{"operation":"document","citation":"CPF 420145032W","title":"PLAINS PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-12-03","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(2), 195.410(a)(1), 195.581(a), 195.581(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145032w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145032w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145032w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420145032W","body":"Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(2),  195.410(a)(1),  195.581(a),  195.581(b). The case was opened on 2014-12-03 and is reported as closed as of 2014-12-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420145032W_Warning_12032014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145032W/420145032W_Warning_12032014.pdf\n\n420145032W_Warning_12032014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145032W/420145032W_Warning_12032014_text.pdf\n\n420145032W_Warning_12032014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 3, 2014\nMr. Troy Valenzuela\nVP, Environmental Health & Safety\nPlains Pipeline, L.P.\n333 Clay Street, Suite 1600\nHouston, TX 77002\nCPF 4-2014-5032W\nDear Mr. Valenzuela:\nBetween February 18, 2014 – August 29, 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your procedures, records, and pipeline facilities in the States of Louisiana, Illinois,\nOklahoma, New Mexico, and Texas.\nAs a result of the inspection, it appears that you have committed § 195.404(c) (2) of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation(s) are:\n1. § 195.404 Maps and records.\n(c) Each operator shall maintain the following records for the periods specified:\n(2) The date, location, and description of each repair made to parts of the pipeline\nsystem other than pipe shall be maintained for at least 1 year.\nOver pressure protection records for the Tussy Station indicated that the set point was found at 0\npsi on 8/9/13, but there was no description of the problem identified in the inspection comment\n\n\n\nnotes for this equipment. Operator stated that the equipment was newly installed at that time, so\nthere would be no previous or “found” pressure set point at the time of the equipment test.\nOperator needs to verify pipeline system records include descriptions for each repair or test data\nthat could be interpreted as equipment not operating properly.\n2. § 195.410 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\nfollowing:\n(1) Markers must be located at each public road crossing, at each railroad crossing,\nand in sufficient number along the remainder of each buried line so that its location\nis accurately known.\nThere were not a sufficient number of line markers along each buried pipeline so that their\nlocation could be accurately known on the Buffalo pipeline system.\nLine markers were needed on the ROW entering the Dove Truck station; on the east side of the\nHwy 58 crossing; ROW on west side of MLV – B 011; on top of hill between MLV – B 010 and\nHwy 530; and north of Stockholm Station in the direction of Harpers Ranch.\n3. § 195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to\nthe atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\nAbove ground piping was not properly coated to prevent atmospheric corrosion at different\nlocations on the pipeline system. Piping at the following locations need to be cleaned and\ncoated: 1) Quitman station had paint peeling off; 2) Healdton pump station had coating\ndegradation at the flanges and manifolds; 3) coating degradation at MLV-15, MLV-16, MLV-B\n011, MLV-B 09, MLV-B 07 (All Buffalo pipeline system); 4) three pumps at Blaine Station; 5)\nand newly installed piping had not been painted at Stockholm station.\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\n2\n\n\n\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Plains Pipeline L.P. 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 4-2014-5032W. 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\n3","truncated":false,"body_characters":5430}