{"operation":"document","citation":"CPF 220156001W","title":"CENTRAL FLORIDA PIPELINE CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-07-09","effective_on":null,"summary":"CLOSED warning letter citing 195.573(e), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220156001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220156001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220156001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220156001W","body":"Warning Letter involving CENTRAL FLORIDA PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 195.573(e),  195.589(c). The case was opened on 2015-07-09 and is reported as closed as of 2015-07-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220156001W_warning letter_07092015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220156001W/220156001W_warning%20letter_07092015.pdf\n\n220156001W_warning letter_07092015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220156001W/220156001W_warning%20letter_07092015_text.pdf\n\n220156001W_warning letter_07092015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 9, 2015\nMr. Ronald McClain\nPresident\nProducts Pipelines\n1001 Louisiana St., Suite 1000\nHouston, TX 77002\nCPF 2-2015-6001W\nDear Mr. McClain:\nOn December 8-11, 2014, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS), pursuant to\nChapter 601 of 49 United States Code, inspected the Central Florida Pipeline Corporation\n(CFPL) refined products pipeline from Tampa to Orlando, Florida.\nAs a result of the inspection, it appears that CFPL have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe 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 Sec. 195.401(b). However, if the deficiency involves a pipeline\nin an integrity management program under Sec. 195.452, you must correct the\ndeficiency as required by Sec. 195.452(h).\nCFPL did not correct corrosion control deficiencies identified at three different locations\nas required by §195.401(b).\nA review of CFPL's 2011 through 2013 annual cathodic protection (CP) survey\npipe-to-soil readings revealed two locations on the 10-inch pipeline, and one location on\nthe 16-inch pipeline with deficiencies (i.e. less negative than – 0.85V) that were not\ncorrected for several years as listed below:\n\n\n\n2. CFPL 10-inch Pipeline, Line Section Name: Kissimmee, Milepost 81.400\n12/11/2011: No CP potentials recorded\n12/02/2012: 0.000 V\n10/18/2013: No CP potentials recorded\n12/13/2013: -1.325 V (CFPL repaired and retested test station)\nCFPL 10-inch pipeline, Line Section Name: Tampa, Milepost 3.852\n12/09/2011: 0.033 V\n12/10/2012: -0.398 V\n10/15/2013: 0.110 V\n12/13/2013: -1.695 V (CFPL repaired and retested test station)\nCFPL 16-inch Pipeline, Line Section Name: Pinecrest, Milepost 20.076\n12/02/2011: -0.600 V\n12/04/2012: -0.606 V\n10/21/2013: -0.556 V\n12/12/2013: -1.325 V (CFPL repaired and retested test station)\n§195.589 What corrosion control information do I have to maintain?\n… (c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs. 195.569,\n195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the\npipeline remains in service.\nCFPL did not provide a record or other documentation to demonstrate that it had inspected\nthe internal surface of the 8-inch ITE pipeline for evidence of internal corrosion as\nrequired by Subpart H.\nCFPL personnel performed pipe inspections on five sections of the ITE 8-inch pipeline as\npart of a pipeline construction project and documented the work on the Kinder Morgan\nPipeline Inspection/Repair Report, form L-OM200-02 for each inspection. The OPS\ninspector reviewed these pipe inspection reports and found that CFPL did not properly\ndocument the inspection of the pipeline’s internal surface for evidence of corrosion at one\nof the five locations. Records documenting the inspection of the internal pipe surface for\ninternal corrosion as required by §195.579(c) must be retained for as long as the pipeline\nremains in service.\nUnder 49 United States Code, § 60122, Central Florida Pipeline Corporation is subject to a\ncivil penalty not to exceed $200,000 per violation per day the violation persists up to a\nmaximum of $2,000,000 for a related series of violations. For violations occurring prior to\nJanuary 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a\nmaximum penalty not to exceed $1,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\n2\n\n\n\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in\nCentral Florida Pipeline Corporation 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 2-2015-6001W. 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":5784}