{"operation":"document","citation":"CPF 520085005W","title":"EXPRESS HOLDINGS (USA), LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-03-06","effective_on":null,"summary":"CLOSED warning letter citing 195.555, 195.575(a), 195.583(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085005W","body":"Warning Letter involving EXPRESS HOLDINGS (USA), LLC. PHMSA's enforcement data identifies the cited regulations as 195.555,  195.575(a),  195.583(c). The case was opened on 2008-03-06 and is reported as closed as of 2008-03-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085005W_operator response_04032008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085005W/520085005W_operator%20response_04032008.pdf\n\n520085005W_warning letter_03062008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085005W/520085005W_warning%20letter_03062008.pdf\n\n520085005w_warning letter_03062008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085005W/520085005w_warning%20letter_03062008_text.pdf\n\n520085005w_warning letter_03062008_text.pdf\n\nat=. lVT Ti, ' i tot:tPL&A&E RBGl~\nH II'ticopy „Lticctrtmtcailts~\n8 ot Cop;» L. '\nDtue ~'\n12300 W. Dakota Ave.\nLakewood, CO 80228\nSuite 110\n,\nU. S. Department\nof franspoitatian\nPipeline and\nHazardous Materials Safety\nAdministration\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nMarch 6, 2008\nMr. Dean Dick\nKinder Morgan (USA) Inc.\nDirector Southern Region\n800 Werner Court\nCasper, WY 82601\nCPF 5-2008-5005W\nDear Mr. Dick:\nOn August 13 to August 17, 2007 and October 22 to October 25, 2007, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of\n49 United States Code, inspected your Express pipeline in Wyoming and Montana.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\ntt195. 575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n(a) You must electrically isolate each buried or submerged pipeline from other\nmetallic structures, unless you electrically interconnect and cathodically protect the\npipeline and the other structures as a single unit.\nAt Express pipeline station 23163+91, where Colorado Interstate Gas (CIG) has a\ncompressor station, the Express Pipeline is experiencing high cathodic protection (CP)\n\"off' levels. CIG has moved their station ground bed in an effort to help KM remediate\nthose high CP levels but this action did not lower the levels. KM has been experiencing\nthese high levels for several years. These high \"off * CP levels indicate that foreign\ncurrent is interfering with KM's CP system.\n\n\n\n$195. 555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge of\nthat portion of the corrosion control procedures established under Sec.\n195. 402(c)(3) for which they are responsible for insuring compliance.\nRecords showing verification of corrosion control supervisors' knowledge of the\ncorrosion control procedures for which they are responsible was inadequate. I was\ninformed that a new test for corrosion control supervisors was being developed but that\ntest has not yet been developed.\n3. I)195. 583 What must I do to monitor atmospheric corrosion control?\n(c) If you find atmospheric corrosion during an inspection, you must provide\nprotection against the corrosion as required by Sec. 195. 581.\nKM reported that they have been making repairs to remediate deficiencies noted in their\n2006 atmospheric corrosion inspections but they have not been documenting those\nrepairs. As required by 195, 583(c) and 195. 589(c) KM must document remedial\nmeasures taken as a result of atmospheric corrosion inspections.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this-\nletter. Failure to do so will result in Kinder Morgan (USA) Inc. being subject to additional\nenforcement action,\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-5005W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\nSincerely,\nChil idal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Davis (¹118903, 118876)","truncated":false,"body_characters":5034}