# TAMPA BAY PIPELINE CO. — Warning Letter

- **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:** Not available
- **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.

Official case documents:

220116010W_warning letter_11212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116010W/220116010W_warning%20letter_11212011.pdf

220116010W_warning letter_11212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220116010W/220116010W_warning%20letter_11212011_text.pdf

220116010W_warning letter_11212011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 21, 2011
Robert L. Rose
President
Tampa Bay Pipeline Company
Tampa Pipeline Corporation
Post Office Box 25236
Sarasota, Florida 34242
CPF 2-2011-6010W
Dear Mr. Rose:
On August 29 - September 2, and September 12, 2011, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code, inspected the Tampa Bay Pipeline Company (TBPL) procedures and records in
Tampa, Florida, and pipeline facilities in Hillsborough and Polk Counties, Florida.
As a result of the inspection, it appears that TBPL has committed probable violations of the
Pipeline Safety Regulations, Title 49 Code of Federal Regulations. The items inspected and
the probable violations are as follows:
1. §195.406 Maximum operating pressure.
.... (b) No operator may permit the pressure in a pipeline during surges or other
variations from normal operations to exceed 110 percent of the operating pressure
limit established under paragraph (a) of this section. Each operator must provide
adequate controls and protective equipment to control the pressure within this limit.
TBPL failed to provide adequate controls for the pipeline operating pressure to ensure that
the pressure would not exceed 110 percent of the Maximum Operating Pressure (MOP)
because its relief valves were set at 750 psig for pipelines with an MOP of 594 psig.
TBPL records show that adequate controls for the pipeline operating pressure were not in
place to ensure the pressure would not exceed 110 percent of the MOP at the Yara - Port
Sutton injection station and at the Kinder Morgan - Port Sutton injection station.
1. Yara - Port Sutton injection station
TBPL’s Semi-Annual Pump Station Inspection Report on 5/10/2011 showed the
“Required Set Point - found and left” values for the six relief valves to be
750 [psig.]



2. Kinder Morgan - Port Sutton injection station
TBPL’s Semi-Annual Pump Station Inspection Reports on 10/14/2010 and
4/14/2011 show “Required Set Point - found and left” values for the ten relief
valves to be 720 [psig.]
Notwithstanding the above, the PHMSA inspector did not find any evidence that the MOP
of these pipelines had been exceeded.
2. §195.420 Valve maintenance.
.... (c) Each operator shall provide protection for each valve from unauthorized
operation and from vandalism.
TBPL’s valve BV-25 was not protected from unauthorized operation and vandalism.
During the field inspection the PHMSA inspector observed that BV-25 was not locked or
otherwise secured to protect the valve from vandalism and prevent unauthorized
operation. The valve is located on the Mosaic-Bartow plant property. Subsequent to the
inspection TBPL reported to the PHMSA Southern Region that the valve was now secured
by a padlock.
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. We advise you to correct
the items identified in this letter. Failure to do so will result in Tampa Bay Pipeline Company
being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 2-2011-6010W. 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
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