{"operation":"document","citation":"CPF 220101003W","title":"DESTIN PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-02-09","effective_on":null,"summary":"CLOSED warning letter citing 192.459, 192.479, 192.731(c), 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220101003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220101003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220101003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220101003W","body":"Warning Letter involving DESTIN PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.459,  192.479,  192.731(c),  192.739(a). The case was opened on 2010-02-09 and is reported as closed as of 2010-02-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220101003W_operator response_04082010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220101003W/220101003W_operator%20response_04082010.pdf\n\n220101003W_warning letter_02092010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220101003W/220101003W_warning%20letter_02092010.pdf\n\n220101003W_warning letter_02092010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220101003W/220101003W_warning%20letter_02092010_text.pdf\n\n220101003W_warning letter_02092010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 9, 2010\nMr. Steve Pankhurst\nBusiness Unit Leader\nDestin Pipeline Company, LLC\nBP US Pipeline & Logistics\n28100 Torch Parkway\nWarrenville, Illinois 60555\nCPF 2-2010-1003W\nDear Mr. Pankhurst:\nOn July 13 – 17, 2009, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nrecords and procedures in Moss Point, Mississippi and pipeline facilities of Destin Pipeline\nCompany, LLC in Mississippi and the Gulf of Mexico.\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 violation(s) are:\n1. §192.491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to\n§§192.465(a) and (e) and 192.475(b) must be retained for as long as the pipeline\nremains in service.\n§192.459 External corrosion control: Examination of buried pipeline when\nexposed.\nWhenever an operator has knowledge that any portion of a buried pipeline is\nexposed, the exposed portion must be examined for evidence of external corrosion\nif the pipe is bare, or if the coating is deteriorated. If external corrosion requiring\n\n\n\nremedial action under §§192.483 through 192.489 is found, the operator shall\ninvestigate circumferentially and longitudinally beyond the exposed portion (by\nvisual examination, indirect method, or both) to determine whether additional\ncorrosion requiring remedial action exists in the vicinity of the exposed portion.\nDestin Pipeline did not properly document the examination of its pipeline when\nexposed.\nDestin Pipeline Repair and Inspection Report Report Numbers DSN-08-I-0001 and\nDSN-08-I-0002 are not filled in to document the examination of the condition of the\ncoating in field A14.e Coating Condition on the reports.\n2. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts L and\nM of this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\n§192.731 Compressor stations: Inspection and testing of relief devices.\n(c) Each remote control shutdown device must be inspected and tested at intervals\nnot exceeding 15 months, but at least once each calendar year, to determine that it\nfunctions properly.\nDestin Pipeline did not have a record documenting the 2005 Pascagoula Compressor\nStation test of the high discharge pressure shutdown and calibration of the compressor\nstation discharge side pressure transmitter.\nDestin Pipeline was unable to provide a copy of the Work Order documenting the\ncalibration of the Pascagoula Compressor Station discharge side pressure transmitter\nand the test of the PLC set points for the Hi Pressure Point and Hi Hi Pressure Point.\n3. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission lines for the\nperiods specified:\n(c) A record of each patrol, survey, inspection, and test required by subparts L and\nM of this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\n§192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\npressure regulating station and its equipment must be subjected at intervals not\nexceeding 15 months, but at least once each calendar year, to inspections and tests\nto determine that it is–\n2\n\n\n\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nDestin Pipeline could not provide copies of the inspection records for the inspections of\npressure regulating control valve PV-1400 at the Pascagoula Compressor Station.\nDestin Pipeline did not have inspection records for pressure regulating control valve\nPV-1400 which is identified on the Pascagoula Compressor station Fuel Gas Heater /\nFilter Separator Mechanical Flowsheet drawing DES-C1-A-104.\n4. §192.479 Atmospheric corrosion control; General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,\nthe operator need not protect from atmospheric corrosion any pipeline for which\nthe operator demonstrates by test, investigation, or experience appropriate to the\nenvironment of the pipeline that corrosion will--\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled\ninspection.\nThe recycle line to the Unit #1 Suction Line at the Sand Hill Compressor Station is not\ncoated at the soil-to-air interface.\nThe coating of the soil-to-air interface on the bypass line at the Pascagoula Compressor\nStation had deteriorated and surface rust was observed on the pipe.\nDuring the field portion of the inspection at the Sand Hill Compressor Station, light\nsurface rust was observed on the recycle line of the Unit #1 Suction Line at the soil-to-\nair interface. Upon further examination it was noted that the pipe was not coated.\nDuring the field portion of the inspection at the Pascagoula Compressor Station, light\nsurface rust was observed on the bypass line at the soil-to-air interface. Upon further\nexamination it was noted that the coating on the pipe had deteriorated.\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\n3\n\n\n\nin this letter. Failure to do so will result in Destin Pipeline Company, LLC being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2010-1003W. 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).\nSincerely,\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":8547}