{"operation":"document","citation":"CPF 32021008WL","title":"ENERGY TRANSFER COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-02-02","effective_on":null,"summary":"CLOSED warning letter citing 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021008wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021008wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021008wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021008WL","body":"Warning Letter involving ENERGY TRANSFER COMPANY. PHMSA's enforcement data identifies the cited regulation as 195.589(c). The case was opened on 2021-02-02 and is reported as closed as of 2021-02-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021008WL_Operator Response to Notice_03042021_(20-196716).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021008WL/32021008WL_Operator%20Response%20to%20Notice_03042021_(20-196716).pdf\n\n32021008WL_Warning Letter_02022021_(20-196716).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021008WL/32021008WL_Warning%20Letter_02022021_(20-196716).pdf\n\n32021008WL_Warning Letter_02022021_(20-196716)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021008WL/32021008WL_Warning%20Letter_02022021_(20-196716)_text.pdf\n\n32021008WL_Warning Letter_02022021_(20-196716)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: matthew.ramsey@energytransfer.com ,\ngregory.mcilwain@energytransfer.com and todd.nardozzi@energytransfer.com\nFebruary 2, 2021\nMr. Matt Ramsey\nChief Operating Officer\nEnergy Transfer Partners, LLC\nRose Rock White Cliffs\n8111 Westchester,\nDallas, TX 75225\nCPF 3-2021-008-WL\nDear Mr. Ramsey:\nOn September 29 through November 16, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected your RoseRock White Cliffs Pipeline LLC (White Cliffs) field assets and\nfield records both virtually and onsite in Colorado and Kansas.\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 violation is:\n\n\n\n1. §195.589 What corrosion control information do I have to maintain?\n(a) …\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. 195.569,\n195.573(a)and (b), and 195.579(b)(3)and (c) must be retained for as long as the\npipeline remains in service.\n§195.571 What criteria must I use to determine the adequacy of cathodic protection?\nCathodic protection required by this subpart must comply with one or more of the\napplicable criteria and other considerations for cathodic protection contained in\nparagraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by\nreference, see § 195.3).\nWhite Cliffs failed to maintain records of IR drop consideration for test points in the White\nCliffs system for the time period 2018-2020 as also required by their IR drop consideration\nprocedure noted in italics below. The six stations below failed to have IR drop consideration\ninformation as listed below:\n Sharon Station WC1\n Sharon Station WC2\n Laird Station WC1\n Laird Station WC2\n Cunningham Station WC1\n Cunningham Station WC2\nRose Rock IR Drop Consideration Procedure:\n3.6 IR Drop Consideration 195.571\n3.6.1 Voltage drop is considered by taking potential readings directly over, or as near as\npractical to the structure surface. The effect of the potential measuring circuit is kept to a\nminimum by using a high resistance voltmeter and being mindful of lead lengths and\ncondition, contact to structure and contact to electrolyte.3.6.2. At locations where the\npipe-to-soil reading is suspected to not represent the cathodic protection level on the\nstructure, the cathodic protection level can be determined by utilizing one or more of the\nfollowing methods:\n3.6.2.1 Measuring or calculating the voltage drops\n3.6.2.2 Reviewing the historical performance of the cathodic protection system\n3.6.2.3 Evaluating the physical or electrical characteristics of the pipeline and its\nenvironment\n3.6.2.4 Determining if there is physical evidence of corrosion\n2\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Energy Transfer Partners LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2021-008-WL. 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: Mr. Gregory Mcilwain, Operations VP, Energy Transfer Partners, LLC,\ngregory.mcilwain@energytransfer.com\nMr. Todd Nardozzi, Director Regulatory Compliance, Energy Transfer Partners, LLC,\ntodd.nardozzi@energytransfer.com\n3","truncated":false,"body_characters":5670}