# CENEX PIPELINE LLC — Warning Letter

**Citation:** CPF 520165007W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2016-08-18

CLOSED warning letter citing 195.583(b).

## Document text

Warning Letter involving CENEX PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.583(b). The case was opened on 2016-08-18 and is reported as closed as of 2016-08-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520165007W_Operator Response to Notice_10052016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165007W/520165007W_Operator%20Response%20to%20Notice_10052016.pdf

520165007W_Warning Letter_08182016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165007W/520165007W_Warning%20Letter_08182016.pdf

520165007W_Warning Letter_08182016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165007W/520165007W_Warning%20Letter_08182016_text.pdf

520165007W_Warning Letter_08182016_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 18, 2016
Mr. Richard S. Petersen
President
Cenex Pipeline, LLC
PO Box 909
Laurel, MT 59044
CPF 5-2016-5007W
Dear Mr. Petersen:
Between December 2014 and November 2015, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States
Code, inspected the Cenex Products Pipeline (Cenex) between Laurel, Montana and Fargo,
North Dakota.
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 items inspected and
the probable violation is as follows:
1. 195.583 What must I do to monitor atmospheric corrosion control?
(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.
During the field inspection, Cenex’s Block Valve 17.1 near the Souris River in North Dakota
was surrounded by water. This flooded condition was said to be common, and Cenex has
been unable to adequately inspect and coat the exposed pipe at this location. In addition, there
are two (2) fixed supports without a pipe insulator at block valve 250 near Fargo where the



pipe appears to be corroding at the interface of the support and pipe. These areas must be
given attention to address ongoing atmospheric 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 Cenex Pipeline LLC 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 5-2016-5007W 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 M. Petronis (#145448)
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520165007W>
- Source ID: `phmsa-enforcement`
- SHA-256: `361b422dd118b5458b5b4e7cbc225717064dc0586a0ac5d9227280faeddc94b5`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T13:58:21.592Z
- Document slug: `phmsa-enforcement-520165007w`

### Source metadata

```json
{
  "cpf": "520165007W",
  "operator": "CENEX PIPELINE LLC",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.583(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
  "attachments": [
    {
      "name": "520165007W_Operator Response to Notice_10052016.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520165007W/520165007W_Operator%20Response%20to%20Notice_10052016.pdf",
      "bytes": 18729,
      "category": "party_submission"
    },
    {
      "name": "520165007W_Warning Letter_08182016.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520165007W/520165007W_Warning%20Letter_08182016.pdf",
      "bytes": 80339,
      "category": "agency_document"
    },
    {
      "name": "520165007W_Warning Letter_08182016_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520165007W/520165007W_Warning%20Letter_08182016_text.pdf",
      "bytes": 99262,
      "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": "CENEX PIPELINE LLC"
}
```
