMP program Big West has identified this as an action
item during 2008
Evidence: No documented program existed for training company personnel with
responsibihties for implementmg its IMP program Big West has identified this as an
action item during 2008
Under 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed
$100, 000 for each violation for each day the 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 items
identified in this letter Failure to do so will result m Big West of Cahfornia, LLC bemg
subject to additional enforcement action



No reply to this letter is required If you choose to reply, ni your correspondence please refer
to CPF 5-2008-0026M. Be advised that all material you submit m response to this
enforcement action is subject to bemg made pubhcly available If you believe that any portion
of your responsive material quahfies 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 beheve quahfy for confidential treatment redacted and an explanation of why
you beheve the redacted mformation quahfies for confidential treatment under 5 U S C.
552(b)
Smcerely,
Chris al
Director, Western Region
Pipehne and Hazardous Materials Safety Administration
cc PHP-60 Comphance Registry
PHP-500 I Giliiam (¹121269)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520080026W>
- Source ID: `phmsa-enforcement`
- SHA-256: `728fe0e19a532c8b12ee43001ca1f81d6e71075189e6627ce27c261a3cd45e17`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T01:21:15.431Z
- Document slug: `phmsa-enforcement-520080026w`

### Source metadata

```json
{
  "cpf": "520080026W",
  "operator": "BIG WEST OF CALIFORNIA, LLC",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.917(e)(5)",
    "192.947(e)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520080026W_warning letter_12152008.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520080026W/520080026W_warning%20letter_12152008.pdf",
      "bytes": 189326,
      "category": "agency_document"
    },
    {
      "name": "520080026w_warning letter_12152008_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520080026W/520080026w_warning%20letter_12152008_text.pdf",
      "bytes": 183096,
      "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": "BIG WEST OF CALIFORNIA, LLC"
}
```
