{"operation":"document","citation":"CPF 120085005W","title":"PORTLAND PIPE LINE CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-16","effective_on":null,"summary":"CLOSED warning letter citing 195.573(c), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120085005W","body":"Warning Letter involving PORTLAND PIPE LINE CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.573(c),  195.589(c). The case was opened on 2008-09-16 and is reported as closed as of 2008-09-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120085005W_Warning Letter_09162008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085005W/120085005W_Warning%20Letter_09162008.pdf\n\n120085005w_warning letter_09162008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085005W/120085005w_warning%20letter_09162008_text.pdf\n\n120085005w_warning letter_09162008_text.pdf\n\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n409 3\" St S W Suite 300\nWashington, D C 20024\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nSeptember 16, 2008\nMs. Marjorie Dawson\nPresident\nPortland Pipeline Terminal\n30 Hill Street\nS. Portland, ME 04106\nCPF I-200S-5005W\nDear Ms. Dawson:\nDuring the week of November 5, 2007, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour crude oil pipeline between Portland, Maine and Jay, Vermont\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n\n\n\n1. $195. 573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper\nperformance each device in the first column at the frequency stated in the\nsecond column.\nDevice\nRectifier\nReverse current switch\nDiode\nInterference bond whose failure would\neo ardize structural rotection\nOther interference bond\nCheck fre uenc\nAt least six times each calendar year, but\nwith intervals not exceeding 2 ~/i months\nAt least once each calendar year, but\nWith intervals not exceedin 15 months.\nPortland Pipeline Corporation (PMPL) has eighteen locations where one or both of its pipelines\nare bonded to ExxonMobil Pipeline or Portland Natural Gas Transmission Company. PMPL has\nrecords demonstrating that the electrical check on its interference bonds may not have been\nadequate in satisfying the regulations. PMPL provided the inspector with the records of the\neighteen locations. In a review of the procedures addressing the interference bonds, the\nfollowing was stated in Section 6. 5. 2. 4 of the PMPL written plan.\nSome of the most important tests include the following:. . .\nf) Resistance Bonds — These are electrical ties between our own lines and foreign\npipelines that cross us. Data is gathered that reflects the electric current flow in\namperes to or from these foreign lines.\nThere is no further guidance in the procedures explaining how PMPL obtains the field readings\nof these bonds nor how the readings are interpreted to determine whether a failure of the bond\nwould jeopardize the PMPL pipeline. Those bonds whose failure could jeopardize a PMPL\npipeline are required to be surveyed six times annually, In the records for the 18 locations\n(many of which contained multiple bonds) the operator provided, at best, annual readmgs. These\nreadings were potential readings (pipe to soil) in millivolts on the 18-mch and 24-inch pipelines\nand the foreign structure to which they were bonded. There was no direction in the procedures to\nrecord electric current flow in amperes to or from foreign lmes, nor was there any guidance on\nthe use of the pipe to soil readings that were performed and recorded on an annual basis. In\naddition, there was no assessment presented at the inspection whereby the operator distinguished\nwhich of the interference bonds would jeopardize the PMPL pipeline in the event of a bond\nfailure. A summary of the record review is below for each bond area.\n\n\n\nStation PMPL Foreign Line\nLine\n55+00\n18\"\n6\" ExxonMobil\n304+99\n350+30\n497+79\n624+40\n1198+72\n2515+20\n2639+59\n2878+76\n2991+37\n3264+46\n3563+19\n3571+63\n3791+40\n3874+52\n4066+00\n4257+39\n1 8»\n24\"\n24\"\n18\"\n24»\n18\"\n24\"\n18\"\n24»\n18\"\n24\"\n1 8»\n24»\n1 8»\n24\"\n18\"\n24»\n1 8»'\n24\"\n18\"\n24\"\n18\"\n24\"\n18\"\n24»\n18\"\n24\"\n18\"\n24»\n18\"\n24»\n12\" Gas\n6\" ExMob\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\n24\" PNGTS\nRemarks\nPipe to soil reads (p/s) not taken m 2007 on the\nExMobil i ehne.\nP/s reads complete for 5 years on the 3 structures.\nP/s reads complete for 5 years on the 2 structures\nmeasuring current through a shunt,\nP/s reads for 5 years on the 3 structures. Current\nrecorded during 2005 and 2006.\nP/s reads for 5 years on the 3 structures.\nP/s reads for 5 years on the 3 structures.\nP/s reads for 2002-2006 on the PMPL structures. None\nfor 2007. Not bonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. None\nfor 2007 Not bonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line\nP/s reads for 2002-2006 on the PMPL structures, Not\nbonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line.\nP/s reads for 2002-2006 on the PMPL structures. Not\nbonded to the PNGTS line.\nP/s reads for 5 years on the 3 structures. No current\nrecorded.\nThe probable violation is based upon a review of the operator's procedures and a review of the\ntest records and drawings of the PMPL's interference bonds with foreign structures.\n\n\n\n$195. 5S9 What corrosion control information do I have to maintain?\nc) You must maintain a record of each analysis, check, demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in\nsufficient detail to demonstrate the adequacy of corrosion control measures or that\ncorrosion requiring control measures does not exist. You must retain these records\nfor at least 5 years, except that records related to Secs. 195. 569, 195. 573(a) and (b),\nand 195. 579(b)(3) and (c) must be retained for as long as the pipeline remains in\nservice.\nOperator's written procedures state in section 6 of its written procedures:\nJ. Painting (Inspection)\nAll painted facilities are visually inspected [annually] for paint and coating failures.\nPaint or coating is applied to areas requiring attention during the following warm\nweather season. If any abnormalities are discovered, an immediate report is made\nto the Maintenance Supervisor South Portland or to the Senior Chief Montreal.\nThe operator had no record to demonstrate that PMPL monitored its pipeline facilities exposed to\nthe atmosphere for atmospheric corrosion. During the inspection, PMPL stated that it performed\nannual review of its facilities, and if paint or coatmg is needed, it is applied during the coming\nyear, There were no records on file to document the observations of the atmospheric corrosion\nevaluator.\nThe probable violation is based upon the operator's procedures and his lack of records to\ndemonstrate compliance with the monitoring of atmospheric corrosion.\nUnder 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circinnstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Portland Pipeline Corporation being subject to additional\nenforcement action\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-200S-5005W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U S. C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8738}