{"operation":"document","citation":"CPF 220075003W","title":"VALERO TERMINALING AND DISTRIBUTION COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-04-18","effective_on":null,"summary":"CLOSED warning letter citing 195.402, 195.406, 195.49, 195.569, 195.573(a)(2), 195.575, 195.577(a), 195.589.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220075003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220075003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220075003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220075003W","body":"Warning Letter involving VALERO TERMINALING AND DISTRIBUTION COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.402,  195.406,  195.49,  195.569,  195.573(a)(2),  195.575,  195.577(a),  195.589. The case was opened on 2007-04-18 and is reported as closed as of 2007-04-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220075003W_warning letter_04182007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220075003W/220075003W_warning%20letter_04182007.pdf\n\n220075003w_warning letter_04182007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220075003W/220075003w_warning%20letter_04182007_text.pdf\n\n220075003w_warning letter_04182007_text.pdf\n\nU 5 Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n233 Peachtree Street Ste 600\nAtlanta GA 30303\nWARNING LETTER\nCERTIFIED MAIL — RETURN RECEIPT RE UESTED\nApnl 18, 2007\nMr Paul Brochu\nVice President\nValero Energy Corporation\nThe Premcor Pipeline Company\nOne Valero Way\nSan Antonio, TX 78249\nCPF 2-2007-5003Vtr\nDear Mr Brochu\nOn June 19 — 22, 2006, a representative of the Pipehne and Hazardous Matenals Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nPremcor Pipeline Company's Hazardous Liquid Pipehne facihties and reviewed records in\nMississippi, Tennessee and Arkansas\nAs a result of the inspection, it appears that you have commttted probable violations of the\nPipehne Safety Regulations Title 49, Code of Federal Regulations The items inspected and the\nprobable violations are\nf'1195. 49 Annual report.\nBeginntng no later than June 15, 2005, each operator must annually complete and\nsubmit DOT form RSPA F 7000-1 I for each type of hazardous hquid pipelme\nacdity operated at the end of the previous year. A separate report is required for\ncrude oil, HVL (including anhydrous ammonia), petroleum products, and carbon\ndioxide pipehnes. Operators are encouraged, but not required, to file an annual\nreport by June 15, 2004, for calendar year 2003.\n\n\n\nPremcor filed its annual report atter June 15, 2006\n2. (l195. 406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipelme at a pressure that exceeds any of the following\n(I) The internal design pressure of the pipe determined in accordance with\ntt195. 106. However, for steel pipe in pipehnes bemg converted under I)195. 5, if one\nor more factors of the design formula (tk195. 106) are unknown, one of the following\npressures is to be used as design pressure:\n(i) Eighty percent of the first test pressure that produces yield under section N5. 0\nof appendix N of ASME B31. S, reduced by the appropriate factors in 8195. 106(a)\nand (e); or\n(u) If the pipe is 12'/4 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 of the pipehne.\n(3) Eighty percent of the test pressure for any part of the pipehne which has been\npressure tested under Subpart E of this part\n(4) Eighty percent of the factory test pressure or of the prototype test pressure for\nany individually mstalled component which is excepted from testing under\nI)195. 305.\n(5) For pipehnes under @195. 302 (b)(1) and (b)(2)(i) that have not been pressure\ntested under subpart E of this part, 80 percent of the test pressure or highest\noperating pressure to which the pipehne was sublected for 4 or more contmuous\nhours that can be demonstrated by recordmg 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\nvariattons from normal operations to exceed 110 percent of the operating pressure\nhmit established under paragraph (a) of this section. Each operator must provide\nadequate controls and protective equipment to control the pressure within this\nlimit.\nPremcor did not provide a record venfymg the calculated MOP of its pipehne\nI')195. 577 What must I do to alleviate interference currents?\n(a) For pipehnes exposed to stray currents, you must have a program to identify,\ntest for, and mtnimixe the detrimental effects of such currents.\nPremcor did not provide a record venfyiug testmg for stray currents or analysis of\nnon-exposure to stray currents\n\n\n\n4. $195. 575 Which facihties must I electrically isolate and what inspechons, 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 pipehne 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.\nPremcor did not provide a record verifying inspection of its electncal isolations\n5. ('l195. 589 What corrosion control information do I have to maintain?\n(a) You must maintam current records or maps to show the location of—\n(1) Cathodically protected pipehnes;\n(2) Cathodic protection facihties, including galvamc anodes, installed after\nJanuary 29, 2002; and\n(3) Neighbormg structures bonded to cathodic protection systems.\n(b) Records or maps showing a stated number of anodes, installed in a stated\nmanner or spacing, need not show specific distances to each buried anode.\nPremcor did not provide an adequate record and or map showing location of the\nfollowing sacrificial anodes, ground beds, cntical and non-crit&cal bonds, rectifiers,\nelecu'ical isolations, test stations, AC interference components, hghtemng arrestors and\ngrounds\n(l195. 402 Procedural manual for operations, maintenance, and emergencies.\n(c) Mamtenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(13) Penodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and\ntaking corrective action where deficiencies are found.\n(d) Abnormal operation. The manual required by paragraph (a) of this section\nmust mclude procedures for the followmg to provide safety when operating design\nhmits have been exceeded:\n(5) Periodically reviewing the response of operator personnel to determine the\neffectiveness of the procedures controlling abnormal operation and taking\ncorrective action where deficiencies are found.\n\n\n\nPremcor did not provide a record verifying penodic review of personnel work normal\nand abnormal operations to determine effectiveness of procedures\nt'l 195. 569 Do I have to examme exposed portions of burred pipehnes?\nWhenever you have knowledge that any portion of a buried pipehne is exposed,\nyou must examme the exposed portion for evidence of external corrosion if the\npipe is bare, or if the coating is deteriorated. If you find external corrosion\nrequiring corrective action under )195 585, you must investigate circumferentially\nand longitudmally beyond the exposed portion (by visual examination, indirect\nmethod, or both) to determine whether additional corrosion requiring remedial\naction exists in the vicinity of the exposed portion.\nPremcor did not provide a record venfying inspection of exposed buried pipehnes\n8. t'l195 573 What must I do to monitor external corrosion control\"\n(a) Protected pipefmes. You must do the following to determine whether cathodic\nprotection required by this subpart comphes with $195. 571:\n(2) Identify before December 29, 2003 or not more than 2 years after cathodic\nprotection is installed, whichever comes later, the circumstances m which a close-\ninterval survey or comparable technology is practicable and necessary to\naccomphsh the oblectives of paragraph 10. 1 1. 3 of NACE Standard RP0169-96\n(incorporated by reference, see $195 3).\nPremcor did not provide a record of this evaluation Post inspection PHMSA received\nresponse from operator regarding tlus requirement This response did not provide\nverificatio that Premcor had identified circumstances in which a close-mterval survey\nor comparable technology would be practicable and necessary to accomplish the\nob)ectrves of paragraph 10 1 1 3 of NACE standard RP0169-96\nUnder 49 United States Code, $ 60122, you are sub) ect 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 senes of violatious 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 Be advised that failure to do so will result in Premcor Pipehue Company being\nsub)ect to additional enforcement action\n\n\n\nNo reply to this letter is required If you choose to reply, in your correspondence please refer to\nCPF 2-2007-5003W Be advised that all material you submit in response to this enforcement\naction is sublect to being made publicly available If you believe that any portion of your\nresponsive matenal quahfies 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 quahfies for confidential treatment under 5 U S C 552(b)\nSincerely,\nC6&oQ\nLinda Daugherty\nDirector, Southern Region\nPipehne and Hazardous Matenals Safety Administration","truncated":false,"body_characters":9653}