{"operation":"document","citation":"CPF 220125003W","title":"DIXIE PIPELINE COMPANY LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-05-08","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3), 195.428(a), 195.452(f)(3), 195.452(h)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220125003W","body":"Warning Letter involving DIXIE PIPELINE COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(3),  195.428(a),  195.452(f)(3),  195.452(h)(2). The case was opened on 2012-05-08 and is reported as closed as of 2012-05-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220125003W_Warning Letter_05082012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125003W/220125003W_Warning%20Letter_05082012.pdf\n\n220125003W_Warning Letter_05082012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125003W/220125003W_Warning%20Letter_05082012_text.pdf\n\n220125003W_Warning Letter_05082012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 8, 2012\nMr. Kevin Bodenhamer\nSenior Vice President of Liquid Pipeline Operations\nDixie Pipeline Company, LLC\n1100 Louisiana Street\nHouston, Texas 77002\nCPF 2-2012-5003W\nDear Mr. Bodenhamer:\nFrom March 21 - 24, April 11- 15, May 2 - 6, May 9 - 12, May 23 - 27, June 13 - 16,\nJune 27- July 1, July 18 - 21, August 8 - 11, September 5 - 8, and October 6, 2011,\nrepresentatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\ninspected the Dixie Pipeline Company (Dixie) written procedures, integrity management\nprogram records, operations & maintenance (O&M) records, and facilities in Alabama,\nGeorgia, Louisiana, Mississippi, North Carolina, South Carolina, and Texas pursuant to\nChapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that (Dixie) has committed probable violations of the\nPipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½\nmonths, but at least twice each calendar year, inspect and test each pressure limiting\ndevice, relief valve, pressure regulator, or other item of pressure control equipment\nto determine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nDixie did not inspect the Trenton Station overpressure safety devices at intervals not to\nexceed 7½ months. Dixie inspected the overpressure safety devices at Trenton Station on\nSeptember 3, 2010, and then on April 21, 2011, exceeding 7½ months by three days.\n\n\n\n2. §195.452 Pipeline integrity management in high consequence areas.\n... (h) What actions must an operator take to address integrity issues?\n... (2) Discovery of condition. Discovery of a condition occurs when an operator has\nadequate information about the condition to determine that the condition presents a\npotential threat to the integrity of the pipeline. An operator must promptly, but no\nlater than 180 days after an integrity assessment, obtain sufficient information about\na condition to make that determination, unless the operator can demonstrate that the\n180-day period is impracticable.\nDixie did not obtain sufficient information to make a determination of discovery within\n180 days after completing the 2010 Opelika to Albany integrity assessment.\nDixie completed the Opelika to Albany inline inspection (ILI) integrity assessment on\nFebruary 10, 2010, but did not obtain sufficient information to establish the “discovery\ndate” until August 30, 2010. Dixie requested the ILI vendor to review and revise its data\nfor the ILI run on June 22, 2010, and then worked with the vendor until it obtained a\nrevised final report on August 24, 2010. Dixie exceeded the required date by 21 days.\n3. §195.452 Pipeline integrity management in high consequence areas.\n... (f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n... (3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nDixie did not properly perform the 2011 risk analysis (completed on March 23, 2011) for\nthe Milner to Norwood section of the Dixie pipeline. Dixie did not include in the risk\nanalysis a Direct Affect High Population Area (HPA) High Consequence Area (HCA)\nfrom mile post 773.97 to 776.0 that it had established on March 11, 2011. When this was\nidentified during the PHMSA inspection, Dixie personnel performed the risk analysis\nagain and included the HCA. Dixie had previously assessed the HCA during its baseline\nassessment.\n4. §195.404 Maps and records.\n... (c) Each operator shall maintain the following records for the periods specified:\n... (3) A record of each inspection and test required by this subpart shall be\nmaintained for at least 2 years or until the next inspection or test is performed,\nwhichever is longer.\n2\n\n\n\nDixie did not properly maintain the records for the overpressure protection and safety\ndevice inspections and tests for its Stegall Injection Station, Baker Station, and Mount\nHermon Station.\nDixie did not properly maintain records for the inspections and tests of the overpressure\nprotection and safety devices for three of its stations as noted below:\n− Stegall Injection: Dixie placed Stegall Injection in service in 2009 but did not\ndocument the inspection of overpressure protection and safety devices until\nApril 2010. Dixie personnel stated that they had reviewed the construction and\npre-commissioning tests but could not locate the records for the inspections and tests\nof the overpressure protection and safety devices in the construction job books or in\nDixie’s records.\n− Baker Station: Dixie’s September 23, 2008, overpressure protection inspection record\nfor the Baker Station “Station High Discharge Switch” had a set-point of 1320 psi\nrecorded on the form. The set-point was more than 10% above the reduced Maximum\nOperating Pressure (MOP) in effect at that time from Corrective Action Order (CAO)\n2-2007-5100H. That said, Dixie’s records for the prior inspections on\nMarch 31, 2008, and on March 30, 2009, had handwritten notes with the correct\nset-points shown. Moreover, the PHMSA inspector reviewed Dixie’s pressure\ndischarge records for September 23, 2008, to March 30, 2009, and found that Dixie\nhad operated the pipeline within the reduced MOP.\n− Mount Hermon Station: Dixie’s April 2, 2008, overpressure protection inspection\nrecord for the Mount Hermon “Station High Discharge Switch” has a set-point of 1320\npsi recorded on the form. That said, Dixie’s records for the subsequent\nSeptember 22, 2008, inspection had a handwritten note with the correct set-point\nshown. Moreover, the PHMSA inspector reviewed Dixie’s pressure discharge records\nfor April 2, 2008, to September 22, 2008, and found that Dixie had operated the\npipeline within the reduced MOP.\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 Dixie Pipeline Company being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-5003W. 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\n3\n\n\n\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\n4","truncated":false,"body_characters":8775}