{"operation":"document","citation":"CPF 220145004W","title":"WOLVERINE PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-09-11","effective_on":null,"summary":"CLOSED warning letter citing 195.446(e)(5), 195.446(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220145004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220145004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220145004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220145004W","body":"Warning Letter involving WOLVERINE PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.446(e)(5),  195.446(h). The case was opened on 2014-09-11 and is reported as closed as of 2014-09-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220145004W_Operator Response_03202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220145004W/220145004W_Operator%20Response_03202015.pdf\n\n220145004W_warning letter_09112014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220145004W/220145004W_warning%20letter_09112014.pdf\n\n220145004W_warning letter_09112014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220145004W/220145004W_warning%20letter_09112014_text.pdf\n\n220145004W_warning letter_09112014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 11, 2014\nMr. Marius Green\nVice President & Operations Manager\nWolverine Pipeline Company\n8075 Creekside Drive, Suite 210\nPortage, MI 49024\nCPF 2-2014-5004W\nDear Mr. Green:\nOn June 16-20, 2014, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nWolverine Pipeline Company (Wolverine) control room management program at\nPortage, Michigan, pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that Wolverine 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. § 195.446 Control room management.\n… (e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller response to\nalarms. An operator's plan must include provisions to:\n…(5) Monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals not\nexceeding 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms; and\nWolverine did not monitor the content and volume of general activity being directed to\nand required of each controller at least once each calendar year, but at intervals not\nexceeding 15 months.\n\n\n\nThat is, Wolverine did not present to the OPS inspector records to demonstrate that it had\nmonitored the content and volume of general activity being directed to, and required of,\neach controller in calendar year 2013.\n2. § 195.446 Control room management.\n…(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least once\neach calendar year, but at intervals not to exceed 15 months. An operator's program\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator. In addition, the training program must include the\nfollowing elements:\nWolverine did not review the training program content at least once each calendar year,\nbut at intervals not exceed 15 months, to identify potential improvements.\nThat is, Wolverine did not present to the OPS inspector records to demonstrate that it had\nreviewed the training program content in calendar year 2013 to identify potential\nimprovements.\nUnder 49 United States Code, § 60122, Wolverine is subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a 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 Wolverine being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2014-5004W. 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\n2","truncated":false,"body_characters":4849}