{"operation":"document","citation":"CPF 520080026W","title":"BIG WEST OF CALIFORNIA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-12-15","effective_on":null,"summary":"CLOSED warning letter citing 192.917(e)(5), 192.947(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080026w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080026w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080026w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520080026W","body":"Warning Letter involving BIG WEST OF CALIFORNIA, LLC. PHMSA's enforcement data identifies the cited regulations as 192.917(e)(5),  192.947(e). The case was opened on 2008-12-15 and is reported as closed as of 2008-12-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520080026W_warning letter_12152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080026W/520080026W_warning%20letter_12152008.pdf\n\n520080026w_warning letter_12152008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080026W/520080026w_warning%20letter_12152008_text.pdf\n\n520080026w_warning letter_12152008_text.pdf\n\nU S. Department\nof Transportation\nPipslline and\nHdzmdovs Materidlis Safety\nAdministrdition\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nWA~ING KKTTKR\nDecember 15, 2008\nMr Gene Cotton\nVice President Refining/Plant Manager\nBig West of Cahfornia, LLC\n6451 Rosedale Highway\nBakersfield, CA 93308\nCPF 5-2008-0026M\nDear Mr. Cotton\nOn April 1 and July 22-23, 2008, a representative of the Pipehne and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nBig West of Cahfornia, LLC's (Big West) integrity Management Program (IMP) procedures\nand records Our inspection was conducted at your offices in Bakersfield, Cahfornia\nAs a result of the inspection, it appears you have committed probable violations of the Pipeluie\nSafety Regulations, Title 49, Code of Federal Regulations The items mspected and the\nprobable violations are\n(e) Actions to address partjlcullar threats. Lf an operator identifies any of the\nfollowing threats, the operator must take the following actions to address the\nthreat.\n\n\n\nBig West identified external and internal corrosion threats but had not developed a\nwritten program to address these threats Big West's eight-inch diameter pipeline has\npreviously been ui liquid service The gas it currently transports contains hydrogen\nsulfide These commodities are potentially corrosive\nRegarding external corrosion, Big West is plannmg to make eleven (11) excavations at\nimmediate mdications based on Mears' ECDA supplemental assessment Also, Big\nWest plans to use UT guided wave on the pipe adjacent to these excavations to\nevaluate internal corrosion at those locations Big West will then conduct further\nanalyses to determine how best to evaluate the risks from the internal corrosion tlireat.\nBaker Hughes has been contacted to perform internal corrosion calculations and\nmodehng to determine the locations most likely for internal corrosion. Regardless of\nthese planned activities, the operator had not estabhshed a written program to comply\nwith 192 917 (e)(5)\nEvidence: The hne has previously been in hquid service transporting potentially\ncorrosion causing products. It has not as yet determmed the presence of any internal\ncorrosloli\nBig West does not have a documented training program for individuals with\nresponsibihties for Big West's IMP program Big West has identified this as an action\nitem during 2008\nEvidence: No documented program existed for training company personnel with\nresponsibihties for implementmg its IMP program Big West has identified this as an\naction item during 2008\nUnder 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time We advise you to correct the items\nidentified in this letter Failure to do so will result m Big West of Cahfornia, LLC bemg\nsubject to additional enforcement action\n\n\n\nNo reply to this letter is required If you choose to reply, ni your correspondence please refer\nto CPF 5-2008-0026M. Be advised that all material you submit m response to this\nenforcement action is subject to bemg made pubhcly available If you believe that any portion\nof your responsive material quahfies for confidential treatment under 5 U S. C, 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you beheve quahfy for confidential treatment redacted and an explanation of why\nyou beheve the redacted mformation quahfies for confidential treatment under 5 U S C.\n552(b)\nSmcerely,\nChris al\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\ncc PHP-60 Comphance Registry\nPHP-500 I Giliiam (¹121269)","truncated":false,"body_characters":4625}