{"operation":"document","citation":"CPF 320075028W","title":"JAYHAWK PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-10-10","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.402(e), 195.404(b)(1), 195.428(a), 195.579(b), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320075028w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320075028w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320075028w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320075028W","body":"Warning Letter involving JAYHAWK PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(e),  195.404(b)(1),  195.428(a),  195.579(b),  195.583(a). The case was opened on 2007-10-10 and is reported as closed as of 2007-10-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320075028W_Warning_Letter_10102007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075028W/320075028W_Warning_Letter_10102007.pdf\n\n320075028W_Warning_Letter_10102007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075028W/320075028W_Warning_Letter_10102007_text.pdf\n\n320075028W_Warning_Letter_10102007_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 10, 2007\nMr. Myron Hoover\nJayhawk Pipeline LLC\n2000 South Main\nMcPherson, Kansas 67460\nCPF 3-2007-5028W\nDear Mr. Hoover:\nOn April 4-8, April 11-15, April 25-29, and May 9-13, 2005, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your pipeline facilities in Kansas, Oklahoma, Nebraska, and Texas.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §195.402(a) Procedural manual for operations, maintenance, and emergencies.\nGeneral. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies.\n§402(c)(10) Abandonment of Facilities. Jayhawk did not follow its O&M\nProcedure Section 205, “Abandonment of Pipeline Facilities.\n” You did not document\nthat the following pipeline segments were abandoned by safely disconnecting from the\noperating pipeline system, purging of combustibles, and sealing, if left in place, to\nminimize safety and environmental hazards.\na. Susank, KS to Buhler Junction, KS 8\"\nb. Inman Junction, KS to McPherson, KS 6\"\nc. Chase, KS to Hollow Junction, KS 8\" (except for 15 miles of p/l from\nWalsten Junction to Buhler Junction)\n\n\n\nd. Hollow Junction, KS to Valley Center, KS 6\"\ne. Valley Center, KS to Augusta, KS 8\" & 10\"\nf. Valley Center, KS to Ponca City, OK 8\"\ng. Walsten Junction, KS to Valley Center, KS 10\"\n2. §195.402(a) Procedural manual for operations, maintenance, and emergencies.\nGeneral. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies.\n§195.402 (d) Abnormal operation. Jayhawk did not follow its O&M procedure Section\n300, “Abnormal Operating Conditions”. Jayhawk did not have a record indicating their\nresponse, investigation, and correction of the cause of the abnormal operation condition\nthat occurred at Taloga Pump Station on 11/25/02. During a review of the 2002\noverpressure protection inspection records for the Taloga Pump Station, a recalibration\nrecord was found that stated ”recalibration after Operator’s reports of failure of unit\nshutdown.” There was no documentation of an investigation following the malfunction\nof the overpressure device.\n3. §195.402(a) Procedural manual for operations, maintenance, and emergencies.\nGeneral. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies.\n§195.402 (e) Emergencies. Jayhawk did not follow its O&M procedure Section 400,\n“Emergency Operations.” Jayhawk did not conduct a post accident review of their\nemployees’ activities to determine the effectiveness of their procedures after the fire on\nFebruary 11, 2004, at Holdrege, NE Pump Station.\n4. §195.404 Maps and Records.\n(b) Each operator shall maintain for at least 3 years daily operating records\nthat indicate-\n(1) The discharge pressure at each pump station; and\nJayhawk did not provide a means to capture the daily discharge pressure at the following\npump stations:\n1 - Wilburton Injection Pump\n2 - Hudson Injection\n3 - Frees Injection\n4 - McPherson Injection\n5 - Schurr (10\" to Chase) Pump\nAs a result of this inspection, Chart Recorders were installed at all locations by the end\nof July 2005.\n2\n\n\n\n5. §195.428 Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or\nin the case of pipelines used to carry highly volatile liquids, at intervals not\nto exceed 7½ months, but at least twice each calendar year, inspect and\ntest each pressure limiting device, relief valve, pressure regulator, or other\nitem of pressure control equipment to determine that it is functioning\nproperly, is in good mechanical condition, and is adequate from the\nstandpoint of capacity and reliability of operation for the service in which\nit is used.\n(d) After October 2, 2000, the requirements of paragraphs (a) and (b) of this\nsection for inspection and testing of pressure control equipment apply to\nthe inspection and testing of overfill protection systems.\nJayhawk has not been inspecting and testing their breakout tanks’ overfill protection\nalarm system at intervals not to exceed 15 months, but at least once each calendar year\nfor the following locations:\nChase, KS 12 Breakout Tanks\nLiberal, KS 11 Breakout Tanks\nWichita, KS 9 Breakout Tanks\nAs a result of this inspection, Jayhawk started inspecting overfill protection systems on\nJune 2005\n6. §195.579 What must I do to mitigate internal corrosion?\n(b) Inhibitors. If you use corrosion inhibitors to mitigate internal corrosion,\nyou must--\n(3) Examine the coupons or other monitoring equipment at least twice\neach calendar year, but with intervals not exceeding 7 1/2 months.\nJayhawk did not examine the coupon at the Interstate Station to monitor for internal\ncorrosion at least twice each calendar year, or with intervals not exceeding 7 ½ months.\nJayhawk’s maintenance crew removed the coupon holder at Interstate Station during\nmaintenance and failed to replace the coupon holder. Jayhawk’s last coupon inspection\nat Interstate was on 04/08/2003. Jayhawk missed the second required inspection in\n2003, both required inspection in 2004, and the first required inspection in 2005. A\ntotal of 4 inspections were missed. As a result of this inspection, the coupon holder was\nreplaced.\n7. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\n3\n\n\n\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore\nAt least once every 3 calendar years, but\nwith intervals not exceeding 39 months\nJayhawk did not inspect each pipeline or portion of pipeline that was exposed to the\natmosphere. Inspections were not performed on 1 span in the Chase area and 31 pump\nstations for evidence of atmospheric corrosion. See attached spreadsheet labeled\n“Atmospheric Corrosion Inspection Requirements Not Met.”\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Failure to do so will result in Jayhawk Pipeline LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2007-5028W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nIn addition, our representative noted that Jayhawk did not follow their procedure which\nrequires a drill that exercises the entire response plan for each response zone, be conducted at\nleast once every 3 years. The last OPA 90 drill where Jayhawk’s Oil Spill Removal\nOrganization (OSRO) was used and booms were deployed was in 1998 on the Little Arkansas\nRiver. After PHMSA’s inspection, Jayhawk completed a spill drill with their OSRO and full\ndeployment of booms on July 27, 2005. We hope you will consider this area of concern as an\nopportunity to improve your existing pipeline safety program.\nSincerely,\nIvan A. Huntoon\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":9245}