{"operation":"document","citation":"CPF 220126006W","title":"GENESIS PIPELINE ALABAMA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-03-20","effective_on":null,"summary":"CLOSED warning letter citing 195.222(a), 195.305(a), 195.442(c)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220126006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220126006W","body":"Warning Letter involving GENESIS PIPELINE ALABAMA, LLC. PHMSA's enforcement data identifies the cited regulations as 195.222(a),  195.305(a),  195.442(c)(1). The case was opened on 2012-03-20 and is reported as closed as of 2012-03-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220126006W_Operator Response_04182012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126006W/220126006W_Operator%20Response_04182012.pdf\n\n220126006W_warning letter_03202012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126006W/220126006W_warning%20letter_03202012.pdf\n\n220126006W_warning letter_03202012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220126006W/220126006W_warning%20letter_03202012_text.pdf\n\n220126006W_warning letter_03202012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 20, 2012\nMr. Mike Moore\nVice President, Pipelines and Trucking Operations\nGenesis Pipeline Alabama, LLC\n919 Milam, Suite 2100\nHouston, Texas 77002-5417\nCPF 2-2012-6006W\nDear Mr. Moore:\nFrom February 13-16, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Genesis Pipeline Alabama, LLC (Genesis-AL)\nCastleberry Pipeline’s written operations and maintenance (O&M) procedures, records and\nfacilities in Alabama pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that (Genesis-AL) has committed probable violations\nof the Pipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104\n(incorporated by reference, see §195.3) or section IX of the ASME Boiler and\nPressure Vessel Code, (incorporated by reference, see §195.3) except that a welder\nqualified under an earlier edition than listed in §195.3 may weld but may not re-\nqualify under that earlier edition.\nGenesis-AL did not follow its written welding procedures because it did not document and\nkeep welder qualification records as required by its written procedures.\nThe Genesis Energy Liquid & CO2 Operations, Maintenance and Emergency Procedures\nManual (LOM&E) is used by all Genesis Energy, L.P. companies operating hazardous\nliquid pipelines regulated under 49 CFR Part 195. LOM&E Section 2.15 Welding stated,\nin part, the following:\n“Documentation\nAll welding projects must be documented. Documentation must be kept for the life of the\npipeline and includes: . . . Welder qualification (coupon test or radiography results)”\n\n\n\nGenesis did not provide welder qualification records for the welder who welded on the\nconstruction and installation of a check meter and associated piping fabrication at the\nterminus of the 8-inch Castleberry Line at the I-65 Junction in December 2010. While\nGenesis provided Operator Qualification (OQ) records that indicated the welder was\nqualified to direct the repair of certain defective welds, no records were provided to\nconvey how and when the welder had been qualified to weld on the referenced project.\n2. §195.305 Testing of components.\n(a) Each pressure test under §195.302 must test all pipe and attached fittings,\nincluding components, unless otherwise permitted by paragraph (b) of this section.\nGenesis-AL did not pressure test all fittings, including components, of a fabricated\nassembly that was installed at the terminus of the 8-inch Castleberry Line at the I-65\nJunction in December 2010. The components and fittings included a strainer, a meter,\nweld neck flanges, and pipe fittings. The exemption in §195.305(b) did not apply because\nmore than one component was installed.\n3. §195.442 Damage prevention program.\n. . . (c) The damage prevention program required by paragraph (a) of this section\nmust, at a minimum:\n(1) Include the identity, on a current basis, of persons who normally engage in\nexcavation activities in the area in which the pipeline is located.\nGenesis-AL did not include the identity, on a current basis, of persons who normally\nengage in excavation activities in the area in which the pipeline is located.\nGenesis-AL did not provide any records to indicate it had identified persons who normally\nengage in excavation activities in Conecuh County, Alabama for calendar years 2010 and\n2011. The 8-inch Castleberry Line traverses through Conecuh County for approximately\n13 miles, and is located within about 9 miles from the town of Evergreen, Conecuh\nCounty. An internet search of building and construction companies by the PHMSA\ninspector found several companies located in Evergreen that would be considered\nexcavators, including water well drillers, general contractors, and heavy construction\ncontractors.\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 Genesis Pipeline Alabama,\nLLC 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 2-2012-6006W. 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),2\n\n\n\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":6162}