{"operation":"document","citation":"CPF 320085001W","title":"TE PRODUCTS PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-01-29","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.404.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320085001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320085001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320085001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320085001W","body":"Warning Letter involving TE PRODUCTS PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.404. The case was opened on 2008-01-29 and is reported as closed as of 2008-01-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320085001W_Warning Letter_01292008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320085001W/320085001W_Warning%20Letter_01292008.pdf\n\n320085001w_warning letter_01292008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320085001W/320085001w_warning%20letter_01292008_text.pdf\n\n320085001w_warning letter_01292008_text.pdf\n\nO\nU. S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n901 Locust Street, Suite 462\nKansas City, MO 64106-2641\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nJanuary 29, 2008\nMr. Terry L. Hurlburt\nSenior Vice President of Operations\nTexas Eastern Products Pipeline Company, LP\n1100 Louisiana St.\nHouston, TX 77002\nCPF 3-2008-5001W\nDear Mr. Hurlburt:\nOn June 9, 2006, a representative of the Pipehne and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Texas\nEastern Products Pipehne Company's (TEPPCO) repair of a failed girth weld on the Al\npipehne near the intersection of County Road 22 and Cory Road near the Village of Port\nWilliam, in Clinton County, Ohio.\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\nthe probable violations are:\n1. $195. 404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information;\n(1) Location and identification of the following pipeline facilities;\n(ii) Pump stations;\n\n\n\nTEPPCO did not have current accurate maps available for field personnel utilization\nduring the response to the June 7, 2006 girth weld leak on the A-1 pipeline in Clinton\nCounty, Ohio. During the course of PHMSA's investigation, alignment sheets were\nreviewed onsite. These alignment sheets did not contain the location of the Chester\npump station. TEPPCO's latest alignment sheets obtained through a January 31, 2007\nPHMSA Data Request, indicated that the Chester pump station was added to the sheet\non 11-18-03.\n2. $195. 402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies.\nTEPPCO did not follow their procedures while conducting hot tapping operations during\na cut out repair on the A-1 pipeline. TEPPCO's procedures for the operation of the\nstoppling equipment are the same as the equipment manufacturer, TD Williamson\n(TDW).\nOn June 6, 2006, TEPPCO discovered a leak on the A-1 pipeline at MP 39. 4. The leak\nwas caused by a failed girth weld. To cut out the leaking girth weld on June 9, 2006,\nworkmen welded stopple fittings to the A-1 pipehne in bell holes dug on the north and\nsouth sides of the leaking girth weld. TDW drilling and stopping equipment was used to\nstop the flow. TEPPCO owns the stoppling equipment and three TEPPCO employees\nwere observed operating the equipment. All three employees were trained and qualified\non July 19, 2005 by attending a TDW training session and taking an exam.\nDuring the course of operations in the north bell hole, a sandwich valve was installed\nover the spit tee and the drilling equipment was set on the tee. Connections were made\ntight and a pressure gauge was installed. Workmen then proceeded to immediately cut\nthe \"cookie\" without completing the pressure test as required by Step 3. 7 of TDW\nModel 660a/760a Tapping Machines Operation and Maintenance Instructions. TDW\ninstructions specify a pressure test be done after plumbing and bolt up of the drilhng\nmachine to verify no product leaks will be present after the pilot drill bit punctures the\npipe.\nWhen our representative realized that no pressure test had taken place prior to\ncommencement of the drilling, your onsite engineer was notified that TDW's procedures\nwere not being followed. As a result, your onsite engineer stopped the operation before\npuncturing the pipe and pressure tested the fitting as required by procedures.\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\n2\n\n\n\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\naction or penalty assessment proceedings at this time. We advise you to correct the item(s)\nidentified in this letter. Failure to do so will result in Texas Eastern Products Pipeline\nCompany, LP 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 3-2008-5001W. 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 portion\nof your responsive material quahfies for confidential treatment under 5 U. S, C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U. S. C.\n552(b).\nSincerely,\nIvan A. Huntoon\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":5856}