# SHELL PIPELINE CO., L.P. — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 42023010NOPV
- **title:** SHELL PIPELINE CO., L.P. — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2023-06-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.420(b), 195.428(a), 195.505(b), 195.573(e).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42023010nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42023010nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42023010NOPV
**body:**

Notice of Probable Violation involving SHELL PIPELINE CO., L.P.. PHMSA's enforcement data identifies the cited regulations as 195.420(b),  195.428(a),  195.505(b),  195.573(e). The case was opened on 2023-06-02 and is reported as closed as of 2025-05-15. Proposed civil penalty: $176,000. Assessed civil penalty: $169,700. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42023010NOPV_Closure Letter_05152025_(22-232749).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_Closure%20Letter_05152025_(22-232749).pdf

42023010NOPV_Closure Letter_05152025_(22-232749)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_Closure%20Letter_05152025_(22-232749)_text.pdf

42023010NOPV_Final Order_09112024_(22-232749).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_Final%20Order_09112024_(22-232749).pdf

42023010NOPV_Final Order_09112024_(22-232749)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_Final%20Order_09112024_(22-232749)_text.pdf

42023010NOPV_Operator Response to Notice_06302023_(22-232749).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_Operator%20Response%20to%20Notice_06302023_(22-232749).pdf

42023010NOPV_PCP PCO_06022023_(22-232749).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_PCP%20PCO_06022023_(22-232749).pdf

42023010NOPV_PCP PCO_06022023_(22-232749)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42023010NOPV/42023010NOPV_PCP%20PCO_06022023_(22-232749)_text.pdf

42023010NOPV_Closure Letter_05152025_(22-232749)_text.pdf

VIA ELECTRONIC MAIL TO: sean.guillory@shell.com
May 15, 2025
Mr. Sean Guillory
General Manager, US Midstream
Shell Pipeline Co., LP
150 North Dairy Ashford, Building A, Fourth Floor
Houston, TX 77079
RE: CPF 4-2023-010-NOPV
Dear Mr. Guillory:
From May through November 22, 2022, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49
United States Code (U.S.C.) inspected Shell Pipeline Company, LP’s (Shell) hazardous liquid
pipeline systems in Texas, Louisiana, and the Gulf of Mexico. As a result of the inspection, ETC
Shell was issued a Notice of Probable Violation (NOPV) of the Pipeline Safety Regulations, Title
49, Code of Federal Regulations in the above-referenced case.
On September 11, 2024, PHMSA issued a Final Order in the above-referenced case. This Order
included a Compliance Order and Civil Penalty. Based on our review of the documentation you
provided and confirmation of payment of the civil penalty, it has been determined that Shell has
complied with the terms of this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Ms. Deborah Price, Integrity & Regulatory Services Manager, Shell Pipeline Co., LP,
deborah.price@shell.com

42023010NOPV_Final Order_09112024_(22-232749)_text.pdf

September 11, 2024
VIA ELECTRONIC MAIL TO: wael.sawan@shell.com
Wael Sawan
Chief Executive Officer
Shell Pipeline Company LP
WCK Building A
150 North Dairy Ashford Road
Houston, Texas 77079
Re: CPF No. 4-2023-010-NOPV
Dear Mr. Sawan:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a reduced civil penalty of $169,700, and specifies actions that need to be
taken by Shell Pipeline Company LP, to comply with the pipeline safety regulations. The
penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and
the terms of the compliance order completed, as determined by the Director, Southwest Region,
this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the
date of transmission and acknowledgement of receipt as provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Sean Guillory, President, Shell Pipeline Company LP, sean.guillory@shell.com
Ms. Deborah Price, Integrity & Regulatory Services Manager, Shell Pipeline Company LP,
deborah.price@shell.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Shell Pipeline Company LP, ) CPF No. 4-2023-010-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From May 9 through November 22, 2022, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Shell
Pipeline Company LP’s (Shell or Respondent) hazardous liquid pipeline systems in Texas,
Louisiana, and the Gulf of Mexico.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated June 2, 2023, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the
Notice proposed finding that Shell had committed three violations of 49 C.F.R. Part 195,
proposed assessing a civil penalty of $176,000 for the alleged violations, and proposed ordering
Respondent to take certain measures to correct the alleged violations. The Notice also included
an additional warning item pursuant to 49 C.F.R. § 190.205, which warned the operator to
correct the probable violation or face possible future enforcement action.
Shell responded to the Notice by letter dated June 30, 2023 (Response). Shell responded to all
allegations, offered additional information in response to the Notice, requested that the proposed
civil penalty be reconsidered, and that the proposed compliance order be withdrawn. Respondent
did not request a hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.420(b), which states:
§ 195.420 Valve maintenance.
(a) …
(b) Each operator shall, at intervals not exceeding 7½ months, but at



least twice each calendar year, inspect each mainline valve to determine that
it is functioning properly.
The Notice alleged that Respondent violated 49 C.F.R. § 195.420(b) by failing on 56 separate
instances to inspect 35 mainline valves at the required intervals during the calendar years of 2020
through and including 2022.
In its Response, Shell admitted it had documentation issues regarding its mainline valve
inspections from 2020 through 2022, but stated that all required inspections did occur in
accordance with § 195.420(b). Shell explained that it transitioned to a new data management
system to track inspection and maintenance tasks in 2020 and implemented that system in the
field in 2022.
1 However, Shell acknowledged that that there were technical difficulties
providing records from the new system during PHMSA’s inspection.2 Shell provided multiple
screenshots from its new system as proof the inspections had occurred as required as part of its
Response, and detailed the steps it has taken to remedy its technical issues since the PHMSA
inspection.
3 Shell requested that the violation and civil penalty be reevaluated based on the
screenshots and explanation provided within its Response.
PHMSA has stated in prior enforcement matters that every, “Respondent is responsible for
compliance with the pipeline safety regulations, which includes sound record keeping. Without
this history, an operator will have difficulty determining areas where there are problems that
need to be addressed.”4 While Shell has provided an explanation for the missing records at the
time of the inspection, as well as additional documentation, a review of that documentation
reveals that its records are still incomplete.
While Attachment 1 does provide some clarity, there are still multiple instances where the
inspection history is either incomplete or the interval between inspections is greater than what is
allowed by the pipeline safety regulations. First, there are no records of inspection for valve
number 2044008 included in the Response. Additionally, the screenshots provided in the
Response indicate only one inspection of the mainline valve occurred in 2020 for valve numbers
2042012, 2064000, 2064002, 2064009, 2144098, 2131321, 1000356, 1032009, 2404338,
2404340, 2406171, 3217501, and 3217508.5 Attachment 1 further indicates a missing or late
inspection in 2022 for valve number 2336005.
6 Moreover, Attachment 1 indicates that valve
numbers 1002011 and 1002013 each had inspections occur at intervals greater than 7½ months,
with an inspections occurring on April 28, 2021, January 6, 2022, and October 27, 2022.
7
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
1 Response, at 1-2.
2 Response, at 2.
3 Id.
4 In the Matter of Ozark Gas Transmission, Final Order 2-2002-1004, 2003 WL 26473449 at *2 (April 29, 2003).
5 Respondent’s Attachment 1, at 2, 4-10, 29, 31, 37, 44-45.
6 Respondent’s Attachment 1, at 12.
7 Respondent’s Attachment 1, at 20-21.



§ 195.420(b) by failing to inspect its mainline valves at intervals not exceeding 7½ months, but
at least twice each calendar year to determine that it is functioning properly, as required.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states:
§ 195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section, each operator
shall, at intervals not exceeding 15 months, but at least once each calendar
year, or in the case of pipelines used to carry highly volatile liquids, at
intervals not to exceed 7½ months, but at least twice each calendar year,
inspect and test each pressure limiting device, relief valve, pressure
regulator, or other item of pressure control equipment to determine that it is
functioning properly, is in good mechanical condition, and is adequate from
the standpoint of capacity and reliability of operation for the service for
which it is used.
The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a) by failing to inspect and test
each pressure limiting device, relief valve, pressure regulator, or other item of pressure control
equipment as required. Specifically, the Notice alleged from 2020 to 2022, Shell failed to
inspect seven overpressure safety devices once a calendar year at intervals not exceeding 15
months on 11 instances. Additionally, the Notice alleged that from 2020 to 2022, Shell failed to
inspect seven overpressure safety devices twice a calendar year at intervals not exceeding 7½
months on a highly volatile liquid system on 14 instances.
In its Response, Shell admitted it had documentation issues with regards to its overpressure
device inspections, but stated it had conducted the inspections at the appropriate intervals in
accordance with the code.
8 Shell explained that the issue with documentation was the same as it
described for Item 1 and provided screenshots from its data management program as proof it had
conducted the required inspections as part of its Response. A review of Respondent’s
Attachment 2 confirms that all of the inspections on the Crude System Valve Equipment
referenced in the Notice were conducted at the appropriate intervals. However, the
documentation is still incomplete regarding the Highly Volatile Liquid System Valve Equipment
referenced in the Notice.
A review of Attachment 2 indicates that only one inspection, instead of the required two,
occurred in 2020 on overpressure safety device numbers 1025341, 2194027, 1025340, 3207629,
and 1009765.9 Additionally, the screenshots provided are missing relevant information for some
of the inspections, including who conducted the inspection and what the results of the inspection
were, in regards to inspections conducted on overpressure safety device numbers 2194024,
1025341, 2194025, 1025340, 3207629, and 1009765.10
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.428(a) by failing to inspect overpressure safety devices twice a calendar year at intervals
8 Response, at 3.
9 Respondent’s Attachment 2, at 12, 14, 18, 20 and 22.
10 Respondent’s Attachment 2, at 11, 13, 16, 19, 21 and 23.



not exceeding 7½ months on a highly volatile liquid system as required.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.505(b), which states:
§ 195.505 Qualification program.
(a) …
are qualified;
(b) Ensure through evaluation that individuals performing covered tasks
The Notice alleged that Respondent violated 49 C.F.R. § 195.505(b) by failing to follow its
written qualification program to confirm through evaluation that all individuals performing
covered tasks are qualified as required. Specifically, the Notice alleged that an unqualified
employee performed 37 valve inspections, which is a covered tasked, from December 2020 to
July 2022, without supervision of a qualified inspector.
In its Response, Shell did not contest the violation. Shell acknowledged that the employee in
question performed valve inspections without being qualified and stated that they were qualified
the day after the discrepancy was discovered.11 Shell further stated that it had conducted a full
review of all other employee task lists and did not find any similar discrepancies and that it had
implemented a system to prevent similar occurrences in the future.12
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.505(b) by failing to ensure that all individuals performing covered tasks are qualified.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.13
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue
doing business; the good faith of Respondent in attempting to comply with the pipeline safety
regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.
In addition, I may consider the economic benefit gained from the violation without any reduction
because of subsequent damages, and such other matters as justice may require. The Notice
11 Response, at 3.
12 Id.
13 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223 for adjusted amounts.



proposed a total civil penalty of $176,000 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $62,900 for Respondent’s violation of 49 C.F.R.
§ 195.420(b), for failing to inspect its mainline valves at intervals not exceeding 7½ months, but
at least twice each calendar year to determine that it is functioning properly, as required. As
discussed above, in its Response, Shell stated that it had conducted the mainline valve
inspections at the required intervals but could not provide documentation of each inspection at
the time of PHMSA’s inspection. Shell’s Response further described its record keeping process,
provided evidence of the completed inspections, and asked that the civil penalty be reconsidered
based on its explanation and additional documentation. However, after reviewing all of the
information provided in the Response, I found that a violation still exists. This is because the
records are incomplete as to whether several inspections occurred and, in some cases, the records
indicate the inspections of mainline valves occurred at an interval that exceeds 7½ months.
Without a record of each inspection being completed, I cannot determine if the inspection had
occurred and, if it had occurred, if the inspection was timely. Therefore, I find that this Item was
appropriately assessed as an activities violation. Also, per the Region Recommendation, the
proposed civil penalty assessed three instances, one for each calendar year of 2020, 2021, and
2022.
14 As I noted, at least one instance of violation in each of those calendar years. I,
therefore, do not find a basis to decrease the number of instances for this Item. Additionally, as
some of the valves are located in a high consequence area, I find that the gravity was
appropriately assessed, as were the other civil penalty factors. Accordingly, having reviewed the
record and considered the assessment criteria, I assess Respondent a civil penalty of $62,900 for
violation of 49 C.F.R. § 195.420(b).
Item 2: The Notice proposed a civil penalty of $62,900 for Respondent’s violation of 49 C.F.R.
§ 195.428(a), for failing to inspect overpressure safety devices twice a calendar year at intervals
not exceeding 7½ months on a highly volatile liquid system as required. As described above,
similar to Item 1, in its Response, Shell maintained it had conducted all required inspections but
had documentation issues at the time of the PHMSA inspection. Shell described its record
keeping process, provided evidence of completed inspections, and asked for the violation and
civil penalty to be reconsidered based on its explanation and documentation. However, after
reviewing all of the information provided, I found that a violation still exists. This is because the
records were incomplete as to whether several inspections had occurred. Additionally, some of
the records lacked the necessary information to determine who had conducted the inspection and
what that inspector observed. As stated above, without a proper record of the inspection being
completed, I cannot determine if the inspection occurred and, if it had occurred, if the inspection
was timely. Therefore, I find that this Item was appropriately assessed as an activities violation.
Also, per the Region Recommendation, the proposed civil penalty assessed three instances, one
for each calendar year of 2020, 2021, and 2022.15 Upon review of the documents provided by
Respondent, however, I find the instances of violation only occurred in the calendar years of
2020 and 2021 for this Item. Therefore, I find that the number of instances should be assessed at
two instead of three. As some of the valves are located in a high consequence area, I find that
the gravity was appropriately assessed, as were the other civil penalty factors. Accordingly,
having reviewed the record and considered the assessment criteria, I assess Respondent a
14 Region Recommendation, at footnote 1.
15 Region Recommendation, at footnote 3.



reduced civil penalty of $56,600 for violation of 49 C.F.R. § 195.428(a).
Item 3: The Notice proposed a civil penalty of $50,200 for Respondent’s violation of 49 C.F.R.
§ 195.505(b), for failing to ensure that all individuals performing covered tasks are qualified. In
its Response, Shell acknowledged the individual had been performing inspections without being
qualified, described the actions it took to both qualify that individual and safeguard that the
violation would not happen again, and asked that because it was a first-time offense and there
was no risk to pipeline safety, that the civil penalty be reduced. While the individual in question
was qualified for the task the day after the discrepancy was discovered, as some of the valves
they had inspected while not being properly qualified for the task were located a high
consequence area, so the gravity was properly assessed. Additionally, while the steps Shell has
taken to prevent this event from occurring in the future are commendable, that is not a basis to
reduce a civil penalty because the corrective action occurred after PHMSA discovered the
violation occurred.
16 Accordingly, having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $50,200 for violation of 49 C.F.R. § 195.505(b).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $169,700.
Payment of the civil penalty must be made within 20 days after receipt of this Final Order.
Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer
through the Federal Reserve Communications System (Fedwire), to the account of the U.S.
Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire
transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation
Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,
Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the civil penalty will result in accrual of interest at the current annual rate in
accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those
same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment
is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result
in referral of the matter to the Attorney General for appropriate action in a district court of the
United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. §§ 195.420(b) and 195.428(a) respectively. Under 49 U.S.C. § 60118(a),
each person who engages in the transportation of hazardous liquids or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601.
16 See In the Matter of Oasis Midstream Partners LP, a General Partner of Oasis Petroleum Inc., Final Order 3-
2019-5020, 2020 WL 6870720 at 7 (August 19, 2020) (“While Oasis is to be commended for improving its internal
processes to ensure compliance with the pipeline safety regulations, such post-inspection activities do not warrant
the withdrawal of, or a reduction in, a proposed civil penalty.”)



With regard to the violation of § 195.420(b) (Item 1), Respondent argued it had conducted the
mainline valve inspections as required per the pipeline safety regulations and provided additional
documentation as proof. However, as stated above, the documentation provided was incomplete
to determine whether all necessary inspections were conducted at the required intervals.
However, Attachment 1 did provide evidence that inspections of mainline valve numbers
1020307, 1020305, 1020326, 1009628, 1012904, 1014255, 1014256, 1024300, 1024301,
2130495, 2404992, 2404993, 2404994, 2405001, 2405003, 2410000, 2410002, 2410004,
2410015, and 2410020 had occurred in a timely manner. Therefore, the compliance order will
be modified to only include the mainline valves not listed above.
With regard to the violation of § 195.428(a) (Item 2), Respondent argued it had conducted the
overpressure safety device inspections as required per the pipeline safety regulations and
provided additional documentation as proof. However, as stated above, the documentation
provided was incomplete to determine whether all necessary inspections were conducted at the
required intervals. However, Attachment 2 did provide evidence that inspections of overpressure
safety device numbers 1019997, 1019998, 2131376, 1029264, 1029259, 1012490, and 1012491
had occurred in a timely manner. Therefore, the compliance order will be modified to only
include the overpressure safety devices not listed above.
For the above reasons, the Compliance Order is modified as set forth below.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is
ordered to take the following actions to ensure compliance with the pipeline safety regulations
applicable to its operations:
1. With respect to the violation of § 195.420(b) (Item 1), Respondent must inspect
mainline valve numbers 2044008, 2042012, 2064000, 2064002, 2064009, 2144098,
2131321, 1000356, 1032009, 2404338, 2404340, 2406171, 3217501, 3217508,
2336005, 1002011, and 1002013, maintain inspection records as required by its
procedure, and provide the mainline valve inspection records to the Director,
Southwest Region within 90 days of issuance of the Final Order.
2. With respect to the violation of § 195.428(a) (Item 2), Respondent must inspect
and test overpressure safety device numbers 2194024, 1025341, 2194027, 2194025,
1025340, 3207629, 1009765, maintain the inspection records as required by its
procedure, and provide the overpressure safety device inspection records to the
Director, Southwest Region within 90 days of issuance of the Final Order.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. It is
requested that these costs be reported in two categories: (1) total cost associated with
preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.



Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (see 49 C.F.R. § 190.223 for adjusted amounts),
for each violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.
WARNING ITEM
With respect to Item 4, the Notice alleged a probable violation of Part 195, but identified it as a
warning item pursuant to § 190.205. The warning was for:
49 C.F.R. § 195.573(e) (Item 4) ─ Respondent’s alleged failure to correct
identified annual cathodic protection deficiencies on its Ship Shoal 22 Loop at
MP 7.5 within a reasonable time, as required.
Shell acknowledged the deficiencies were not corrected in a reasonable time in its Response and
stated the issue has since been remedied. Under § 190.205, PHMSA does not adjudicate warning
items to determine whether a probable violation occurred. If OPS finds a violation of this
provision in a subsequent inspection, Respondent may be subject to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address. The written petition must be received no later than
20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a
statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a
petition automatically stays the payment of any civil penalty assessed. The other terms of the
order, including corrective action, remain in effect unless the Associate Administrator, upon
request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
September 11, 2024
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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