# PLAINS PIPELINE, L.P. — Warning Letter

- **operation:** document
- **citation:** CPF 32022041WL
- **title:** PLAINS PIPELINE, L.P. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-03-04
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.446(e)(3), 195.446(e)(4).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32022041wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32022041wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32022041wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32022041WL
**body:**

Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.446(e)(3),  195.446(e)(4). The case was opened on 2022-03-04 and is reported as closed as of 2022-03-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32022041WL_Operator Response to Notice_04012022_(21-201003).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022041WL/32022041WL_Operator%20Response%20to%20Notice_04012022_(21-201003).pdf

32022041WL_Warning Letter_03042022_(21-201003).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022041WL/32022041WL_Warning%20Letter_03042022_(21-201003).pdf

32022041WL_Warning Letter_03042022_(21-201003)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022041WL/32022041WL_Warning%20Letter_03042022_(21-201003)_text.pdf

32022041WL_Warning Letter_03042022_(21-201003)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: hnpefanis@paalp.com and khcunningham@paalp.com
March 4, 2022
Mr. Harry Pefanis
President/CEO
Plains Pipeline, LP
333 Clay Street, Suite 1600
Houston, TX 77002
CPF 3-2022-041-WL
Dear Mr. Pefanis:
From June 14 to July 20, 2021, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), remotely
inspected Plains Pipeline, LLC’s (Plains) Control Room Management (CRM) procedures and
records in Midland, Texas.
As a result of the inspection, it is alleged that Plains has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 195.446 Control room management.
(a) . . .
(e) Alarm Management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms. An
operator’s plan must include provisions to:
(1) . . .
(3) Verify the correct safety-related alarm set-point values and alarm descriptions
when associated field instruments are calibrated or changed and at least once each
calendar year, but at intervals not to exceed 15 months.
Plains failed to complete the verification of correct safety-related alarm set-point values and
alarm descriptors when associated field instruments are calibrated or changed and at least once
each calendar year, but at intervals not to exceed 15 months. The operator stated, during the
inspection, that prior to 2020, they were "just relying on the fact that safety related alarms were
part of DOT maintenance; they were dependent upon the field doing the job.” They could not
validate that all safety related alarms were verified through this process.



In 2020, Plains changed its process (Section 6.6.12) to export all safety-related alarms to a
format where it could review the set points and alarm descriptions. While Plains staff indicated
they did look at all alarms, they did not have the documentation to support what they looked at.
Plains also modified its O&M manual to include the field safety related points and flagged them
in Maximo, the operator’s work management system, as required work tickets. This was noted
on the annual review log changes completed on February 5, 2021.
2. § 195.446 Control room management.
(a) . . .
(e) Alarm Management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms. An
operator’s plan must include provisions to:
(1) . . .
(4) Review the alarm management plan required by this paragraph at least once
each calendar year. But at intervals not exceeding 15 months, to determine the
effectiveness of the plan.
Plains failed to follow their procedure to provide documentation demonstrating compliance it
performed review of the Alarm Management Plan (AMP) at least once each calendar year, but at
intervals not exceeding 15 months, in order to determine the effectiveness of the plan for 2018,
2019, and 2020. In a review of the records, there was no reference or documentation of the
performance measures outlined in sections 6.6.10.3.1 - 6.6.10.3.7 of the AMP. The Alarm
Management Review Form has dates of 3/25/2019, 10/9/19, and 10/1/2020. A note in the
3/25/2019 review findings from the AMP review were noted in form 2018 CRM Plan and
Procedures Review Improvement Action Items. This was a general tracking document for action
items from review various control room procedures. Some of the items were obviously related to
the Alarm Management Plan. While it appears some portion or all the review was completed in
2018, the documentation is dated in 2019. The operator was not able to explain this.
A document titled Pacific Pipeline Systems Console Procedures Annual Review Checklist
6/29/2020, provided as a 2020 compliance record, was submitted as an example for all
consoles. Section 2 under the Console - Specific SCADA System & Screen Review provided
questions for review related to accuracy of the SCADA data base for alarms set points and
descriptions. This was not in the procedure. It could have been included as a performance
measure, but it was not.
Also, while recommendations were made for improvements, there was no documentation to
demonstrate what was reviewed, results compared to metrics, findings/deficiencies, and
corrective actions. All that was provided were corrective actions. There were no links between
performance measurements, findings/deficiencies, proposed corrective actions, completion of
action items and documentation.
2



Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a
related series of violations. For violation occurring on or after January 11, 2021 and before May
3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation
persists, up to a maximum of $2,225,034 for a related series of violations. For violation
occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for
a related series of violations. For violation occurring on or after November 27, 2018 and before
July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a
maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,
2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per
violation per day, with a maximum penalty not to exceed $2,090,022.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to conduct additional 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
Plains Pipeline, LP 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 3-2022-041-WL. 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,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Kevin Cunningham, Director, HSE Compliance Programs (khcunningham@paalp.com)
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