{"operation":"document","citation":"CPF 420175033W","title":"WEST TEXAS GULF PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-10-27","effective_on":null,"summary":"CLOSED warning letter citing 195.310(a), 195.310(b)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175033w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175033w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175033w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175033W","body":"Warning Letter involving WEST TEXAS GULF PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.310(a),  195.310(b)(4). The case was opened on 2017-10-27 and is reported as closed as of 2017-10-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175033W_Warning Letter_10272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175033W/420175033W_Warning%20Letter_10272017.pdf\n\n420175033W_Warning Letter_10272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175033W/420175033W_Warning%20Letter_10272017_text.pdf\n\n420175033W_Warning Letter_10272017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 27, 2017\nMr. Ryan Coffey\nVice President of Operations\nWest Texas Gulf Pipeline Company\n800 East Sonterra Boulevard\nSan Antonio, TX 78258\nCPF 4-2017-5033W\nDear Mr. Coffey:\nOn June 5 - 8, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nthe West Texas Gulf Pipeline Company at your Corsicana Field Office (Wortham Station) in\nCorsicana, Texas.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation is:\n1. §195.310 Records\n(a) A record must be made of each pressure test required by this subpart, and\nthe record of the latest test must be retained as long as the facility tested is in\nuse.\n(b) The record required by paragraph (a) of this section must include:\n(4) The date and time of the test;\nWest Texas Gulf Pipeline Company (WTG-PELA) failed to provide complete records to PHMSA\nrepresentative for the hydrostatic test of Breakout Tank 45.\n\n\n\nWest Texas Gulf Pipeline Company (WTG-PELA) states in two (2) separate procedures the\nretention period of all documentation shall be for the life of the tank and also, date, time and\nambient temperature should be recorded at intervals not to exceed two (2) hours.\nNew hydrotest records were submitted to the Southwest Region via email on June 29, 2017 after\nthey were initially reviewed in the field on June 8, 2017. PHMSA representatives gave WTG-\nPELA the opportunity to obtain the complete record.\nWTG-PELA both hydrotest records to PHMSA representative included the following information:\nDate/time hydrotest started on January 8, 2016 and date/time hydrotest completed on January 14,\n2016. 24-hour hold started on January 15, 2016 at 9:00 a.m. and to be completed on January 16,\n2016 at 9:00 a.m.\nHowever, both records reading and observation at two (2) hour intervals were dated from January\n8, 2016 at 3:30 p.m. through January 15, 2016 at 9:00 a.m. The missing information included\nhydrotest date and time between January 15, 2016 at 9:00 a.m. through January 16, 2016 at 9:00\na.m.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 for a 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 in\nthis letter. Failure to do so will result in West Texas Gulf Pipeline Co. 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 4-2017-5033W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nTerri J. Binns\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4319}