{"operation":"document","citation":"CPF 320205030W","title":"CITGO PETROLEUM CORPORATION (TERMINALS) — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-11-05","effective_on":null,"summary":"CLOSED warning letter citing 195.446(c), 195.446(f)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320205030w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320205030w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320205030w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320205030W","body":"Warning Letter involving CITGO PETROLEUM CORPORATION (TERMINALS). PHMSA's enforcement data identifies the cited regulations as 195.446(c),  195.446(f)(2). The case was opened on 2020-11-05 and is reported as closed as of 2020-11-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320205030W_Warning Letter_11052020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320205030W/320205030W_Warning%20Letter_11052020.pdf\n\n320205030W_Warning Letter_11052020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320205030W/320205030W_Warning%20Letter_11052020_text.pdf\n\n320205030W_Warning Letter_11052020_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: Cjorda@citgo.com; Sbuckner@citgo.com\nNovember 5, 2020\nMr. Carlos E. Jordá\nVice President, Supply and Marketing\nCitgo Petroleum Corporation\n1293 Eldridge Parkway\nHouston, TX 77077\nCPF 3-2020-5030W\nDear Mr. Jordá:\nFrom June 16 to 20, 2019, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nthe Citgo Petroleum Corporation’s (Citgo) assets and records associated with Citgo’s East\nChicago Terminal in East Chicago, Indiana.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.446 Control room management.\n(a) . . .\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\n\n\n\nCitgo failed to provide its controllers with the information necessary for the controllers to carry\nout roles and responsibilities that the operator has defined. During the inspection, the screens on\nthe SCADA system in Citgo’s control room in Bryan, TX and the automation system in East\nChicago Terminal displayed identical identification numbering for two motor operated valves.\nHowever, this numbering is inconsistent with the remote identification numbering found in the\nfield.\nSpecifically, two valves (No. 12 and 13 as identified by their actual field equipment tags) at the\nBuckeye Bullpen (located on W Columbus Drive – outside the terminal) were manipulated during\nthe PHMSA inspection of the terminal and associated assets. However, the same two valves are\nidentified by the terminal and control center screens as valves No. 2 and 5 respectively. The\noperator indicated that the mainline block valves have a numbering system separate (and different)\nfrom what is shown on the screens since there is a relatively small number of mainline valves but\ndozens of manifold valves. However, differences in the identification of components between the\nfield and Citgo’s screens do not provide the controllers with adequate and consistent information\nin order to promptly react to emergency or abnormal operating conditions. Proper identification\nand operation of the correct equipment by the controller is critical to the safe operation of the\npipeline system.\n2. § 195.446 Control room management.\n(a) . . .\n(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following:\n(1) . . .\n(2) Require its field personnel to contact the control room when emergency conditions\nexist and when making field changes that affect control room operations.\nCitgo’s field personnel failed to contact the control room when making field changes that affect\ncontrol room operations. During the field inspection, PHMSA requested to observe a valve at the\nBuckeye Bullpen being moved in three modes: (1) remote operation by the Control Room in Bryan,\nTexas; (2) local operation by the onsite field operator accompanying PHMSA; and (3) manual\nturning. Citgo’s field personnel had the call to the control room on speaker phone in order to\nallow for the PHMSA inspectors to listen to the conversation.\nDuring the performance of the three operational modes, the phone conversations and co-\nordinational activities that took place immediately prior, during, and after the performance of each\nmode occurred between the field operator and the terminal operator. However, the terminal\noperator did not make a hold request at any time to contact the Control Room. Further, the remote\noperation of the valves was completed by the terminal operator (local controller) instead of the\nremote controller at the Control Room.\n2\n\n\n\nFollowing the field observation, Citgo indicated that terminal operator (local controller) usually\ndoes not operate those valves and that the control room in Bryan, Texas was notified by the\nterminal before sending the remote commands for opening and closing the valves. Citgo also\nindicated that they were going to make some modifications to the terminal operation and\nprocedures so that the local operators could not start and stop pumps nor move the Buckeye\nBullpen valves.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a\nrelated series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring\nprior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per\nday, with a maximum penalty not to exceed $2,000,000 for a related series of violations.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2019-5028W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nCc:\nScott Buckner\nRegional EHSS Manager\nCITGO Petroleum Corporation\n2316 Terminal Drive\nArlington Heights, IL 60005\nP: 847.867.2420\nSbuckner@citgo.com\n3","truncated":false,"body_characters":6918}