{"operation":"document","citation":"CPF 220085001W","title":"PLAINS PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-02-07","effective_on":null,"summary":"CLOSED warning letter citing 195.402(c)(13), 195.404(a)(2), 195.432, 195.573(a)(2), 195.583.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220085001W","body":"Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(13),  195.404(a)(2),  195.432,  195.573(a)(2),  195.583. The case was opened on 2008-02-07 and is reported as closed as of 2008-02-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220085001W_warning letter_02072008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085001W/220085001W_warning%20letter_02072008.pdf\n\n220085001w_warning letter_02072008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085001W/220085001w_warning%20letter_02072008_text.pdf\n\n220085001w_warning letter_02072008_text.pdf\n\nU. S. 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\nFebruary 7, 2008\nMr. Troy E. Valenzula\nVice President\nEnvironmental Health rfc Safety\nPlains Pipeline, L. P.\n333 Clay Street Suite 1600\nHouston, TX 77210\nCPF 2-2008-5001W\nDear Mr. Valenzula:\nOn July 17 - 21, 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 Mississippi and Alabama.\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\nthe probable violations are:\ntj195. 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 tj195. 571:\n(2) Identify before December 29, 2003 or not more than 2 years after cathodic\nprotection is installed, whichever comes later, the circumstances in which a close-\ninterval survey or comparable technology is practicable and necessary to\naccomplish the objectives of paragraph 10. 1. 1. 3 of NACE Standard RP0169-96\n(incorporated by reference, see tj195. 3).\n\n\n\n3. Plains did not provide a record of this evaluation. Post inspection PHMSA received a\nresponse from operator regarding this code. This response did not provide verification\nthat Plains had identified circumstances in which a close-interval survey or comparable\ntechnology would be practicable and necessary to accomplish the objectives of\nparagraph 10. 1. 1. 3 of NACE standard RP0169-96.\n(1195. 432 Inspection of in-service breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service atmospheric and\nlow pressure steel aboveground breakout tanks according to section 4 of API\nStandard 653. However, if structural conditions prevent access to the tank\nbottom, the bottom integrity may be assessed according to a plan included in the\noperations and maintenance manual under (1195. 402(c)(3).\n(d) The intervals of inspection specified by documents referenced in paragraphs\n(b) and (c) of this section begin on May 3, 1999, or on the operator's last recorded\ndate of the inspection, whichever is earlier.\nPlains did not provide API 653 evaluation reports for 14 breakout tanks during the\ninspection. In addition, API 653 report provided for tank 1193 at Lumberton\nstation was dated August 1999 and outside of the required 5 year time period.\nI'1195. 404 Maps and records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information:\n(2) All crossings of public roads, railroads, rivers, buried utilities, and foreign\npipelines.\nPlains did not provide a recent survey map or record for its pipeline showing public\nroads, railroads, rivers, buried utilities and foreign pipelines. The map provided was\nover 30 years old with no updates and only covered a portion of the pipeline.\n(1195. 583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports,\nin splash zones, at deck penetrations, and in spans over water.\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by (1195. 581.\n11195. 581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to\nthe atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n\n\n\nRecords provided during the inspection were insufficient to address issues found in\nthe field — rusting, need for cleaning and coating of mainline valves and aboveground\nstation piping.\n(j195. 402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance 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) Periodically 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 include procedures for the following to provide safety when operating design\nlimits 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.\nPlains did not provide a record verifying periodic review of personnel work normal\nand abnormal operations to determine effectiveness of procedures.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations. 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. Failure to do so will result in Plains Pipeline, L. P. 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 2-2008-5001W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies 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 qualifies for confidential treatment under 5 U. S. C. 552(b).\nSmcarely,\nMohammed Shoaib\nActing Director, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7382}