# CITGO PIPELINE CO — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320045028
- **title:** CITGO PIPELINE CO — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2004-09-09
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.452(b)(2), 195.452(c), 195.452(c)(2), 195.452(e)(1), 195.452(f), 195.452(f)(3), 195.452(f)(4).
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**body:**

Notice of Probable Violation involving CITGO PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195,  195.452(b)(2),  195.452(c),  195.452(c)(2),  195.452(e)(1),  195.452(f),  195.452(f)(3),  195.452(f)(4). The case was opened on 2004-09-09 and is reported as closed as of 2007-02-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320045028_final order_02062007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045028/320045028_final%20order_02062007.pdf

CPF_NO_3-2004-5028.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045028/CPF_NO_3-2004-5028.pdf

320045028_final order_02062007.pdf

400 Seventh Street, S.W.
U.S. Department Washington, D.C. 20590
of Transportation
Pipeline and Hazardous
Materials Safety Administration
FEB - 6 2807
Mr. Kent Powers
General Manager
CITGO Petroleum Corporation - Pipelines and Terminals
One Warren Place
61 00 South Yale Avenue
Tulsa, OK 74 1 02
Re: CPF No. 3-2004-5028
Dear Mr. Powers:
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in the
above-referenced case. It makes a finding of violation and finds that you have completed the
actions specified in the Notice required to comply with the pipeline safety regulations. The Final
Order also finds that you have addressed the inadequacies in your procedures that were cited in
the Notice of Amendment. This case is now closed. Your receipt of the Final Order constitutes
service under 49 C.F.R. § 190.5.
Sincerely,
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Ivan Huntoon
Director, Central Region, PHMSA
CERTLFIED MAIL -RETURN RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADNIIIVISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of
CITGO Petroleum Corporation
Pipelines and Terminals
Respondent
) 1 CPF NO. 3-2004-5028
1
1
1
1
FINAL ORDER
On September 15-19 and October 6-8, 2003, pursuant to 49 U.S.C. 4 601 17, representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
conducted an inspection of Respondent's integrity management program (IMP) in Tulsa,
Oklahoma. As a result of the inspection, the Director, Central Region, PHMSA, issued to
Respondent, by letter dated September 9, 2004, a Notice of Probable Violation, Proposed
Compliance Order, and Notice of Amendment (Notice). In accordance with 49 C.F.R. 4
190.207, the Notice proposed finding that Respondent had committed violations of 49 C.F.R.
Part 195 and proposed ordering Respondent to take certain measures to correct the alleged
violations. The Notice also proposed, in accordance with 49 C.F.R. 4 190.237, that Respondent
amend its operating and maintenance procedures.
Respondent responded to the Notice by letter dated October 1 1,2004, as supplemented by letter
dated August 10, 2005 (Response). Respondent contested two of the allegations of inadequate
procedures, provided information concerning the corrective actions it has taken, and submitted
copies of certain of its procedures that it had revised. Respondent did not request a hearing, and
therefore has waived its right to one.
FINDING OF VIOLATION
Item 7 in the Notice alleged that Respondent violated 49 C.F.R. 195.452(f) by failing to specify
tolerance criteria for addressing dent issues identified by integrity assessments, and failing to
treat a dent on Line 372A as a 180-day condition in the absence of geometry tool performance
specification. In its Response, Respondent did not contest the alleged violation. Accordingly, I
find .that Respondent violated 49 C.F.R. 195.452(f), as more hlly described in the Notice.



This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
WITHDRAWAL OF ALLEGATIONS
Item 2 in the Notice alleged that Respondent had violated 49 C.F.R. 8 195.452(c)(l)(i) by failing
to select an assessment method capable of assessing seam integrity on low-frequency electric
resistance welded (ERW) pipe in the Bell to Granville line. In its response, Respondent
submitted information demonstrating that it had selected a UT crack tool to assess seam integrity
on its low frequency ERW pipe and that this tool was run to complete the baseline assessment of
the Bell to Granville line. Based on this information demonstrating compliance with the
regulation, I am withdrawing this allegation of violation.
Item 3 in the Notice alleged that Respondent had violated 49 C.F.R. 8 195.452(~)(2) by failing to
document modifications to its list of identified segments. In its response, Respondent submitted
information demonstrating that it had documented the modifications to its list of identified
segments. Based on this information demonstrating compliance with the regulation, I am
withdrawing this allegation of violation.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 7 in the Notice for Respondent's
failure to specify tolerance criteria for addressing dent issues identified by integrity assessments,
and failure to treat a dent on Line 372A as a 180-day condition in the absence of geometry tool
performance specification. Under 49 U.S.C. 601 18(a), each person who engages in the
transportation of hazardous liquids or who owns or operates a pipeline facility is required to
comply with the applicable safety standards established under chapter 601. The Director,
Central Region, PHMSA, has indicated that Respondent has revised its dent evaluation practices
to consider the entire dent and require unity plots for evaluating tool tolerances. Respondent has
also demonstrated that it completed the examinations and repairs of 37 dent indications as
scheduled. Accordingly, since compliance has been achieved with respect to this violation, it is
unnecessary to include compliance terms in this Order.
AMENDMENT OF PROCEDURES
Items 1,4,5, and 6 in the Notice alleged inadequacies in Respondent's operating and
maintenance procedures and proposed to require amendment of Respondent's procedures to
comply with the requirements of 49 C.F.R. Part 195. In its response, Respondent submitted
copies of its amended procedures. The Director, Central Region, PHMSA reviewed the amended
procedures and determined that the amendments addressed the inadequacies identified in the
Notice. Based on the results of this review, I find that Respondent's original procedures as
described in the Notice were inadequate, but that Respondent has corrected the identified
inadequacies. Accordingly, it is unnecessary to issue an order directing amendment of
Respondent's procedures.



The terms and conditions of this Final Order are effective on receipt.
Date Issued
Administrator
for Pipeline Safety
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