# WOLVERINE PIPELINE CO — Warning Letter

- **operation:** document
- **citation:** CPF 320105003W
- **title:** WOLVERINE PIPELINE CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-02-02
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.420(b), 195.569, 195.579(c).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320105003w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320105003W
**body:**

Warning Letter involving WOLVERINE PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.420(b),  195.569,  195.579(c). The case was opened on 2010-02-02 and is reported as closed as of 2010-02-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320105003W_Warning Letter_02022010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105003W/320105003W_Warning%20Letter_02022010.pdf

320105003W_Warning Letter_02022010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105003W/320105003W_Warning%20Letter_02022010_text.pdf

320105003W_Warning Letter_02022010_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 2, 2010
Mr. John Gurrola, Vice President and Manager
Wolverine Pipe Line Company
8075 Creekside Drive, Suite 210
Portage, MI 49024-5251
CPF 3-2010-5003W
Dear Mr. Gurrola:
On October 22-26, 2007, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Wolverine Pipe Line Company’s procedures and records as part of a standard unit inspection
in Portage, MI.
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. §195.420 Valve maintenance.
(b) Each operator shall, at intervals not exceeding 7 1/2 months, but at
least twice each calendar year, inspect each mainline valve to determine
that it is functioning properly.
Wolverine Pipe Line Company did not document the inspection of each mainline
valve to determine that it was functioning properly at least twice each calendar year at
intervals not exceeding 7 ½ months. Records indicate that personnel that were at the
Casco Junction station were performing other scheduled maintenance. Wolverine



indicated that the valve inspections would have been part of the scheduled
maintenance at that time. However, there is no documentation on the valve
inspections for October 2005.
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.
Wolverine Pipe Line Company did not document two external and internal inspections
of their pipeline system. This is noted by documentation that neither end of the GH-
FB 8-inch pipeline segment replacement project in Grand Haven on the PL-751, form
dated February 8, 2006 was inspected. In addition, the parent pipe on the VI-FD 16-
inch pipeline replacement at station 7684+33 on May 6, 2006, PL-0751, Report
Number FD-44-06 contains no documentation that an external and internal inspection
was performed.
3. §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.
Wolverine Pipe Line Company did not examine the exposed two portions of the
pipeline for external corrosion if the pipe is bare, or if the coating is deteriorated. The
records show that the condition of the pipe coating was not documented for the GH-
FB 8-inch pipeline and the VI-FD 16-inch pipeline.
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
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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 Wolverine Pipe Line
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 3-2010-5003W. 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
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