{"operation":"document","citation":"CPF 320175004W","title":"WHITE CLIFFS PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-11","effective_on":null,"summary":"CLOSED warning letter citing 195.404(a), 195.404(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320175004W","body":"Warning Letter involving WHITE CLIFFS PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.404(a),  195.404(c)(3). The case was opened on 2017-05-11 and is reported as closed as of 2017-05-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320175004W_Warning Letter_05112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175004W/320175004W_Warning%20Letter_05112017.pdf\n\n320175004W_Warning Letter_05112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175004W/320175004W_Warning%20Letter_05112017_text.pdf\n\n320175004W_Warning Letter_05112017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 11, 2017\nMr. David Minielly\nVice President of Operations\nWhite Cliffs Pipeline, LLC\n6120 S. Yale Ave.\nSuite 1500\nTulsa, Oklahoma 74136\nCPF 3-2017-5004W\nDear Mr. Minielly:\nOn October 3rd – 14th, 2016, representatives of the Central Region office of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your records and facilities at your offices in Colorado, Kansas, and\nOklahoma.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) 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(c) Each operator shall maintain the following records for the periods specified:\n(3) A record of each inspection and test required by this subpart shall be maintained\nfor at least 2 years or until the next inspection or test is performed, whichever is\nlonger.\n\n\n\nWhite Cliffs Pipeline did not document the effectiveness review of the procedures controlling\nabnormal operations and did not document the corrective actions taken where deficiencies\nwere found. White Cliffs typically completes the review after each abnormal operation occurs\nand takes the necessary corrective actions, but the required documentation was not completed.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the item(s) identified in this letter. Failure to do so will\nresult in White Cliffs Pipeline, LLC 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 3-2017-5004W. 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,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":3953}