{"operation":"document","citation":"CPF 220115005W","title":"ENTERPRISE PRODUCTS OPERATING LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-03-18","effective_on":null,"summary":"CLOSED warning letter citing 195.404(a)(2), 195.404(a)(3), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220115005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220115005W","body":"Warning Letter involving ENTERPRISE PRODUCTS OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.404(a)(2),  195.404(a)(3),  195.589(c). The case was opened on 2011-03-18 and is reported as closed as of 2011-03-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220115005W_warning letter_03182011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115005W/220115005W_warning%20letter_03182011.pdf\n\n220115005W_warning letter_03182011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115005W/220115005W_warning%20letter_03182011_text.pdf\n\n220115005W_warning letter_03182011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 18, 2011\nMr. Kevin Bodenhamer\nSenior Vice President of Liquid Pipeline Operation\nEnterprise Products Operating, LLC\n1100 Louisiana Street\nHouston, Texas 77002\nCPF 2-2011-5005W\nDear Mr. Bodenhamer:\nBetween February 28 and March 3, 2011, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected Enterprise Products Operating, LLC\n(Enterprise) records in Chunchula, Alabama, and your pipeline facilities located in Alabama\nand Mississippi, pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that Enterprise has committed probable violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violations are:\n1. §195.404 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.\nEnterprise did not have current maps or records of its Chunchula Pipeline System to\nshow all the foreign pipeline crossings.\nEnterprise’s records did not show the Destin Pipeline crossing at Mile Post 38 in\nGreene County, Mississippi, or the Tennessee Gas Pipeline crossings at Mile Post 6 in\nPetal, Mississippi. During the PHMSA inspection, Enterprise personnel submitted\nEncroachment/Foreign Line Crossing reports to Enterprise’s Asset Integrity\n\n\n\nCoordinator to update the maps and records for the Destin Pipeline and Tennessee Gas\nPipeline crossings.\n2. §195.404 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.... (3) The maximum operating pressure of each pipeline.\nEnterprise did not have the correct records for the maximum operating pressure\n(MOP) of the suction side piping in the Chunchula Pump Station.\nEnterprise’s records indicated that the MOP of the Chunchula Pipeline System, to\ninclude the Chunchula Pump Station, was 1,440 psig. Enterprise’s hydrostatic\npressure test records for the pump station, and the ANSI 300 components, do not\nsupport a 1,440 psig MOP per §195.406(a) between the station upstream isolation\nvalves and the pumps.\nDuring the PHMSA inspection, Enterprise personnel submitted an MOP Data Change\nRequest to Enterprise’s Asset Integrity Department to review and reestablish the\nstation MOP at 720 psig between the upstream isolation valves and suction side of the\npumps. Notwithstanding the incorrect records, the pump station piping on the suction\nside of the pumps has been protected by the high discharge pressure shutdown switch\nat the upstream Hatters Pond Pump Station, which was set at 600 psig\n3. §195.589 What corrosion control information do I have to maintain?\n.... (c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to §§195.569,\n195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the\npipeline remains in service.\nEnterprise did not have records for the inspection of the internal surface of the pipe for\nevidence of corrosion when certain pipe sections were removed from Enterprise’s\nChunchula Pipeline System.\nEnterprise’s Maintenance Reports for repairs done on the pipeline on December 22,\n2010, did not show that the internal pipe surface of the removed pipe was inspected\nfor evidence of corrosion per §195.579(c). During the PHMSA inspection, Enterprise\npersonnel inspected the internal surface of the removed pipe for evidence of corrosion\nand corrected the Maintenance Reports. The removed pipe was inspected at\nEnterprise’s Petal Storage facility where the pipe was stored. It had no signs of\ncorrosion. The repair work during which the pipe was removed was:\n− Dig #1, ASSMT 409 at Mile Post 11.95 in Escambia County, Alabama\n− Dig #2, ASSMT 406 at Mile Post 2.45 in Mobile County, Alabama\n2\n\n\n\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\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Enterprise being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2011-5005W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n3","truncated":false,"body_characters":6281}