{"operation":"document","citation":"CPF 420195020W","title":"CITGO PRODUCTS PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-11-20","effective_on":null,"summary":"CLOSED warning letter citing 195.505(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195020w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195020w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195020w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420195020W","body":"Warning Letter involving CITGO PRODUCTS PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.505(a). The case was opened on 2019-11-20 and is reported as closed as of 2019-11-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420195020W_Warning Letter_11202019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195020W/420195020W_Warning%20Letter_11202019.pdf\n\n420195020W_Warning Letter_11202019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195020W/420195020W_Warning%20Letter_11202019_text.pdf\n\n420195020W_Warning Letter_11202019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 20, 2019\nKresha Sivinski\nGeneral Manager Terminals & Pipeline\nCitgo Products Pipeline Co.\n1293 Eldridge Parkway\nHouston, Texas 77077\nCPF 4-2019-5020W\nDear Kresha Sivinski:\nFrom February 21, 2018 through August 30, 2018, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected your Lakemont Pipeline System in Texas and Louisiana.\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 item inspected and\nthe probable violation is:\n1. §195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) Identify covered tasks;\nCitgo failed to identify grinding to repair pipe defects as a covered task. Grinding was used as a\nrepair method for two pipe repairs on the Lakemont Pipeline System in 2016.\n\n\n\nPHMSA personnel reviewed two pipe repair records in 2016 which noted the used of grinding to\nrepair defects on the pipe. Citgo’s covered task list titled Appendix A1 Covered Task List did not\ninclude a covered task which covered grinding as a repair method. An appropriate covered task\nwas added to the covered task list as task 42.7 “Removal of Pipeline Defects by Grinding” prior\nto the completion of this inspection.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Citgo Products Pipeline Co. being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2019-5020W. 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\n2","truncated":false,"body_characters":4089}