EXPLORER PIPELINE CO — Warning Letter

320075010W_Warning Letter_03092007.pdf, page 1Official PDFMAR 1 4 200t @ u.s. Deporlmenl of Tronsportotion Pipeline ond Hozordous lylqledols Soleiy Adminlstrotion 901 Locusl Strest, Suite .162 Kansas City, MO 64106-2641 WARNING LETTER CERTIX'IED MAIL - RETURN RECEIPT REOUESTED March 9, 2007 Mr. Timothy C. Felt President & CEO Explorer Pipeline Autumn Oaks Building, Suite 300 Third Floor 6846 South Canton Avenue Tulsa, Ok 74136 cP[' 3-2007-5010w Dear Mr. Felt: On June 26 - 30, September 18 - 22,, September 25 - 29, and November 27 - 30, 2006, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your pipeline facilities in Illinois, Missouri, and Indiana. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: $195.567 Which pipelines must have test leads and what must I do to install and maintain the leads? (a) Maintenance. You must maintain the test lead wires in a condition that enables you to obtain electrical measurements to determine whether cathodic protection complies with Sec. 195.571. Explorer did not maintain the test lead wires at MP I 56. 13 6, 369.8299 (or 369.83), 37L9646,371.9657, and MP 375.8415 for the 2003, 2004, and 2005 annual inspections.#

320075010W_Warning Letter_03092007.pdf, page 21 $195.573 What must I do to monitor external corrosion control? (d) Breakout tanks. You must inspect each cathodic protection system used to control corrosion on the bottom ofan aboveground breakout tank to ensure that operation and maintenance of the system are in accordance with API Recommended Practice 651. However, this inspection is not required if you note in the corrosion control procedures established under Sec. f95.402(cx3) why compliance with all or certain operation and maintenance provisions of APr Recommended Practice 651 is not necessary for the safety of the tank J . 4. 5. Explorer did not inspect the center cathodic protection test lead for two consecutive years for breakout tank numbers 431.439. & 471 at Wood River and 654 at Hammond. $195.589 What corrosion control information do I have to maintain? (c) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey, and test required by this subpart in sufficient detail to demonstrate the adequacy ofcorrosion control measures or that corrosion requiring control measures does not exist. You must retain these records for at least 5 years, except that records related to secs. 195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service. Explorer did not have records that documented the electrical check for proper performance on rectifiers # 446 for the 3/3112004 ar'd # 421-9 for the llll0/2004. and 12/28/2004 Wood River area surveys. $195.533 What must I do to monitor atmospheric corrosion control? (a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows: If the pipeline is located: Onshore Then the frequency of inspection is: At least once every 3 calendar years, but with intervals not exceeding 39 months Explorer did not inspect each pipeline or portion ofpipeline that was exposed to the atmosphere on 14 Spans in the Wood River area and I Span in the Hammond area for evidence ofatmospheric corrosion. see attached spreadsheet labeled "List ofspans.tt Explorer is expected to document future inspections of spans for atmospheric colrosion. $195.406 Maximum operating pressure (MOP). (d) No operator may permit the pressure in a pipeline during surges or other variations from normal operations to exceed 110 percent ofthe operating pressure limit established under paragraph (a) of this section. Each operator must provide adequate controls and protective equipment to control the pressure within this limit. Explorer exceeded I l0% of MOP on the Hammond Station ANSI 150 pound piping on July 25, 2005. The MOP of ANSI 150 is 285 psig and I l0% would be 313.5 psig. The overpressure condition was a momentary surge of 330 psig.#

320075010W_Warning Letter_03092007.pdf, page 3Under 49 United States Code, S 60122, you are subject to a civil penalty not to exceed $ 100,000 for each violation for each day the violation persists up to a maximum of $ 1 ,000,000 for aly related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct these items ideirtihed in this letter. Failure to do so will result in Explorer Pipeline Company being subject to additional enforcement action. No reply to this letter is required. Ifyou choose to reply, in your correspondence please refer to CPF 3-2007-5010W. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. Ifyou believe that any portion ofyour responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe quali$ for confidential treatment redacted and an explanation ofwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Director, Central Region Pipeline and Hazardous Materials Safety Administration#