{"operation":"document","citation":"CPF 320095013W","title":"TE PRODUCTS PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-08-31","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320095013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320095013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320095013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320095013W","body":"Warning Letter involving TE PRODUCTS PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 195.428(a),  195.583(a). The case was opened on 2009-08-31 and is reported as closed as of 2009-08-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320095013W_Warning Letter_08312009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320095013W/320095013W_Warning%20Letter_08312009.pdf\n\n320095013W_Warning Letter_08312009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320095013W/320095013W_Warning%20Letter_08312009_text.pdf\n\n320095013W_Warning Letter_08312009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 31, 2009\nMr. Terry Hurlburt, Sr.\nTE Products Pipeline Company, LLC\nSenior Vice President Operations\n1100 Louisiana Street\nHouston, Texas 77002-5227\nCPF 3-2009-5013W\nDear Mr. Hurlburt:\nOn August 11-15, 2008, August 25-29, 2008, September 29 – October 3, 2008, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code inspected your TE Products Pipeline, LLC\n(TEPPCO) records and field facilities in Missouri, Illinois, Indiana, Ohio & West Virginia.\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. §195.428 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 in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½\nmonths, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\n\n\n\nTEPPCO overpressure protection inspection process failed to require the inspection\nand testing of the complete pressure information circuit loop for the pressure limiting\ndevices and pressure control equipment at intervals not to exceed 7½ months, but at\nleast twice each calendar year, to determine that it is functioning properly, is in good\nmechanical condition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nTEPPCO failed to inspect the complete pressure information circuit loop for stations\nthat used transmitters and PLCs as overpressure protection. The pressure transmitters\npressure range was inspected. However, TEPPCO failed to inspect the PLC’s actual\npressure shutdown initiation.\n2. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs.\n195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long\nas the pipeline remains in service.\nReview of TEPPCO records revealed that the record for the following required\ncorrosion control inspection was not retained for 5 years:\n(a) 195. 583 What must I do to monitor atmospheric corrosion control?\nTEPPCO has not been documenting atmospheric corrosion inspection\nof their Mainline Valves since this regulation went into effect. They\naffirm that the inspections were completed, but no documentation was\nmade. Therefore, no records are available for atmospheric corrosion\ninspection for any of TEPPCO Mainline Valves.\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\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 TE Products Pipeline, LLC being subject\nto additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2009-5013W. 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 qualifies 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\n3","truncated":false,"body_characters":5387}