{"operation":"document","citation":"CPF 220076001W","title":"KEY WEST PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-01-11","effective_on":null,"summary":"CLOSED warning letter citing 195.573(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220076001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220076001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220076001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220076001W","body":"Warning Letter involving KEY WEST PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.573(a)(2). The case was opened on 2007-01-11 and is reported as closed as of 2007-01-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220076001W_Warning Letter_01112007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220076001W/220076001W_Warning%20Letter_01112007.pdf\n\n220076001W_Warning Letter_01112007.pdf\n\n@\nU.S. Depodmenl\nof Tronsporlolion\nPlpellne ond\nHozordous ifdadqls Sqlety\nAdmlnislrqtlon\n.r '1 ! f: f\"-lJ\n233 PeachFee Stre€t Ste. 600\nAllanta, GA 30303\nWARNING LETTER\nCERTIX'IED MAIL January 11,2007\nMr. Mark S. Rauch\nPresident\nKey West Pipeline Company\nPipeline & Terminal Management Corp.\nP.O. Box 270415\nHouston, TX71277\n- RETURN RECEIPT REOUESTED\ncPF 2-2007-6001W\nDear Mr. Rauch:\nOn May 10, 2006, a representaLive of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nHazardous Liquid Pipeline facilities and reviewed records in Key West, Florida\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n$f 95.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with $195.571:\n(2) Identify before December 29r2003 or not more than 2 years after cathodic protection\nis installed, whichever comes later, the circumstances in which a close-interval survey or\ncomparable technology is practicable and necessary to accomplish the objectives of\nparagraph 10.f.1.3 ofNACE Standard RP0169-96 (incorporated by reference, see\n$1es.3).\n\n\n\nKey West Pipeline has failed to identifu the circumstances in which a close interval survey\nwould be needed to accomplish the objectives of paragraph 10.1.1.3 of NACE RPO169-96.\nThe objectives ofparagraph 10.1.1.3 are as follows:\n. Assess the effectiveness ofthe cathodic protection system\nr Provide base line operating data\nr Locate areas of inadequate protection levels\nr Identify locations likely to be adversely affected by construction, stray currents, or other\nunusual environmental conditions\nr Select areas to be monitored periodically.\nA copy of a fax from Giobal Cathodic Protection (GCP) was submitted to PHMSA in response\nto questions on how Key West Pipeline had addressed the requirements of 195.573(a)(2). This\nfax indicates that GCP does not think a close interval survey is necessary and that since the\npipeline is in the water the survey would be in their opinion inaccurate. This fax does not\naddress any ofthe objectives ofRPO169 paragraph 10.1.1.3.\nThough much of the pipeline is underwater, a good portion of the pipeline is on land and in\nareas where a close interval survey would be practical to perform. Much of the underwater\nportion of the pipeline is in very shallow water, in areas where it appears that conducting a\nclose interval survey would be feasible.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty notto exceed\n$ 1 00,000 for each violation for each day the violations persists up to a maximum of $l,000,000\nfor any related series of violations. We have reviewed the circumstances and supportlng\ndocuments involved in this case, and have decided not to conduct additional enforoement action\nor penalty assessment proceedings at this time. We advise you to correct the item identified in\nthis letter. Be advised that failure to do so will result in Key West Pipeline Company being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\ncPF 2-2007-6001w.\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":3992}