# KEY WEST PIPELINE CO — Warning Letter

- **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:** Not available
- **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.

Official case documents:

220076001W_Warning Letter_01112007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220076001W/220076001W_Warning%20Letter_01112007.pdf

220076001W_Warning Letter_01112007.pdf

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WARNING LETTER
CERTIX'IED MAIL January 11,2007
Mr. Mark S. Rauch
President
Key West Pipeline Company
Pipeline & Terminal Management Corp.
P.O. Box 270415
Houston, TX71277
- RETURN RECEIPT REOUESTED
cPF 2-2007-6001W
Dear Mr. Rauch:
On May 10, 2006, a representaLive of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Hazardous Liquid Pipeline facilities and reviewed records in Key West, Florida
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
$f 95.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine whether cathodic
protection required by this subpart complies with $195.571:
(2) Identify before December 29r2003 or not more than 2 years after cathodic protection
is installed, whichever comes later, the circumstances in which a close-interval survey or
comparable technology is practicable and necessary to accomplish the objectives of
paragraph 10.f.1.3 ofNACE Standard RP0169-96 (incorporated by reference, see
$1es.3).



Key West Pipeline has failed to identifu the circumstances in which a close interval survey
would be needed to accomplish the objectives of paragraph 10.1.1.3 of NACE RPO169-96.
The objectives ofparagraph 10.1.1.3 are as follows:
. Assess the effectiveness ofthe cathodic protection system
r Provide base line operating data
r Locate areas of inadequate protection levels
r Identify locations likely to be adversely affected by construction, stray currents, or other
unusual environmental conditions
r Select areas to be monitored periodically.
A copy of a fax from Giobal Cathodic Protection (GCP) was submitted to PHMSA in response
to questions on how Key West Pipeline had addressed the requirements of 195.573(a)(2). This
fax indicates that GCP does not think a close interval survey is necessary and that since the
pipeline is in the water the survey would be in their opinion inaccurate. This fax does not
address any ofthe objectives ofRPO169 paragraph 10.1.1.3.
Though much of the pipeline is underwater, a good portion of the pipeline is on land and in
areas where a close interval survey would be practical to perform. Much of the underwater
portion of the pipeline is in very shallow water, in areas where it appears that conducting a
close interval survey would be feasible.
Under 49 United States Code, $ 60122, you are subject to a civil penalty notto exceed
$ 1 00,000 for each violation for each day the violations persists up to a maximum of $l,000,000
for any related series of violations. We have reviewed the circumstances and supportlng
documents involved in this case, and have decided not to conduct additional enforoement action
or penalty assessment proceedings at this time. We advise you to correct the item identified in
this letter. Be advised that failure to do so will result in Key West Pipeline Company being
subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
cPF 2-2007-6001w.
Linda Daugherty
Director, Southern Region
Pipeline and Hazardous Materials Safety Administration
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