BIG WEST OF CALIFORNIA, LLC — Warning Letter

520080026w_warning letter_12152008_text.pdf, page 1Official PDFU S. Department of Transportation Pipslline and Hdzmdovs Materidlis Safety Administrdition 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 WA~ING KKTTKR December 15, 2008 Mr Gene Cotton Vice President Refining/Plant Manager Big West of Cahfornia, LLC 6451 Rosedale Highway Bakersfield, CA 93308 CPF 5-2008-0026M Dear Mr. Cotton On April 1 and July 22-23, 2008, a representative of the Pipehne and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Big West of Cahfornia, LLC's (Big West) integrity Management Program (IMP) procedures and records Our inspection was conducted at your offices in Bakersfield, Cahfornia As a result of the inspection, it appears you have committed probable violations of the Pipeluie Safety Regulations, Title 49, Code of Federal Regulations The items mspected and the probable violations are (e) Actions to address partjlcullar threats. Lf an operator identifies any of the following threats, the operator must take the following actions to address the threat.#

520080026w_warning letter_12152008_text.pdf, page 2Big West identified external and internal corrosion threats but had not developed a written program to address these threats Big West's eight-inch diameter pipeline has previously been ui liquid service The gas it currently transports contains hydrogen sulfide These commodities are potentially corrosive Regarding external corrosion, Big West is plannmg to make eleven (11) excavations at immediate mdications based on Mears' ECDA supplemental assessment Also, Big West plans to use UT guided wave on the pipe adjacent to these excavations to evaluate internal corrosion at those locations Big West will then conduct further analyses to determine how best to evaluate the risks from the internal corrosion tlireat. Baker Hughes has been contacted to perform internal corrosion calculations and modehng to determine the locations most likely for internal corrosion. Regardless of these planned activities, the operator had not estabhshed a written program to comply with 192 917 (e)(5) Evidence: The hne has previously been in hquid service transporting potentially corrosion causing products. It has not as yet determmed the presence of any internal corrosloli Big West does not have a documented training program for individuals with responsibihties for Big West's IMP program Big West has identified this as an action item during 2008 Evidence: No documented program existed for training company personnel with responsibihties for implementmg its IMP program Big West has identified this as an action item during 2008 Under 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed $100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any 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 items identified in this letter Failure to do so will result m Big West of Cahfornia, LLC bemg subject to additional enforcement action#

520080026w_warning letter_12152008_text.pdf, page 3No reply to this letter is required If you choose to reply, ni your correspondence please refer to CPF 5-2008-0026M. Be advised that all material you submit m response to this enforcement action is subject to bemg made pubhcly available If you believe that any portion of your responsive material quahfies 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 beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted mformation quahfies for confidential treatment under 5 U S C. 552(b) Smcerely, Chris al Director, Western Region Pipehne and Hazardous Materials Safety Administration cc PHP-60 Comphance Registry PHP-500 I Giliiam (¹121269)#