{"operation":"document","citation":"CPF 220085009W","title":"GENESIS PIPELINE USA, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-12-31","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220085009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220085009W","body":"Warning Letter involving GENESIS PIPELINE USA, L.P.. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2008-12-31 and is reported as closed as of 2008-12-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220085009W_warning letter_12312008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085009W/220085009W_warning%20letter_12312008.pdf\n\n220085009w_warning letter_12312008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220085009W/220085009w_warning%20letter_12312008_text.pdf\n\n220085009w_warning letter_12312008_text.pdf\n\nU. S. Department\nof Transportation\nPtipelllne and\nHaxairdous Maferiialls Safety\nAdmiiniisfiraftin\n233 Peachtree Street Ste 600\nAtlanta, GA 30303\nWA~lXG I KTYKR\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nDecember 31, 2008\nPatrick Hodgins\nDirector Health, Safety, Security and Environment\nGenesis Pipeline USA, L. P.\n17411 Village Green Drive\nHouston, Texas 77040\nCPF 2-2008-5009W\nDear Mr. Hodgins:\nOn June 23 through June 27, 2008, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour records and pipeline facilities in Jay, Florida.\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:\nl. $195. 402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactiviities and handling abnormal operations and emergencies. This manual shaH\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to itnsure that the manual is\neffective. This manual shaH be prepared befo~e initial operations of a pipehne\ncommence, and appropriate parts shaH be kept at locations where operations and\nmaintenance activities are conducted.\nGenesis states in the Liquid A CO2 Operations, Maintenance and Emergency Procedures\nManual, Section 2. 26 titled Training, employees will be tested on normal operations and\nmaintenance, recognizing and reactmg appropriately to Abnormal Operating Condition (AOC)\n\n\n\nand recognizing and reacting appropriately to emergencies. During the inspection, Genesis\nfailed to provide documentation confirming calendar year 2007 personnel testing\nGenesis produced a sign-in sheet and personnel tests for calendar-year (CY) 2006; CY 2007\nsign-in sheet was on record, however the tests were not. On July 24, 2008, Southern Region\nreceived copies of CY 2008 sign-in sheet and tests.\n$195. 402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nGenesis states in the Liquid k CO2 Operations, Maintenance and Emergency Procedures\nManual, Section 2, 11 titled Breakout Tank Inspection in two (2) separate headings, breakout\ntank inspections will be performed annually and monthly. Genesis provided annual tank\ninspection records for calendar-years 2006 and 2007 and monthly tank inspection beginning\nJanuary 2008 through June, 2008. No monthly tank inspections had been performed and\ndocumented prior to January 2008, therefore no inspection records were available for review.\nAdditionally, Genesis should reference API 653 Section 4, which specifies the monthly\ninspection requirement, under the \"When to Inspect\" heading located in Section 2, 11 titled\nBreakout Tank Inspection. Presently, API 653 Section 4 is referenced under the heading\n\"Physical Integrity Inspection. \"\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 item(s) identified\nin this letter. Failure to do so will result in Genesis being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2008-5009W. 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\n\n\n\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).\nSincerely,\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":5664}