{"operation":"document","citation":"CPF 420175034W","title":"ENTERPRISE CRUDE PIPELINE LLC — 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 195.402(c)(13).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175034w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175034w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175034w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175034W","body":"Warning Letter involving ENTERPRISE CRUDE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(13). 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\n420175034W_Operator Response To Notice_11302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175034W/420175034W_Operator%20Response%20To%20Notice_11302017.pdf\n\n420175034W_Warning Letter_10272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175034W/420175034W_Warning%20Letter_10272017.pdf\n\n420175034W_Warning Letter_10272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175034W/420175034W_Warning%20Letter_10272017_text.pdf\n\n420175034W_Warning Letter_10272017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 27, 2017\nMr. Graham Bacon\nSenior Vice President\nEnterprise Crude Pipeline, LLC\n1100 Louisiana Street\nHouston TX 77002\nCPF 4-2017-5034W\nDear Mr. Bacon:\nOn 7-11 August 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\nyour Enterprise Rancho Pipeline in the Houston Texas Metro area.\nAs a result of the inspection, it is alleged that you have committed a probably violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation is:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph\n(a) of this section must include procedures for the following to provide safety\nduring maintenance and normal operations:\n(13) Periodically reviewing the work done by operator personnel to\ndetermine the effectiveness of the procedures used in normal operation\nand maintenance and taking corrective action where deficiencies are\nfound.\n\n\n\nEnterprise Products failed to document the names of personnel being periodically reviewed\nconducting maintenance and normal operations. Periodic reviews of maintenance and normal\noperations work done by operator personnel are documented on Enterprise Form 601A. However,\nthe electronic documents did not list the name of the personnel being reviewed. The electronic\nversion of Enterprise Form 601A lists the name of the Enterprise employee who inspected the\nwork, and the employee who closed out the work order, but does not identify the operator personnel\nwho performed the work reviewed. On Form 601A, there is a space to document the reviewed\nemployee’s name and employee number, and the supervisor’s information and the date of the\nreview. The operator stated that on the electronic form, the “Inspected By” name is the employee\nbeing reviewed, and the “Closed By” name is the person reviewing that employee’s work. For 6\nJan 2017, on the printed electronic version, the form has R G Fitzpatrick for both the “Inspected\nBy” employee and the “Closed By” employee. R G Fitzpatrick is the supervisor.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in\nthis case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item identified in this letter. Failure to do\nso will result in Enterprise Crude Pipeline, LLC 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 4-2017-5034W. 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 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":4450}