# PLAINS PIPELINE, L.P. — Warning Letter

**Citation:** CPF 520145010W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2014-07-30

CLOSED warning letter citing 195.579(c).

## Document text

Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulation as 195.579(c). The case was opened on 2014-07-30 and is reported as closed as of 2014-07-30. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520145010W_warning letter_07302014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145010W/520145010W_warning%20letter_07302014.pdf

520145010W_warning letter_07302014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145010W/520145010W_warning%20letter_07302014_text.pdf

520145010W_warning letter_07302014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 30, 2014
Mr. Troy Valenzuela
Vice President, Environmental Health & Safety
Plains Pipeline, L.P.
333 Clay Street, Suite 1600
P.O. Box 4648
Houston, TX 77002
CPF 5-2014-5010W
Dear Mr. Valenzuela:
Between July 2013 and September 2013, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States
Code, inspected your Operations and Maintenance (O&M) procedures and records at your
headquarters in Houston, Texas, and field facilities in Casper, Wyoming.
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. §195.579 What must I do to mitigate internal corrosion?
(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect
the internal surface of the pipe for evidence of corrosion. If you find internal
corrosion requiring corrective action under Sec. 195.585, you must investigate
circumferentially and longitudinally beyond the removed pipe (by visual
examination, indirect method, or both) to determine whether additional
corrosion requiring remedial action exists in the vicinity of the removed pipe.
Per §195.579, the operator must inspect the internal surface of any pipe that is removed from
a pipeline to determine if there is evidence of internal corrosion. Also, per Plains Pipeline’s



Operations and Maintenance Procedures Manual Appendix C, all regulated pipelines must be
inspected for internal and external corrosion whenever exposed. During the records review
portion of the inspection, it was determined that an internal inspection was not performed on
a cutout portion of pipe on the Kirby to Casper 12” line which began on 4/24/2012, and
completed on 10/24/2012. Therefore, Plains Pipeline did not comply with the requirements of
Part 195.579(c). Plains Pipeline must inspect the internal surface of any pipe that is removed
to determine if there is evidence of corrosion.
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 Plains Pipeline, 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 5-2014-5010W and for each document you submit please provide a copy in
electronic format to PHP-WRADMIN@dot.gov whenever possible. 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 D. Hubbard (#142643)
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520145010W>
- Source ID: `phmsa-enforcement`
- SHA-256: `435a692ab5afbf9308e0d32bfb30d955c943b77f17ee12657cc959ae0f1d7ca7`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T20:01:44.722Z
- Document slug: `phmsa-enforcement-520145010w`

### Source metadata

```json
{
  "cpf": "520145010W",
  "operator": "PLAINS PIPELINE, L.P.",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.579(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520145010W_warning letter_07302014.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520145010W/520145010W_warning%20letter_07302014.pdf",
      "bytes": 60155,
      "category": "agency_document"
    },
    {
      "name": "520145010W_warning letter_07302014_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520145010W/520145010W_warning%20letter_07302014_text.pdf",
      "bytes": 10939,
      "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": "PLAINS PIPELINE, L.P."
}
```
