# SHELL PIPELINE CO., L.P. — Warning Letter

- **operation:** document
- **citation:** CPF 420195025W
- **title:** SHELL PIPELINE CO., L.P. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-12-10
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.430(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420195025w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420195025w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420195025w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420195025W
**body:**

Warning Letter involving SHELL PIPELINE CO., L.P.. PHMSA's enforcement data identifies the cited regulation as 195.430(a). The case was opened on 2019-12-10 and is reported as closed as of 2019-12-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420195025W_Warning Letter_12102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195025W/420195025W_Warning%20Letter_12102019.pdf

420195025W_Warning Letter_12102019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195025W/420195025W_Warning%20Letter_12102019_text.pdf

420195025W_Warning Letter_12102019_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 10, 2019
Greg Smith
President
Shell Pipeline Co., L.P.
150 North Dairy Ashford, Woodcreek Bldg. A, 2nd Floor
Houston, Texas 77079
CPF 4-2019-5025W
Dear Mr. Smith:
From February 4, 2019 to November 6, 2019, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected your hazardous liquid pipeline systems in Texas, Louisiana, and the Gulf of
Mexico.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. §195.430 Firefighting equipment
Each operator shall maintain adequate firefighting equipment at each pump station
and breakout tank area. The equipment must be—
(a) In proper operating condition at all times;
Shell failed to ensure that their firefighting equipment was in proper operating condition by failing
to perform monthly visual inspection as require by 195.430 (a).



During the field inspection PHMSA inspectors observed three fire extinguishers at the Colex East
tank facility that had not been inspected in the months of July and August 2019.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31,
2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum
penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before
November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a
maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,
the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances
and supporting documents involved in this case, and have decided not to conduct additional
enforcement action or penalty assessment proceedings at this time. We advise you to correct the
item(s) identified in this letter. Failure to do so will result in Shell Pipeline Co., L.P. being subject
to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2019-5025W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe the
redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
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