# WESTERN REFINING LOGISTICS, LP — Warning Letter

- **operation:** document
- **citation:** CPF 420085017W
- **title:** WESTERN REFINING LOGISTICS, LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2008-07-01
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.402(c), 195.420(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420085017w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420085017w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420085017w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420085017W
**body:**

Warning Letter involving WESTERN REFINING LOGISTICS, LP. PHMSA's enforcement data identifies the cited regulations as 195.402(c),  195.420(c). The case was opened on 2008-07-01 and is reported as closed as of 2008-07-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420085017W_warning letter_07012008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085017W/420085017W_warning%20letter_07012008.pdf

420085017w_warning letter_07012008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085017W/420085017w_warning%20letter_07012008_text.pdf

420085017w_warning letter_07012008_text.pdf

U, 5, DepoItmerIr
of TranspoItalioiI
Pipeline ond
Hozor'clous iftoterlots Sofety
Aamlnisirotion
8701 South Gcssher, SuIIC 1110
Hausian, TX 77074
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT RE VESTED
July 1, 2008
Mr. Leroy Crow
Senior Vice President
Western Refining Pipeline Company
123 W. Mills Avenue
El Paso, TX 79901
CPF 4-2008-5017W
Dear Mr. Crow:
On November 27 — December 1, 2006, January 9 — 12, 2007, August 20 — 24, 2007, and November 13—
16, 2007, representatives of the Pipeline ahd Hazardous Materials Safety Administration (PHMSA)
pursuant to Chapter 601 of 49 United States Code inspected your 424 mile 16-inch pipeline in New
Mexico. The operator at the time of the inspections was Giant Industries, Inc (Giant). We were contacted
by you and made aware that Western Refining (Western) acquired Giant effective November 14, 2007.
As a result of the inspection, it appears that you have committed a probable violation of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation
Is:
1. 5195A02 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual of
written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and appropriate
changes made as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline commence, and appropdiate parts shall be
kept at locations where operations and maintenance activities are conducted.
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(13) Periodically reviewing the work done by operator to determine the
effectiveness of the procedures used in normal operation and maintenance and
taking corrective action where deficiencies are found.



At the time of the inspection, Giant was unable to show records of periodic review of the work done by the
operator to determine the effectiveness of the procedures used in normal operation and maintenance and
taking corrective action where deficiencies are found.
Inspector notes taken during the inspection indicate that Section 1. 3. 5 and Form OM-105 address this
requirement, but records of the reviews could not be shown.
2. 5195. 420 Valve maintenance.
(c) Each operator shall provide protection for each valve from unauthorized operation and
from vandalism.
Numerous valves were found without locks during the course of the field inspections. These were
corrected as found by the operator before leaving each location. It is noted that these were on newly
installed valves and site security was being addressed as part of the start up activities.
Under 49 United States Code, () 60122, you are subject to a civil penalty not to exceed $100, 000 for each
violation for each day the violation persists up to a maximum of $1, 000, 000 for any related series of
violations. 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 identified in this letter. Failure to do so will result in Western
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 4-
2008-5017W, 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).
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
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