{"operation":"document","citation":"CPF 220145001W","title":"MID - VALLEY PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-02-20","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3), 195.406(a)(2), 195.406(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220145001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220145001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220145001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220145001W","body":"Warning Letter involving MID - VALLEY PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(3),  195.406(a)(2),  195.406(b). The case was opened on 2014-02-20 and is reported as closed as of 2014-02-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220145001W_warning letter_02202014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220145001W/220145001W_warning%20letter_02202014.pdf\n\n220145001W_warning letter_02202014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220145001W/220145001W_warning%20letter_02202014_text.pdf\n\n220145001W_warning letter_02202014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 20, 2014\nMr. David Chalson\nVice President of Operations\nMid Valley Pipeline Company\n2700 West Passyunk Ave\nPhiladelphia, PA 19145\nCPF 2-2014-5001W\nDear Mr. Chalson:\nFrom June 8, 2013, to November 25, 2013, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Southern Region, Office of Pipeline Safety\n(OPS), pursuant to Chapter 601 of 49 United States Code, inspected Mid Valley Pipeline\nCompany (MVPL) records and facilities at MVPL’s Icedale headquarters office and in\nMichigan, Ohio, Kentucky, Tennessee, Mississippi, Louisiana, and Texas. MVPL is a\nsubsidiary of Sunoco Logistics Partners, L.P.\nAs a result of our investigation, it appears that MVPL has committed probable violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violations are as follows:\n1. §195.406 Maximum Operating Pressure (MOP).\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n… (2) The design pressure of any other component on the pipeline.\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.\nMVPL did not properly establish the maximum operating pressure (MOP) for the\nHaynesville-Magnolia Line, or for the tank lines at its Magnolia, Haynesville, Denver, and\nHebron facilities because the MOPs provided by MVPL at the time of the inspection\nexceeded the design pressures of installed pipeline components.\n\n\n\nMVPL established an MOP of 1,100 psig for the entirety of its Haynesville-Magnolia\nLine, including the Magnolia Station, a downstream delivery facility. At the time of\nPHMSA’s inspection, the scraper trap valves and flanges at the Magnolia Station were\nANSI 400 components, rated for a maximum of 990 psig. Furthermore, the tank lines at\nthe Magnolia Station were equipped with ANSI 300 valves and flanges with a maximum\npossible rating of 740 psig.\nMVPL established an MOP of 936 psig for the Cotton Valley-Haynesville line segment,\nincluding the Haynesville Station. The tank lines at the Haynesville Station were\nequipped with ANSI 300 valves and flanges with a maximum possible rating of 740 psig.\nMVPL established an MOP of 956 psig for the Hornsby-Denver line segment, including\nthe Denver Station. The tank lines at the Denver Station are equipped with ANSI 300\nvalves and flanges with a maximum possible rating of 740 psig.\nMVPL established an MOP of 1,052 psig for the Simpsonville-Hebron line segment,\nincluding the Hebron Station. The tank lines at the Hebron Station are equipped with\nANSI 400 valves and flanges with a maximum possible rating of 990 psig.\nEach of the referenced tank lines are downstream of over pressure protection devices,\nlimiting pressures in the tank lines to a maximum of 500 psig.\n2. §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.\nMVPL did not maintain records of monthly inspections of the breakout tanks at the\nLongview Station as required by Subpart F, §195.432.\nRecords reviewed at MVPL’s Longview office revealed that the required monthly external\ntank inspections of 14 in-service breakout tanks at the Longview Station were not\ndocumented from August through December 2012, or for the months of January and\nJuly 2013.\nUnder 49 United States Code, §60122, Mid Valley Pipeline Company is subject to a civil\npenalty not to exceed $200,000 per violation per day the violation persists up to a maximum\nof $2,000,000 for a related series of violations. For violations occurring prior to March 6,\n2013, the maximum penalty may not exceed $100,000 per violation per day, with a maximum\npenalty not to exceed $1,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in\nMid Valley Pipeline Company 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 2-2014-5001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any2\n\n\n\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":6071}