KEY WEST PIPELINE CO — Warning Letter

220076001W_Warning Letter_01112007.pdf, page 1Official PDF@ U.S. Depodmenl of Tronsporlolion Plpellne ond Hozordous ifdadqls Sqlety Admlnislrqtlon .r '1 ! f: f"-lJ 233 PeachFee Stre€t Ste. 600 Allanta, GA 30303 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).#

220076001W_Warning Letter_01112007.pdf, page 2Key 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#