{"operation":"document","citation":"CPF 420085010W","title":"SFPP, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-02","effective_on":null,"summary":"CLOSED warning letter citing 195.308, 195.505, 195.583(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420085010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420085010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420085010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420085010W","body":"Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulations as 195.308,  195.505,  195.583(b). The case was opened on 2008-04-02 and is reported as closed as of 2008-04-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420085010W_warning_04022008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085010W/420085010W_warning_04022008.pdf\n\n420085010w_warning_04022008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085010W/420085010w_warning_04022008_text.pdf\n\n420085010w_warning_04022008_text.pdf\n\nU. S. Department\nof Transponatian\nIs)pet)no and\nHazardous itttaterlats safely\nAdministration\n870t soutn osstster, suits ti i 0\nHouaton, tX 7707O\nWARNING LETTER\nCERTIFIED IIAIL - RETURN RECEIPT REQUESTED\nApril 2, 2008\nMr. Ron McClain\nVice Presiderit of Operations\nSFPP, L. P.\n500 Dallas Street, Suite 1000\nHouston, TX 77002\nCPF 4-2008-501 0W\nDear Mr. McClain:\nOn April 22-27, 2007, and July 10-12, 2007, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected a portion of your SFPP Pipeline system in Texas and New Mexico and the control\ncenter in Orange, California.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n1. 195. 308 Pipe associated with tie-ins must be pressure tested, either with the\nsection to be tied in or separately\n195. 404 (a) Each operator shall maintain current maps and records of its pipeline\nsystems that include at least the following information;\n(4) The diameter, grade, type and nominal wall thickness of all pipe.\nThe operator has records showing that a pressure test for several numbered joints of pipe was\ncertified by the California State Fire Marshall's office and these joint numbers have been\nrecorded on the inside of the pipes held as pre-tested pipe inventory at locations on the pipeline\nsystem. However, the operator could not produce records that tie the pre-tested pipe inventory\n\n\n\nto a mill specification or original purchase order showing the pipe characteristics, including\ndiameter, wall thickness, and yield strength.\n2. 195. 505 Each operator shall have and follow a written qualification program. The\nprogram shall include provisions to: (b) Ensure through evaluation that\nindividuals performing covered tasks are qualified;\nThe operator presented records showing that atmospheric corrosion inspections for the above-\nground valve components were performed as part of the mainline valve inspections. However,\naccording to the SFPP operator qualification program records, the valve inspector was not\nqualified to perform atmospheric corrosion inspections.\n3. 195. 583 (b) During inspections you must give particular attention to pipe at soil-\nto-air interfaces, under thermal insulation, under disbonded coatings, at pipe\nsupports, in splash zones, at deck penetrations, and in spans over water.\nA partially buried valve at Lordsburg Maintenance Building (MP 159) had a loose wrap at the\nair/soil interface exposing the metal to the soil. Also, the supporting span crossing the Rio\nGrande River had peeling paint and evidence of corrosion.\nUnder 49 United States Code, g 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Failure to do so will result in SFPP being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2008-5010W. Be advised that ail 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).\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration","truncated":false,"body_characters":4680}