{"operation":"document","citation":"CPF 420165028W","title":"TC OIL PIPELINE OPERATIONS INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-08-03","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.434, 195.581(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165028w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165028w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165028w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420165028W","body":"Warning Letter involving TC OIL PIPELINE OPERATIONS INC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.434,  195.581(a). The case was opened on 2016-08-03 and is reported as closed as of 2016-08-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420165028W_Warning Letter_08032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165028W/420165028W_Warning%20Letter_08032016.pdf\n\n420165028W_Warning Letter_08032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165028W/420165028W_Warning%20Letter_08032016_text.pdf\n\n420165028W_Warning Letter_08032016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 3, 2016\nMr. Vern Meier\nVice President Field Operations\nTC Oil Pipeline Operations, Inc.\n717 Texas Avenue\nHouston, TX 77002\nCPF 4-2016-5028W\nDear Mr. Meier:\nOn May 3-4, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nprocedures at pump station facility in Liberty County, TX and various mainline valve stations\nalong pipeline route from Liberty County, TX to Houston Tank Terminal in Houston, TX.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nLiberty County and various MLV stations’ plans or procedures as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies. This manual shall be reviewed\nat intervals not exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is effective. This\nmanual shall be prepared before initial operations of a pipeline system commence,\n\n\n\nand appropriate parts shall be kept at locations where operations and maintenance\nactivities are conducted.\n§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 the\natmosphere, except pipelines under paragraph (c) of this section.\nTransCanada failed to follow their procedures (TransCanada Pipelines Limited Facilities Piping\nFabrication and Installation Specification, Thread Compound Section 9.6.6) that require the\napplication of corrosion inhibitor (Jet Lube TF-15 or approved equal) to the flange bolts. At the time\nof the PHMSA inspection, the flange bolts showed extensive corrosion potentially compromising\ntheir strength.\n2. §195.434 Signs\n(a) Each 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 at\nall times.\nTransCanada failed to install adequate signage around the Liberty Pump Station as required by\n§195.434. TransCanada installed the signs after PHMSA identified the issue but the operator must\nensure that there is adequate signage at all the pumping stations and breakout tank areas.\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 TC Oil Pipeline being subject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2016-5028W. 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, SW Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4825}