{"operation":"document","citation":"CPF 220116010W","title":"TAMPA BAY PIPELINE CO. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-11-21","effective_on":null,"summary":"CLOSED warning letter citing 195.406(b), 195.420(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220116010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220116010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220116010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220116010W","body":"Warning Letter involving TAMPA BAY PIPELINE CO.. PHMSA's enforcement data identifies the cited regulations as 195.406(b),  195.420(c). The case was opened on 2011-11-21 and is reported as closed as of 2011-11-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220116010W_warning letter_11212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116010W/220116010W_warning%20letter_11212011.pdf\n\n220116010W_warning letter_11212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116010W/220116010W_warning%20letter_11212011_text.pdf\n\n220116010W_warning letter_11212011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 21, 2011\nRobert L. Rose\nPresident\nTampa Bay Pipeline Company\nTampa Pipeline Corporation\nPost Office Box 25236\nSarasota, Florida 34242\nCPF 2-2011-6010W\nDear Mr. Rose:\nOn August 29 - September 2, and September 12, 2011, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, inspected the Tampa Bay Pipeline Company (TBPL) procedures and records in\nTampa, Florida, and pipeline facilities in Hillsborough and Polk Counties, Florida.\nAs a result of the inspection, it appears that TBPL has committed probable violations of the\nPipeline Safety Regulations, Title 49 Code of Federal Regulations. The items inspected and\nthe probable violations are as follows:\n1. §195.406 Maximum operating pressure.\n.... (b) No operator may permit the pressure in a pipeline during surges or other\nvariations from normal operations to exceed 110 percent of the operating pressure\nlimit established under paragraph (a) of this section. Each operator must provide\nadequate controls and protective equipment to control the pressure within this limit.\nTBPL failed to provide adequate controls for the pipeline operating pressure to ensure that\nthe pressure would not exceed 110 percent of the Maximum Operating Pressure (MOP)\nbecause its relief valves were set at 750 psig for pipelines with an MOP of 594 psig.\nTBPL records show that adequate controls for the pipeline operating pressure were not in\nplace to ensure the pressure would not exceed 110 percent of the MOP at the Yara - Port\nSutton injection station and at the Kinder Morgan - Port Sutton injection station.\n1. Yara - Port Sutton injection station\nTBPL’s Semi-Annual Pump Station Inspection Report on 5/10/2011 showed the\n“Required Set Point - found and left” values for the six relief valves to be\n750 [psig.]\n\n\n\n2. Kinder Morgan - Port Sutton injection station\nTBPL’s Semi-Annual Pump Station Inspection Reports on 10/14/2010 and\n4/14/2011 show “Required Set Point - found and left” values for the ten relief\nvalves to be 720 [psig.]\nNotwithstanding the above, the PHMSA inspector did not find any evidence that the MOP\nof these pipelines had been exceeded.\n2. §195.420 Valve maintenance.\n.... (c) Each operator shall provide protection for each valve from unauthorized\noperation and from vandalism.\nTBPL’s valve BV-25 was not protected from unauthorized operation and vandalism.\nDuring the field inspection the PHMSA inspector observed that BV-25 was not locked or\notherwise secured to protect the valve from vandalism and prevent unauthorized\noperation. The valve is located on the Mosaic-Bartow plant property. Subsequent to the\ninspection TBPL reported to the PHMSA Southern Region that the valve was now secured\nby a padlock.\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 Tampa Bay Pipeline Company\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2011-6010W. 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\n2","truncated":false,"body_characters":4803}