# VALERO TERMINALING AND DISTRIBUTION COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 42026003NOA
- **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:** 2026-02-11
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.402(a), 195.402(c)(3), 195.587.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42026003noa.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42026003noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42026003NOA
**body:**

Notice of Amendment involving VALERO TERMINALING AND DISTRIBUTION COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  195.587. The case was opened on 2026-02-11 and is reported as closed as of 2026-05-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42026003NOA_Closure Letter_05072026_(25-329817).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026003NOA/42026003NOA_Closure%20Letter_05072026_(25-329817).pdf

42026003NOA_Closure Letter_05072026_(25-329817)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026003NOA/42026003NOA_Closure%20Letter_05072026_(25-329817)_text.pdf

42026003NOA_Notice of Amendment_02112026_(25-329817).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026003NOA/42026003NOA_Notice%20of%20Amendment_02112026_(25-329817).pdf

42026003NOA_Notice of Amendment_02112026_(25-329817)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026003NOA/42026003NOA_Notice%20of%20Amendment_02112026_(25-329817)_text.pdf

42026003NOA_Operator Response to Notice_03112026_(25-329817).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026003NOA/42026003NOA_Operator%20Response%20to%20Notice_03112026_(25-329817).pdf

42026003NOA_Notice of Amendment_02112026_(25-329817)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: fred.hampton@valero.com
February 11, 2026
Fred E. Hampton
Vice President, Pipeline & Terminals
Valero Energy Corporation
One Valero Way,
San Antonio, TX 78249
CPF 4-2026-003-NOA
Dear Mr. Hampton:
From February 24 through June 30, 2025, 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 Energy Terminaling and Distribution Company’s (Valero) procedures for
operations and maintenance in San Antonio, Texas.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Valero’s plans or procedures.
The items inspected and the inadequacy is described below:
1. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline system a manual of written procedures for conducting
normal operations and maintenance activities and handling abnormal
operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the
manual is effective. This manual shall be prepared before initial
operations of a pipeline system commence, and appropriate parts
shall be kept at locations where operations and maintenance activities
are conducted.
(b) . . . .



(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the
following to provide safety during maintenance and normal
operations:
(1) . . . .
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
§ 195.587 What methods are available to determine the strength of corroded pipe?
Under § 195.585, you may use the procedure in ASME/ANSI B31G
(incorporated by reference, see § 195.3) or in PRCI PR-3-805 (R-
STRENG) (incorporated by reference, see § 195.3) to determine the
strength of corroded pipe based on actual remaining wall thickness.
These procedures apply to corroded regions that do not penetrate the
pipe wall, subject to the limitations set out in the respective
procedures.
Valero’s written procedures are inadequate to ensure the safe operation of a pipeline facility in
accordance with § 195.402(c)(3). Specifically, Valero’s written procedure for calculating the
remaining strength of corroded pipe, OME P415 (Rev. 8, 3/1/2025), is inadequate for determining
the remaining strength of corroded pipe wall in accordance with § 195.587. Valero’s procedure,
in Sections 5.2.1 and 5.2.2, provides the formulas to calculate remaining strength from
ASME/ANSI B31G and R-STRENG. However, Sections 5.2.1 and 5.2.2 fail to provide an
explanation for many of the variables used in the identified formulas, and fails to inform personnel
of where they can acquire the variables to be used in the equation. Without definitions for these
variables or instructions on how to acquire them, the formulas and procedure are unusable by
Valero personnel. PHMSA proposes that Valero must amend its procedure to include explanations
for each of the variables in the formulas provided in the procedure.
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).
2



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 30 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, Office of Pipeline Safety,
Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this
matter, please refer to CPF 4-2026-003-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
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42026003NOA_Closure Letter_05072026_(25-329817)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: fred.hampton@valero.com
May 7, 2026
Fred E. Hampton
Vice President, Pipeline & Terminals
Valero Energy Corporation
One Valero Way,
San Antonio, TX 78249
CPF 4-2026-003-NOA
Dear Mr. Hampton:
From February 24 through June 30, 2025, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Valero Energy Terminaling and Distribution
Company’s (Valero) procedures in San Antonio, Texas.
As a result of the inspection, Valero was issued a Notice of Amendment on February 11, 2026,
which proposed amendment of your procedures.
Valero submitted its amended procedures on March 11, 2026. 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 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 Terminaling and Distribution
Company, darin.banther@valero.com
Carlos Gauna, Director Pipeline and Facility Integrity, Valero Partners Operating
Company, LLC, carlos.gauna@valero.com
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