{"operation":"document","citation":"CPF 220126004W","title":"CENTRAL FLORIDA PIPELINE CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-02-09","effective_on":null,"summary":"CLOSED warning letter citing 195.404(a)(1), 195.404(a)(2), 195.567(c), 195.573(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220126004W","body":"Warning Letter involving CENTRAL FLORIDA PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 195.404(a)(1),  195.404(a)(2),  195.567(c),  195.573(e). The case was opened on 2012-02-09 and is reported as closed as of 2012-02-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220126004W_Operator response_05102012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126004W/220126004W_Operator%20response_05102012.pdf\n\n220126004W_warning letter_02092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126004W/220126004W_warning%20letter_02092012.pdf\n\n220126004W_warning letter_02092012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126004W/220126004W_warning%20letter_02092012_text.pdf\n\n220126004W_warning letter_02092012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 9, 2012\nMr. Ron McClain\nVice President\nCentral Florida Pipeline Corporation\nKinder Morgan Energy Partners, L.P.\n500 Dallas Street, Suite 1000\nHouston, TX 77002\nCPF 2-2012-6004W\nDear Mr. McClain:\nOn November 14-18, 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Central Florida Pipeline Corporation (CFPL) refined\npetroleum products pipeline system from Tampa to Orlando, Florida, pursuant to Chapter 601\nof 49 United States Code. CFPL is a subsidiary of Kinder Morgan Energy Partners, L.P.\nAs a result of the inspection, it appears that CFPL has committed probable violations of the\nPipeline Safety Regulations codified in Title 49 of the Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §195.573 What must I do to monitor external corrosion control?\n… (e) Corrective Action. You must correct any identified deficiency in corrosion\ncontrol as required by §195.401(b). However, if the deficiency involves a pipeline in\nan integrity management program under §195.452, you must correct the deficiency\nas required by §195.452(h).\nCFPL did not correct several identified corrosion control deficiencies as required by\n§195.401(b).\nA review of CFPL’s 2009 and 2010 annual cathodic protection (CP) survey pipe-to-soil\n(p/s) readings revealed several locations along the 16-inch pipeline with CP deficiencies\n(i.e. less negative than – 850 mV) as listed below:\n– Mile Post 56.598: -709mV in December 2009 and -825mV in December 2010\n– Mile Post 97.514: -800mV in December 2009 and -799mV in December 2010\n– Mile Post 97.598: -822mV in December 2009 and -771mV in December 2010\n\n\n\nDuring the PHMSA field inspection of the above locations in November 2011, the p/s\nreadings were confirmed as less negative than required by the CP criteria used by CFPL.\nAdditionally, all of the p/s readings for the ASI Line (a 2.5 mile lateral off of the 10-inch\nmain line) were less negative than the -850mV criteria, per the annual survey CFPL\nconducted in December 2010. The readings ranged between -422mV and -818mV.\nDuring the PHMSA field inspection, a p/s reading of -805mV was taken on the ASI Line\nat the Arabian Night Road test station. It should be noted that CFPL had not completed its\n2011 annual CP survey at the time of the inspection.\n2. §195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n… (c) Maintenance. You must maintain the test lead wires in a condition that enables\nyou to obtain electrical measurements to determine whether cathodic protection\ncomplies with §195.571.\nCFPL did not maintain all CP test leads in a condition that enabled it to obtain electrical\nmeasurements to determine whether cathodic protection complies with §195.571.\nThe December 2009 and December 2010 annual CP surveys at mile post (MP) 3.941\nalong the 16-inch line showed p/s readings of -59mV and -68mV, respectively. These low\np/s readings were indicative of inadequate test lead contact with either the electrolyte or\nthe buried pipe.\n3. §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, rivers, buried utilities, and foreign pipelines.\nCFPL did not maintain current maps and records of its pipeline system that included all\nforeign pipeline crossings.\nPHMSA’s review of the operator’s alignment sheets revealed that the location of the\nFlorida Gas Transmission crossings of CFPL’s 10-inch line in the immediate vicinity of\nI-75, as well as further east along the line near Plant City, were not depicted or referenced.\nFurthermore, the TRANSCO crossing of CFPL’s 16-inch line near State Route 17 was not\ndepicted or referenced in the operator’s alignment sheets.\n4. §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(1) Location and identification of the following pipeline facilities;\n… (iv) Pipeline valves\nCFPL did not maintain current maps and records of its pipeline system to include the\nlocation and identification of all pipeline valves.\nThe operator did not maintain a reference list or documentation of the pipeline valves\nrequiring bi-annual inspection. Furthermore, the valve inspection logs for 2009, 2010, and2\n\n\n\n2011 each list varying numbers of valves, with varying descriptions, at the ASI receiving\nmanifold. The valves at this location were not shown in detail on the alignment sheets, or\nreferenced in any other documentation, so it was not possible to confirm the correct\nnumber of valves, or their location/description.\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 Central Florida Pipeline\nCorporation being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-6004W. 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":6972}