{"operation":"document","citation":"CPF 120155009W","title":"PRODUCTS (SE) PIPE LINE CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-16","effective_on":null,"summary":"CLOSED warning letter citing 195.561(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120155009W","body":"Warning Letter involving PRODUCTS (SE) PIPE LINE CORPORATION. PHMSA's enforcement data identifies the cited regulation as 195.561(a). The case was opened on 2015-06-16 and is reported as closed as of 2015-06-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120155009W_Warning Letter_06162015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155009W/120155009W_Warning%20Letter_06162015.pdf\n\n120155009W_Warning Letter_06162015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155009W/120155009W_Warning%20Letter_06162015_text.pdf\n\n120155009W_Warning Letter_06162015_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJune 16, 2015\nMr. Wayne Simmons, VP Operations\nPlantation Pipe Line Company\n1001 Louisiana St, Suite 1000\nHouston, TX 77002\nCPF 1-2015-5009W\nDear Mr. Simmons:\nBetween August 27 and October 29, 2014, State Inspectors from the Virginia State Corporation\nCommission (VA SCC), acting as Agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected your Plantation Pipe Line\nCompany (PPL) pipeline construction activities in Stafford County, Virginia.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s)\nare:\n1. §195.561 When must I inspect pipe coating used for external corrosion control?\n(a) You must inspect all external pipe coating required by §195.557 just prior to lowering the pipe\ninto the ditch or submerging the pipe.\nPPL failed to inspect all external pipe coating required by §195.557(a) just prior to lowering/installing the\npipe into the ditch. During pipe installation, PPL did not adequately inspect the pipe coating to ensure\nthat it had sufficient adhesion/strength to resist damage due to handling and soil stress. PPL was not able\nto demonstrate that a coating Shore D hardness of at least 85 was obtained prior to pipe installation, per\nmanufacturer’s procedures.\nVA SCC’s first inspection of the jobsite located off of Arkendale Road in Stafford County, Virginia was\non August 27, 2014. At that time, the weld joints and coating were visually inspected along the 1,060\nfoot section of 12 inch pipe to be installed. The coating had been curing for several days prior to this\ninspection.\nVA SCC inspected the jobsite again on August 29, 2014. While VA SCC was onsite, the construction\ncrew started to pullback a section of pipe. VA SCC noted that additional coating had been applied to the\nweld joint areas since their inspection on August 27, 2014.\nUpon further investigation, VA SCC found that the additional coating had been applied the morning of\n\n\n\n1-2015-5009W\n2. 3. August 29, 2014, and the coating hardness was not measured by PPL as required by the manufacturer’s\nspecifications.\nWhen VA SCC questioned the PPL O&M Supervisor, he agreed that the coating had not been tested for\nShore D hardness.\n1. As a result, the PPL O&M Supervisor and VA SCC inspectors inspected the coating between the\nfifth and sixth joint using the thumbnail test and a thumb print was left in the coating.\nPPL did not have a durometer on-site to measure the coating hardness.\nOn August 29, 2014, PPL decided to remove the five joints of pipe from the bore hole, and re-\nblasted and recoated the joints with SP 2888.\nEvidence is based on VA SCC photographs of PPL girth weld, pipe entering bore hole, recoated weld\njoint, VA SCC Notice of Investigation (NOI) to PPL, and PPL’s response to the VA SCC NOI.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item(s) identified in this letter. Failure to do so will result in the City being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to: Byron\nCoy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628\nand please refer to CPF 1-2015-5009W. Be advised that all material you submit in response to this\nenforcement action 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 complete\noriginal document you must provide a second copy of the document with the portions you believe qualify\nfor confidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response letter\npertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Mr. Massoud Tahamtani, VA SCC\n120155009W_Warning Letter_06162015 Page 2 of 2","truncated":false,"body_characters":5662}