# SFPP, LP — Warning Letter

**Citation:** CPF 520115002W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2011-02-23

CLOSED warning letter citing 195.428(a).

## Document text

Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulation as 195.428(a). The case was opened on 2011-02-23 and is reported as closed as of 2011-02-23. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520115002W_warning letter_02232011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115002W/520115002W_warning%20letter_02232011.pdf

520115002W_warning letter_02232011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115002W/520115002W_warning%20letter_02232011_text.pdf

520115002W_warning letter_02232011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 23, 2011
Mr. Ron McClain
Vice President of Operations and Engineering
Kinder Morgan Energy Partners, L. P., Products Pipelines
500 Dallas Street
Houston, TX 77002
CPF 5-2011-5002W
Dear Mr. McClain:
From June 1, 2010 to June 3, 2010, a representative of the California State Fire Marshal
representing the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Concord to Sacramento (LS130) pipeline system. As part of this inspection, he reviewed
records at your offices in Concord, Fairfield, and Sacramento, California.
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 probable violation is:
1. §195.428 (a) Overpressure safety devices
(a) Except as provided in paragraph (b) of this section, each operator shall, at
intervals not exceeding 15 months, but at least once each calendar year, or in
the case of pipelines used to carry highly volatile liquids, at intervals not to
exceed 7½ months, but at least twice each calendar year, inspect and test each
pressure limiting device, relief valve, pressure regulator, or other item of
pressure control equipment to determine that it is functioning properly, is in
good mechanical condition, and is adequate from the standpoint of capacity
and reliability of operation for the service in which it is used.



Kinder Morgan failed to inspect the Wickland take-off pressure relief valve (SX-PSV-1) at the
required interval. This pressure relief valve protects LS130 by bypassing the closed SX block
valve when shipping to Wickland. This valve was installed on August 31, 2005 but was not
calibrated until May 25, 2010 when Kinder Morgan added this valve to their “OPS Info”
inspection tracking program. The May 25, 2010 calibration record for the SX-PSV-1 valve
noted the “found” set point as 1,115 psig and the “left” set point as 1,100 psig, demonstrating it
was still functioning at close to the correct set point. Regardless, this pressure relief valve
exceeded the testing interval by approximately three years and six months.
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 item(s) identified in this
letter. Failure to do so will result in Kinder Morgan Energy Partners, L.P. 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 5-2011-5002W. 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,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 T. Finch (Activity #128416)
California State Fire Marshal - Mr. Bob Gorham
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520115002W>
- Source ID: `phmsa-enforcement`
- SHA-256: `8cfaea35686d864274662001764b35728e621b8fe24e4ffaf3ce61861a45eef0`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T15:31:46.467Z
- Document slug: `phmsa-enforcement-520115002w`

### Source metadata

```json
{
  "cpf": "520115002W",
  "operator": "SFPP, LP",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.428(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520115002W_warning letter_02232011.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520115002W/520115002W_warning%20letter_02232011.pdf",
      "bytes": 110547,
      "category": "agency_document"
    },
    {
      "name": "520115002W_warning letter_02232011_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520115002W/520115002W_warning%20letter_02232011_text.pdf",
      "bytes": 15642,
      "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"
}
```
