CPF 320095001W
CPF 320095001W
320095001W_Warning Letter_03302009_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 30, 2009 Jim Lamanna, President BP Pipelines (North America) Inc. Mail Code 7018 28100 Torch Parkway Warrenville, IL 60555 CPF 3-2009-5001W Dear Mr. Lamanna: On July 9-11, 2007 and August 6-9, 2007, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your Amoco Oil Company Whiting to Indianapolis and Whiting to River Rouge products lines in the states of Indiana and Michigan and associated records in Merrillville, IN. 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 violation(s) are: 1. §195.569 Do I have to examine exposed portions of buried pipelines? Whenever you have knowledge that any portion of a buried pipeline is exposed, you must examine the exposed portion for evidence of external corrosion if the pipe is bare, or if the coating is deteriorated. If you find external corrosion requiring corrective action under Sec. 195.585, you must investigate circumferentially and longitudinally beyond the exposed portion (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinity of the exposed portion.#
320095001W_Warning Letter_03302009_text.pdf, page 2BP/Amoco failed to document the external examination of a buried pipeline exposure. There is no record of external inspection for the pipe repair made on the Whiting to Indianapolis Line at MP 119.801 on 4/10/07. 2. §195.579 What must I do to mitigate internal corrosion? (c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the internal surface of the pipe for evidence of corrosion. If you find internal corrosion requiring corrective action under Sec. 195.585, you must investigate circumferentially and longitudinally beyond the removed pipe (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinity of the removed pipe. BP/Amoco failed to document the internal examination of a buried pipeline exposure. There is no record of internal inspection for the pipe repair made on the Whiting to Indianapolis Line at MP 119.801 on 4/10/07. Under 49 United States Code, § 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 any 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 the item(s) identified in this letter. Failure to do so will result in Amoco Oil Company being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 3-2009-5001W. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your 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 qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerely, Ivan A. Huntoon Director, Central Region Pipeline and Hazardous Materials Safety Administration 2#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.