{"operation":"document","citation":"CPF 320121001W","title":"VECTOR PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-03-19","effective_on":null,"summary":"CLOSED warning letter citing 192.459, 192.475(b), 192.481(b), 192.603(b), 192.709(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320121001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320121001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320121001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320121001W","body":"Warning Letter involving VECTOR PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 192.459,  192.475(b),  192.481(b),  192.603(b),  192.709(c). The case was opened on 2012-03-19 and is reported as closed as of 2012-03-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320121001W_Operator Response to Notice_04172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320121001W/320121001W_Operator%20Response%20to%20Notice_04172012.pdf\n\n320121001W_Warning Letter_03192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320121001W/320121001W_Warning%20Letter_03192012.pdf\n\n320121001W_Warning Letter_03192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320121001W/320121001W_Warning%20Letter_03192012_text.pdf\n\n320121001W_Warning Letter_03192012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 19, 2012\nMr. Mark Maki\nSr. Vice President\nVector Pipeline, L.P.\n1100 Louisiana\nSuite 3300\nHouston, TX 77002\nCPF 3-2012-1001W\nDear Mr. Maki:\nOn August 15-18, October 24-27, 2011 and January 16-18, 2012, representatives of the\nMichigan Public Service Commission (MI-PSC) acting as an interstate agent for the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code inspected your facilities for Vector Pipeline L.P. (Vector) within the state\nof Michigan.\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 violation(s) are:\n1. §192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\n\n\n\n§192.459 External corrosion control: Examination of buried pipeline when\nexposed.\nWhenever an operator has knowledge that any portion of a buried pipeline is\nexposed, the exposed portion must be examined for evidence of external corrosion if\nthe pipe is bare, or if the coating is deteriorated. If external corrosion requiring\nremedial action under Secs. 192.483 through 192.489 is found, the operator shall\ninvestigate circumferentially and longitudinally beyond the exposed portion (by\nvisual examination, indirect method, or both) to determine whether additional\ncorrosion requiring remedial action exists in the vicinity of the exposed portion.\nVector did not document the external examination of the 30” and 36” lines when they\nwere exposed during the Highland Compressor Station project in 2009.\nThe 2009 project was for re-configuring the compressor station piping. Vector personnel\nindicated that they did the inspection, but were unable to provide any documentation that\nthe inspection was conducted.\n2. §192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\n§192.475 Internal corrosion control: General.\n(b) Whenever any pipe is removed from a pipeline for any reason, the internal\nsurface must be inspected for evidence of corrosion.\nVector did not document the internal examination of the 30” and 36” lines when they\nwere exposed and cut open during the Highland Compressor Station project in 2009.\nThe 2009 project was for re-configuring the compressor station piping. Vector personnel\nindicated that they did the internal inspections, but were unable to provide any\ndocumentation that the inspections were completed.\n3. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission line for the\nperiods specified:\n2\n\n\n\n(c) A record of each patrol, survey, inspection, and test required by subparts L and\nM of this part must be retained for at least 5 years or until the next patrol, survey,\ninspection, or test is completed, whichever is longer.\nVector personnel did not document the annual inspection of emergency valve LBDV-23\nat Milford Junction for 2009 and 2010. Additionally, at Washington Station, the unit\nblow down valves (UBV 106 & 206), the unit suction valves (USV 101 & 201), and the\nunit discharge valves (UDV 102 & 202,) also did not have any documentation of being\ninspected.\nVector personnel indicated that the valve at Milford Junction was being inspected, but\ncould not provide the documentation. Vector also maintained that the valves at the\nWashington Station were being inspected during their annual emergency shut-down test\n(ESD), but could not provide any documentation to show that those valves operated\nduring the ESD test.\n4. §192.481 Atmospheric corrosion control: Monitoring.\n(b) During inspections the operator must give particular attention to pipe at soil-to-\nair interfaces, under thermal insulation, under disbonded coatings, at pipe supports,\nin splash zones, at deck penetrations, and in spans over water.\nAt the Highland Station, Vector did not conduct an evaluation of the soil to air interface\nfor 2011 where the suction and discharge piping go through the foundation wall and into\nthe soil. Additionally, Vector has not been monitoring and documenting the inspection of\nthe above ground insulated piping that have inspection ports.\nIn 2008, the MI-PSC discussed their concerns about the inspections at these locations to\nVector personnel. As a result, Vector excavated these locations and completed a guided\nwave evaluation on the piping and reportedly found no defects. In order to conduct future\nexaminations, Vector made an attempt to install rubber boots between the exterior of the\nfoundation wall, and the pipe, which would allow inspection of the interface. However,\nupon backfilling the locations, the rubber boot collapsed and there was no way to observe\nthe interface. Vector personnel should make repairs to these locations in order to evaluate\nthe locations effectively.\nVector also has above ground stainless steel piping that is insulated for noise abatement\npurposes. In order to facilitate the atmospheric corrosion inspection, Vector personnel\ninstalled inspection ports to monitor for any possible corrosion. To date, Vector has not\ninspected this installation.\n3\n\n\n\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 Vector Pipeline, L.P. being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2012-1001W. 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,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":7502}