COLLINS PIPELINE CO — Warning Letter

220115001W_warning letter_01252011_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 25, 2011 Ms. Meredith D. West Joint Interest Director Collins Pipeline Company 800 Bell Street Houston, Texas 77002 CPF 2-2011-5001W Dear Ms. West: On November 8 to 10, 2010, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected your records, procedures, and pipeline facilities in Louisiana and Mississippi, pursuant to Chapter 601 of 49 United States Code. As a result of the inspection, it appears 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: §195.573 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: (1) Conduct tests on the protected pipeline at least once each calendar year, but with intervals not exceeding 15 months. However, if tests at those intervals are impractical for separately protected short sections of bare or ineffectively coated pipelines, testing may be done at least once every 3 calendar years, but with intervals not exceeding 39 months.#

220115001W_warning letter_01252011_text.pdf, page 2Collins did not conduct external corrosion control tests on its pipeline at certain test points in 2009 within 15 months of the external corrosion control test dates in 2008. That is, Collins' external corrosion control records for 2008 and 2009 showed that at 23 test points the time between the 2008 test readings and 2009 test readings exceeded 15 months from 5 to 11 days. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violation persists up to a maximum of $1,000,000 for any related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 2-2011-5001W. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerely, Wayne T. Lemoi Director, Office of Pipeline Safety PHMSA Southern Region 2#