{"operation":"document","citation":"CPF 420145007W","title":"VALERO TERMINALING AND DISTRIBUTION COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-04-09","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a), 195.446(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420145007W","body":"Warning Letter involving VALERO TERMINALING AND DISTRIBUTION COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.428(a),  195.446(e)(5). The case was opened on 2014-04-09 and is reported as closed as of 2014-04-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420145007W_Warning_04092014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145007W/420145007W_Warning_04092014.pdf\n\n420145007W_Warning_04092014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145007W/420145007W_Warning_04092014_text.pdf\n\n420145007W_Warning_04092014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 9, 2014\nMr. Rodney Reese, Vice President\nValero Terminaling and Distribution Company\nOne Valero Way\nSan Antonio, Texas 78249\nCPF 4-2014-5007W\nDear Mr. Reese:\nOn December 9-12, 2013 and January 20-22, 2014, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your Valero Terminaling and Distribution Company (Valero) Turpin\nCrude pipeline system and Valero Pipeline Control Center in Perryton, Texas and San Antonio,\nTexas.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, and Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n\n\n\n1. §195.428 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 7½\nmonths, but at least twice each calendar year, inspect and test each pressure limiting\ndevice, relief valve, pressure regulator, or other item of pressure control equipment\nto determine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nValero exceeded the 15 month inspection interval for its Sunray Station high pressure shut down\nswitch by 38 days. Based on records reviewed at Valero’s Perryton office, it was observed that\nSunray Station’s high pressure shut down switch was inspected on May 9, 2012. The subsequent\ninspection of the high pressure shutdown switch was performed on September 16, 2013.\n2. §195.446 Control room management.\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(5) Monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals not\nexceeding 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms\nValero did not provide documentation for the calendar years 2012 and 2013, that the content and\nvolume of general activity being directed to and required of each controller was being monitored\nat least once each calendar year not to exceed 15 months. Valero commissioned a Workload\nAnalyses of the San Antonio Pipeline Control Center that was finalized November 16, 2011. The\nnext documented Workload Analysis was completed on March 6, 2014.\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 items identified in this letter.\nFailure to do so will result in Valero 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 4-2014-5007W. 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\n2\n\n\n\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\n3","truncated":false,"body_characters":4977}