{"operation":"document","citation":"CPF 420085019W","title":"CYPRESS INTERSTATE PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-08-01","effective_on":null,"summary":"CLOSED warning letter citing 195.410(a)(2), 195.428(a), 195.577(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420085019w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420085019w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420085019w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420085019W","body":"Warning Letter involving CYPRESS INTERSTATE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.410(a)(2),  195.428(a),  195.577(a). The case was opened on 2008-08-01 and is reported as closed as of 2008-08-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420085019W_Warning Letter_08012008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085019W/420085019W_Warning%20Letter_08012008.pdf\n\n420085019w_warning letter_08012008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420085019W/420085019w_warning%20letter_08012008_text.pdf\n\n420085019w_warning letter_08012008_text.pdf\n\nu5. Oeponrnenl\nof Transportation\nRIpetins ana\nNaxaraous Hlatertats safety\nA4minfstrafion\n8701 Secre Gewheh S@hr 1110\n4 eeslee, FX Ti074\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 1, 2008\nMr. Ron McClain\nV. P. Operations & Engineering\nKinder Morgan Energy Partners, L. P.\n500 Dallas Street, Suite 1000\nHouston, TX 77002\nCPF 4-2008-5019W\nDear Mr. McClain:\nOn May 19-22 and July 8, 2008, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour Cypress Pipeline records and facilities in Houston, TX, Mont Beivieu, TX, and various\npoints along the pipeline route from Mont Belvieu, TX lo Sulphur, LA.\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:\n195. 410 Line Markers.\n(a) Except as provided in paragraph (b) of this section, each operator shall place\nand maintain line markers over each buried pipeline in accordance with the\nf0 I lowing:\n(2) The marker must state at least the following on a background of\nsharply contrasting color:\n(ii) The name of the operator and a telephone number (including area code)\nwhere the operator can be reached at all times.\n195. 434 Signs.\nEach operator must maintain signs visible to the public around each pumping\nstation and breakout tank area. Each sign must contain the name of the operator\nand a telephone number (including area code) where the operator can be reached\nat all times.\n\n\n\nA few pipeline markers and signs for the Cypress Pipeline did not display the correct emergency\ntelephone number where the operator can be reached at all times. Kinder Morgan completed\nthe sale of a portion of the Cypress Pipeline assets known as the \"North System\" near the end\nof calendar year 2007. This agreement transferred the emergency telephone number for the\nCypress Pipeline to the new operator. After the sale, Kinder Morgan changed the emergency\ntelephone number on the vast majority of markers for the portion of the Cypress Pipeline system\nthat was retained. However, the field inspection revealed that a few markers still displayed the\nold emergency telephone number, including markers at Holis Road and a sign at the Westlake\nChemical Plant site. Kinder Morgan must ensure that all of the Cypress Pipeline line markers\ndisplay the correct emergency telephone number.\n195. 428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed\n7/a months, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\nThe testing employed by Kinder Morgan for pressure relief devices is not adequate to determine\nthat it is functioning properly, is in good mechanical condition, and is adequate from the\nstandpoint of capacity and reliability of operation. Records indicate that the relief valve tests\nconfirmed the exact set point in every test performed. During the field inspection, a qualified\nrepresentative of the operator was asked to demonstrate the relief device testing process at\nSpindletop Pump Station. Once the selected relief device was isolated, inert gas was slowly\napplied until the valve was just slightly raised off of the seat as evidenced by a pressure gauge\nreading that oscillated narrowly above and below the set point. The operator explained that the\nrelief device was not tested to the full open position due to the valve frequently failing to reseat\nafter this type of test. However, this test does not adequately test the mechanical condition of\nthe relief device and failure to reseat could result from debris within the device or a mechanical\nproblem. Kinder Morgan must ensure that the testing being performed satisfies the\nrequirements to confirm proper function, good mechanical condition, and adequate from the\nstandpoint of capacity and reliability of operation for the service in which it is used.\n4. 195. 577 What must I do to alleviate interference currentsg\n(a) For pipelines exposed to stray currents, you must have a program to identify,\ntest for, and minimize the detrimental effects of such currents.\n\n\n\nKinder Morgan has not performed interference testing to ensure that stray currents are not\nproducing a detrimental effect on the Cypress Pipeline system. Annual cathodic protection\nreadings show a significant drop in potentials at several foreign pipeline crossings along the\nCypress Pipeline route. Some examples include the Equilon crossing at milepost 1. 8, the Sun\nOil crossing at milepost 58. 4, and the Exxon crossing at milepost 75. 3. The operator must\nensure that interference currents, possibly sourced from adjacent pipelines with impressed\ncurrent cathodic protection systems, are not damaging the Cypress Pipeline.\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 Kinder Morgan Energy Partners, L. P. being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2008-5019W. 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).\nR, M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMatedals Safety Administration","truncated":false,"body_characters":7372}