{"operation":"document","citation":"CPF 420125034W","title":"BOARDWALK PETROCHEMICAL PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-11-02","effective_on":null,"summary":"CLOSED warning letter citing 195.505(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125034w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125034w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125034w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420125034W","body":"Warning Letter involving BOARDWALK PETROCHEMICAL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 195.505(b). The case was opened on 2012-11-02 and is reported as closed as of 2012-11-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420125034W_Warning Letter_11022012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125034W/420125034W_Warning%20Letter_11022012.pdf\n\n420125034W_Warning Letter_11022012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125034W/420125034W_Warning%20Letter_11022012_text.pdf\n\n420125034W_Warning Letter_11022012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 2, 2012\nMr. Randall L. Curry\nPresident\nChevron Petrochemical Pipeline LLC\n4800 Fournace Place\nBellaire, Texas 77401-2324\nCPF 4-2012-5034W\nDear Mr. Curry:\nDuring August 13-17 and October 3, 2012, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your Evangeline Ethylene Pipeline System at Lafayette, Louisiana and Bellaire, Texas.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. §195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(b) Ensure through evaluation that individuals performing covered tasks are\nqualified;\nChevron Pipeline Company (Chevron) failed to follow their written qualification program.\nChevron’s Pipeline Operator Qualification Program, latest revision dated: November 18, 2011,\nsection 6.1 states the qualified individual must sign or initial any reports or documentation\nassociated with performance of the covered task.\n\n\n\nOn February 14, 2008, Chevron made a fiberglass composite repair on a 16” diameter pipe\nbetween station 762+26.5 and 762+30.5 due to external metal loss type features located by MFL\ntool run. An Inspection, Repair, Replacement and Crossing Report were completed by Mr. Ladd\nHebert. When a PHMSA inspector requested the qualification paperwork of Mr. Hebert,\nChevron informed the PHMSA inspector that Mr. Hebert was not qualified and he was observed\nand supervised by Mr. Robin Roberts. Further investigation revealed Mr. Roberts was found\nqualified and Chevron provided a copy of Mr. Robert’s timesheet dated February 14, 2008\ndepicting he was present at the work site.\nAccording to Chevron Pipeline Operator Qualification Program, an Inspection, Repair,\nReplacement and Crossing Report should have been completed by Mr. Roberts, a qualified\nemployee and not by Mr. Hebert. Chevron failed to follow their written qualification program\nrequirement.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Chevron Petrochemical Pipeline LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2012-5034W. 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).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4419}