# VALERO TERMINALING AND DISTRIBUTION COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 42025001NOA
- **title:** VALERO TERMINALING AND DISTRIBUTION COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2025-05-22
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.452(b)(1), 195.452(b)(4), 195.452(f)(3).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42025001noa.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42025001noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42025001NOA
**body:**

Notice of Amendment involving VALERO TERMINALING AND DISTRIBUTION COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.452(b)(1),  195.452(b)(4),  195.452(f)(3). The case was opened on 2025-05-22 and is reported as closed as of 2025-07-29. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42025001NOA_Closure Letter_07292025_(24-296561).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025001NOA/42025001NOA_Closure%20Letter_07292025_(24-296561).pdf

42025001NOA_Closure Letter_07292025_(24-296561)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025001NOA/42025001NOA_Closure%20Letter_07292025_(24-296561)_text.pdf

42025001NOA_Notice of Amendment_05222025_(24-296561).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025001NOA/42025001NOA_Notice%20of%20Amendment_05222025_(24-296561).pdf

42025001NOA_Notice of Amendment_05222025_(24-296561)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025001NOA/42025001NOA_Notice%20of%20Amendment_05222025_(24-296561)_text.pdf

42025001NOA_Operator Response to Notice_06092025_(24-296561).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025001NOA/42025001NOA_Operator%20Response%20to%20Notice_06092025_(24-296561).pdf

42025001NOA_Notice of Amendment_05222025_(24-296561)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: fred.hampton@valero.com
May 22, 2025
Mr. Fred E. Hampton
Vice President, Pipeline & Terminals
Valero Energy Corporation
One Valero Way,
San Antonio, TX 78249
CPF 4-2025-001-NOA
Dear Mr. Hampton:
From March 11 to September 27, 2024 of the video-conferenced inspection, a representative of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601
of 49 United States Code (U.S.C.), inspected Valero Terminal and Distribution Company’s1
(Valero) integrity management program procedures.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Valero’s procedures. The item inspected and the inadequacies are described below:
1. § 195.452 Pipeline integrity management in high consequence areas.
(a) . . . .
(b) What program and practices must operators use to manage
pipeline integrity? Each operator of a pipeline covered by this section
must:
(1) Develop a written integrity management program that
addresses the risks on each segment of pipeline in the first column of
the following table no later than the date in the second column: . . . .
(4) Include in the program a framework that –
(i) Addresses each element of the integrity management program
under paragraph (f) of this section, including continual integrity
assessment and evaluation under paragraph (j) of this section; and
(ii) Initially indicates how decisions will be made to implement
each element.
1 Valero Terminal and Distribution Co. is a subsidiary of Valero Energy Corp.



(5) . . . .
(f) What are the elements of an integrity management program? An
integrity management program begins with the initial framework. An
operator must continually change the program to reflect operating
experience, conclusions drawn from results of the integrity
assessments, and other maintenance and surveillance data, and
evaluation of consequences of a failure on the high consequence area.
An operator must include, at minimum, each of the following elements
in its written integrity management program:
(1) . . . .
(3) An analysis that integrates all available information about the
integrity of the entire pipeline and the consequences of a failure (see
paragraph (g) of this section);
Valero’s written integrity management program was inadequate to provide safe operation of a
pipeline facility in accordance with § 195.452(f)(3). Specifically, Valero’s Liquid Pipeline
Integrity Management Program (Rev. 4.5; Eff. May 1, 2024), Section 6.6. Facility Risk
Management, does not include an analysis that integrates all available information about the
integrity of the entire pipeline and the consequences of failure in periodically evaluating the
integrity of each pipeline segment under paragraph (g).
Therefore, PHMSA proposes Valero revise its integrity management program procedure to include
a procedure for analyzing all information about the integrity of its entire pipeline and the
consequences of a failure in accordance with § 195.452(f)(3).
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part
of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. 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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this



Notice, we propose that you submit your amended procedures to my office within 60 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Valero maintain documentation of the safety improvement costs
associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)
and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous
Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-
2025-001-NOA and, for each document you submit, please provide a copy in electronic format
whenever possible.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Darin Banther, Manager Regulatory Compliance, Valero Terminaling and Distribution
Company, darin.banther@valero.com

42025001NOA_Closure Letter_07292025_(24-296561)_text.pdf

VIA ELECTRONIC MAIL TO: fred.hampton@valero.com
July 29, 2025
Mr. Fred E. Hampton
Vice President, Pipeline & Terminals
Valero Energy Corporation
One Valero Way,
San Antonio, TX 78249
CPF 4-2025-001-NOA
Dear Mr. Hampton:
From March 11, 2024 to September 27, 2024, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted inspection of Valero Terminal and Distribution Company’s (Valero) integrity
management program procedures. As a result of the inspection, Valero was issued a Notice of
Amendment on May 22, 2025, which proposed amendment of your procedures.
Valero submitted its amended procedures on July 23, 2025. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you that no further action is necessary and this case is now closed. Thank
you for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Darin P. Banther, Manager Regulator Compliance, Valero Energy Corporation,
Darin.Banther@valero.com
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