{"operation":"document","citation":"CPF 12021049WL","title":"SHELL PIPELINE CO., L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-07-16","effective_on":null,"summary":"CLOSED warning letter citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021049wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021049wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021049wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021049WL","body":"Warning Letter involving SHELL PIPELINE CO., L.P.. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2021-07-16 and is reported as closed as of 2021-07-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021049WL_Warning Letter_07162021_(20-172474).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021049WL/12021049WL_Warning%20Letter_07162021_(20-172474).pdf\n\n12021049WL_Warning Letter_07162021_(20-172474)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021049WL/12021049WL_Warning%20Letter_07162021_(20-172474)_text.pdf\n\n12021049WL_Warning Letter_07162021_(20-172474)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: steven.ledbetter@shell.com\nJuly 16, 2021\nMr. Steven Ledbetter\nVice President, US Pipelines\nShell Pipeline Company, LP\n150 North Dairy Ashford Road\nWCK BLDG. A\nHouston, TX 77079\nCPF 1-2021-049-WL\nDear Mr. Ledbetter:\nFrom August 18, 2020 to August 20, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Shell Pipeline Company, LP’s (Shell Pipeline) construction standards in\nImperial, PA.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent\nwith the requirements of this part.\nShell Pipeline failed to construct a pipeline system in accordance with its comprehensive written\nspecifications or standards. Specifically, Shell failed to follow its 40 TS-002 Construction of New\nOnshore Pipelines and Related Facilities, Approved for Use – 06/19 (40-TS-002), regarding\nsupport of coated pipe during handling.\nSection 4.4.2 Coated Pipe, part 3b of 40-TS-002 stated in part, “…all skids used to support coated\n\n\n\nCPF 1-2021-049-WL\npipe shall be padded.”\nDuring the inspection on August 19, 2020 near Short Lane, Potter Township, PA, the PHMSA\ninspector observed that there were two instances where coated pipe was supported on skids that\nwere not padded.\nTherefore, Shell Pipeline failed to construct its pipeline in accordance with its comprehensive\nwritten specifications or standards as required by § 195.202, as it pertain to 40-TS-002.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in Shell\nPipeline Company, LP being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2021-049-WL. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12021049WL_Warning Letter_07162021_(20-172474)_text Page 2 of 2","truncated":false,"body_characters":4838}