{"operation":"document","citation":"CPF 420181006W","title":"BBT TRANS-UNION INTERSTATE PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-04-25","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.614(c)(1), 192.615(b)(2), 192.615(b)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420181006W","body":"Warning Letter involving BBT TRANS-UNION INTERSTATE PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.614(c)(1),  192.615(b)(2),  192.615(b)(3). The case was opened on 2018-04-25 and is reported as closed as of 2018-04-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420181006W_Warning Letter_04252018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181006W/420181006W_Warning%20Letter_04252018.pdf\n\n420181006W_Warning Letter_04252018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181006W/420181006W_Warning%20Letter_04252018_text.pdf\n\n420181006W_Warning Letter_04252018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 25, 2018\nMr. David Lipp\nVP, Commercial and Regulatory\nTrans-Union Interstate Pipeline, L. P.\n10300 Town Park Dr.\nSuite SE1000\nHouston, TX 77072\nCPF 4-2018-1006W\nDear Mr. Lipp:\nFrom February 22-24, 2017 through July 24-28, 2017, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected the Trans-Union Interstate Pipeline, L.P. pipeline system that begins in\nBernice, Louisiana and traverses to El Dorado, Arkansas.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nTrans-Union failed to follow its written procedures for completing the HCA/Class Location\nevaluation report twice per year. During the inspection, the PHMSA inspector reviewed Trans-\nUnion OM&E procedures; Class Location Changes/HCA Section; page 24-27. This section\ndiscusses changes in Class Location and states that an HCA/Class Location evaluation report will\nbe completed twice per year (second and fourth quarters). Records show that this report was\ncompleted only one time in 2016.\nTrans-Union should conduct the review of the pipeline and complete the evaluation report twice\nper year.\n2. §192.614 Damage prevention program.\n(c) The damage prevention program required by paragraph (a) of this section must,\nat a minimum:\n(1) Include the identity, on a current basis, of persons who normally engage in\nexcavation activities in the area in which the pipeline is located.\nTrans-Union failed to ensure that one call tickets are compared to excavator mailout list to verify\nthat current excavators are identified each year. During the inspection, several one call tickets\nwere received from excavators in years 2014-2015; however, it was noted that some excavators\nwere not included in the mailouts for 2016. One excavator, Newt Brown Contractors-Minden, LA,\nhad called in a one call ticket in 2014, 2015, and 2016 and was not placed on the list for a mailout\nin 2016.\nTran-Union uses Paradigm to mail notices to its excavators as part of the Public Awareness Plan.\nTrans-Union should review all one-call tickets and ensure that current excavators are included in\nthe annual mail outs.\n3. §192.615 Emergency plans.\n(b) Each operator shall:\n(2) Train the appropriate operating personnel to assure that they are knowledgeable\nof the emergency procedures and verify that the training is effective.\n(3) Review employee activities to determine whether the procedures were effectively\nfollowed in each emergency.\nTrans-Union failed to include recommendations from a mock training incident drill from 2013 in\nits procedures. Trans-Union reviewed the training as far as effectiveness; however, the\nrecommendations were not implemented into the emergency response process. It was suggested\nthat an annual refresher be conducted with each shift to assure they are familiar with how to collect\ninformation regarding the emergency and the response to provide. There has not been a mock\n2\n\n\n\nemergency incident training drill or annual refresher conducted since 2013.\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 Whitecap 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 4-2018-1006W. 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,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5990}