{"operation":"document","citation":"CPF 220076003W","title":"TPM, INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-02-22","effective_on":null,"summary":"CLOSED warning letter citing 195.406, 195.573(a)(2), 195.575(a), 195.577.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220076003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220076003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220076003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220076003W","body":"Warning Letter involving TPM, INC. PHMSA's enforcement data identifies the cited regulations as 195.406,  195.573(a)(2),  195.575(a),  195.577. The case was opened on 2007-02-22 and is reported as closed as of 2007-02-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220076003W_operator response to notice_03302007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220076003W/220076003W_operator%20response%20to%20notice_03302007.pdf\n\n220076003W_Warning Letter_02222007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220076003W/220076003W_Warning%20Letter_02222007.pdf\n\n220076003W_Warning Letter_02222007.pdf\n\n@\nU.S. Deportment\nof Trqnsportolion\nPlpeline ond\nHdzordous frlqlerisls Sotely\nAdmlnistrotlon\n233 Peachtree Stred Ste. 600\nAtlanta. GA 30303\nWARNING LETTER\nCERTIFIED MAIL - RETIIRN RECEIPT REQUESTED\nFebruary 22,2007\nMr. Lany Clynch\nCompany Executive Offi cer\nTPM.Inc.\nP.O. Box 486\nAlpharetta, GA 30009\ncPF 2-2007-6003W\nDear Mr. Clynch:\nOn June 5 - 7,2006, a representative 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 Memphis, Tennessee.\nAs a result of the inspection, it appears 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. $195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do fhe following to determine whether cathodic\nprotection required by this subpart complies with $195.571:\n(2) Identify before December 2912003 or not more than 2 years after cathodic\nprotection is installed, whichever comes later, the circumstances in which a close-\ninteryal survey or comparable technology is practicable and necessary to accomplish\nthe otrjectives of paragraph 10.1.1.3 of NACE Standard RP0169-96 (incorporated by\nreference, see $195.3).\n\n\n\n)\nJ .\n4.\nTPM personnel did not provide a record of this evaluation. Operator personnel asserted\nthey had plans to address this code requirement.\n$195.575 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 the\npipeline and the other structures as a single unit.\nTPM personnel did not provide a record verifying inspection of its electrical isolations.\nIn addition, operator personnel asserted the Dupont station isolation is not working and they\nhave plans to frx it.\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 identiff' test\nfor, and minimize the detrimental effects of such currents.\n(b) You must design and install each impressed current or galvanic anode system to\nminimize any adverse effects on existing adjacent metallic structures.\nTPM personnel did not provide a record which verified testing for interference curents or\nno need for due to analysis of non-exposure to stray currents.\n$195.406 Maximum operating pressure.\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(1) The internal design pressure of the pipe determined in accordance with $195.106.\nHowever, for steel pipe in pipelines being converted under $195.5' if one or more\nfactors of the design formula (Sf 95.106) are unknown, one of the following pressures\nis to be used as design pressure:\n(i) Eighty percent ofthe first test pressure that produces yield under section N5.0 of\nappendix N of ASME 831.8, rdduced by the appropriate factors in $$195.106(a) and\n(e); or\n(ii) If the pipe is 121/nin (324 mm) or less outside diameter and is not tested to yield\nunder this paragraph,200 p.s.i. (1379 kPa) gage.\n(2) The design pressure of any other component of the pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under Subpart E ofthis part.\n(a) Eighty percent of the factory test pressure or of the protofype test pressure for any\nindividually installed component which is excepted from testing under $195.305.\n(5) X'or pipelines under $$195.302 (bX1) and (b)(z)(i) that have not been pressure\ntested under subpart E ofthis part,80 percent ofthe test pressure or highest\n\n\n\n'.\noperating pressure to which the pipeline was subjected for 4 or more continuous hours\nthat can be demonstrated by recording charts or logs made at the time the test or\noperations 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 of the 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 limit.\nTPM personnel did not provide a record of MOP calculation for its pipeline.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\nfor any related series of violations. We have reviewed the circumstances and supporting\n$100,000 for each violation for each day the violations persists up to a maximum of $1,000,000\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 TPM being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2007-6003 W.\nSincerely,\nSanada Daughuty\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":5990}