{"operation":"document","citation":"CPF 220075002W","title":"TRI-STATES NGL PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-03-01","effective_on":null,"summary":"CLOSED warning letter citing 195.404(a), 195.406, 195.575, 195.577(a), 195.589.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220075002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220075002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220075002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220075002W","body":"Warning Letter involving TRI-STATES NGL PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.404(a),  195.406,  195.575,  195.577(a),  195.589. The case was opened on 2007-03-01 and is reported as closed as of 2007-03-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220075002W_Warning Letter_03012007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220075002W/220075002W_Warning%20Letter_03012007.pdf\n\n220075002W_Warning Letter_03012007.pdf\n\nf.:\"n t ? 3:X7\n@\nU.S. Deporlmenl\nof Tronsporlotion\nPlpellne ond\nHozordour Mqlefiols sofety\nldminlstrotlon\n233 Peachtree Street Ste. 600\nAtlanra. GA 30303\nWARNING LETTER\nCERTIF'IED MAIL . RETURN RECEIPT REOUESTED\nMarch 1, 2007\nMr. Jim Lamanna\nPresident\nBP Pipelines NA Inc.\nTristate NGL Pipeline L.L.C.\n28 100 Torch Parkway\nWanenville. IL 60555\ncPF 2-2007-5002W\no\nDear Mr. Lamanna:\nOn October 23 - 25, 2006, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nTristate NGL Pipeline, L.L.C. faci$ies and records in Alabama and Mississippi.\nAs a result of the inspection, it appets that you have committed probable violations of the\nPipeline Safety Regulations Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. $195.404 Maps and records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information:\n(2) All crossings ofpublic roads, railroads, rivers, buried utilities, and foreign\npipelines.\n(4) The diameter, grade, type and nominal wall thickness of all pipe.\n\n\n\n7\nJ .\n4.\nJ.\nTristate did not provide arecent survey map of its pipeline showing public roads,\nrailroads, rivers, buried utilities and foreign pipelines. The map provided during the\ninspection specified pipe grade, diameter and coating but did not cover all ofthe\nTristate NGL pipeline. Tristate personnel asserted the coating on the pipe was coal tar,\nhowever, the map specified FBE.\n$195.577 What must I do to alleviate interference currents?\n(a) For pipelines exposed to stray currents, you must have a program to identify'\ntest for, and minimize the detrimental effects of such currents.\nTristate did not provide a record verifying testing for stray currents or analysis of\nnon-exposure to stray curTents.\n5195,575 Which facilities must I electrically-isolate and what inspections, tests, and\nsafeguards are required?\n(a) You must electrically isolate each buried or submerged pipeline from other\nmetallic structures, unless you electrically interconnect and cathodically protect\nthe pipeline and the other structures as a single unit.\n(c) You must inspect and electrically test each electrical isolation to assure the\nisolation is adequate.\nTristate did not provide a record verifying inspection of its electrical isolations.\n$195.589 What corrosion control information do I have to maintain?\n(a) You must maintain current records or maps to show the location of -\n(1) Cathodically protected pipelines;\n(2) Cathodic protection facilities, including galvanic anodes, installed after\nJanuary 29, 2002; and\n(3) Neighboring structure{rbonded to cathodic protection systems.\n(b) Records or maps shoriigg a stated number of anodes, installed in a stated\nmanner or spacing, need not show specific distances to each buried anode.\nTristate did not provide an adequate record and or map showing location of the\nfollowing: sacrificial anodes, ground beds, critical and non-critical bonds, rectihers,\nelectrical isolations, test stations, AC interference components, lightening\narrestors and grounds.\n$195.406 Maximum operating pressure.\n\n\n\n\\\no\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(f ) The internal design pressure of the pipe determined in accordance with\n$195.106, However, for steel pipe in pipelines being converted under $195.5, if\none or more factors of the design formula ($195.106) are unknown, one of the\nfollowing pressures is to be used as design pressure:\n(i) Eighty percent ofthe first test pressure that produces yield under section N5.0\nof appendix N of ASME 831.8, reduced by the appropriate factors in\n$$r95.r06(a) and (e); or\n(ii) If the pipe is l2Ye in (324 mm) or less outside diameter and is not tested to yield\nunder this paragraph,200 p.s.i. (1379 kPa) gage.\n(2) The design pressure of any other component ofthe pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under Subpart E ofthis part.\n(a) pighty percent of the factory test pressure or of the prototype test pressure for\nany individually installed component which-is excepfed from testing under\n$19s.30s.\n(5) X'or pipelines under $$195.302 (bxl) and (bXzXi) that have not been pressure\ntested under subpart E ofthis part, 80 percent ofthe test pressure or highest\noperating pressure to which the pipeline was subjected for 4 or more continuous\nhours that can be demonstrated by recording charts or logs made at the time the\ntest or operations were conducted,\n(b) No operator may permit the pressure in a pipeline during surges or other\nvariations from normal operations to exceed 110 percent ofthe operating pressure\nlimit established under paragraph (a) of this section. Each operator must provide\nadequate controls and protective equipment to control the pressure within this\nlimit.\nTristate did not provide a record of MOP calculation for its pipeline.\nUnder 49 United States Code, g 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violations persists up to a maximum of $1,000,000\nfor any related series of violations._,We have reviewed the circumstances and supporting\ndocuments involved in this case, and.have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the items identified in\nthis letter. Failure to do so will result in Tristate NGL Pipeline L.L.C. being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2007-5002W. 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\n\n\n\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,\nLinda Daughty\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration\n\".,.","truncated":false,"body_characters":6994}