{"operation":"document","citation":"CPF 420075001W","title":"PLAINS PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-01-17","effective_on":null,"summary":"CLOSED warning letter citing 195.420(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420075001W","body":"Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulation as 195.420(c). The case was opened on 2007-01-17 and is reported as closed as of 2007-01-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420075001W_Warning Letter_01172007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075001W/420075001W_Warning%20Letter_01172007.pdf\n\n420075001W_Warning Letter_01172007.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n8701 South Gessner, Suite 11 10\nHouston, TX 77074\nWARNING LETTER\nJanuary 17,2007\nMr. Harry N. Pefannis\nPresident\nPlains Pipeline, LP\nP.O. Box 4468\nHouston, TX 7721 0\nCPF NO. 4-2007-5001 W\nDear Mr. Pefannis:\nDuring the months of September and November, 2006, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Southwest Region, pursuant to Chapter\n601 of 49 United States Code, conducted a pipeline safety inspection of Plains Pipeline, LP\nliquid pipeline systems facilities and records.\nAs a result of the inspections, it appears that you have committed probable violations as noted\nbelow of pipeline safety regulations Title 49, Code of Federal Regulations, Part 195. The items\ninspected and the probable violations are:\n91 95.420 Valve maintenance\n(c) Each operator shall provide protection for each valve from unauthorized\noperation and from vandalism.\nA number of the Plains Pipeline LP pipeline valves do not have protection from\nvandalism at the sites. The valves were chained and locked to prevent unauthorized\nuse, but these locations did not provide any deterrence against vandalism. Local\npersonnel did provide additional information regardiqg this issue.\nDuring the inspections it was noted that Plains' preferred method of complying with\n195.420~ is to install locked chain link fencing around the valves. This was evident in the\n\n\n\nthree Plains units that were inspected, where the majority of above ground valves were\nlocated in locked fences.\nSome of the remaining valves in those units were located above ground with no fences.\nThe number of above ground valves that were observed without fences by the inspector on\nthe three Texas and Louisiana units exceeded seven, and the lack of fencing was pointed\nout to Plains personnel at the time of the inspections. Several above ground valves were\nalso observed without fences by the inspector in the marsh of the Louisiana unit of Plains.\nIt should be pointed out that all of the unfenced valves were chair1 locked and most had\nsteel barricade posts installed. A review of your procedures by our inspectors did not\nreveal any alternative method of security for valve sites acceptable to you. Plains should\nreview their program, procedures, and facilities to ensure they are compliant with this\nregulation.\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 violations persists up to a maximum of $1,000,000\nfor any related series of violations. With respect to item 1 we have reviewed the circumstances\nand supporting documents involved in this case and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time.\nWe advise you to promptly correct these item(s). Be advised that failure to do so may result in\nPlains Pipeline LP being subject to additional enforcement action.\nIn your correspondence on this matter, please refer to CPF 4-2007-5001W and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration","truncated":false,"body_characters":3758}