{"operation":"document","citation":"CPF 520085015W","title":"SFPP, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-13","effective_on":null,"summary":"CLOSED warning letter citing 195.420(b), 195.569.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520085015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520085015W","body":"Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulations as 195.420(b),  195.569. The case was opened on 2008-06-13 and is reported as closed as of 2008-06-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520085015W_warning letter_06132008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085015W/520085015W_warning%20letter_06132008.pdf\n\n520085015W_warning letter_06132008.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W. Dakota Ave., Suite 11 0\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 13,2008\nMr. Ron McClain\nVice President of Operations and Engineering\nKinder Morgan Energy Partners, L. P., Products Pipelines\n500 Dallas Street\nHouston, TX 77002\nCPF 5-2008-5015W\nDear Mr. McClain:\nFrom September 24,2007 to October 25,2007, representatives of the Arizona Corporation\nCommission and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601\nof 49 United States Code inspected your Arizona refined petroleum pipeline products pipelines.\nAs part of our inspection, we reviewed records at your offices in Colton and Orange, California;\nand Phoenix, Tucson, and Yuma, Arizona.\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 probable violations\nare :\n1. 9195.420 Valve maintenance\n(b) Each operator shall, at intervals not exceeding 7 112 months, but at least twice\neach calendar year, inspect each mainline valve to determine that it is functioning\nproperly.\nThe valve inspection interval for the Tucson Terminal inlet valve exceeded 7 ?4 months.\nSpecifically, the late valve inspection occurred at MP 303.54 of Line Segment (LS) 6\n(8\" El Paso - Phoenix). Inspection records indicate that the valve was inspected on\nSeptember 28,2006. The next documented inspection of the valve did not take place until\nMay 2 1,2007. Kinder Morgan personnel could not locate any additional records of valve\ninspections done between the dates mentioned above.\n\n\n\n2. 5195.420 Valve maintenance\n(b) Each operator shall, at intervals not exceeding 7 112 months, but at least twice\neach calendar year, inspect each mainline valve to determine that it is\nfunctioning properly.\nNo documentation was available during the inspection to demonstrate that both the Willcox and\nWillcox Dry Lake mainline valves on LS 22 (12\" El Paso - Tucson) had been inspected\nbetween May 18,2006 and May 22,2007. Kinder Morgan personnel were not able to locate\nany records in the Colton Terminal to demonstrate inspection of the mainline valves located at\nWillcox (milepost 220.57) and Willcox Dry Lake (milepost 235.38). The only records available\nindicated the most recent valve inspections occurred on May 18, 2006 and on May 22,2007.\n3. 5195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is exposed, you\nmust examine the exposed portion for evidence of external corrosion if the pipe is\nbare,or if the coating is deteriorated. If you find external corrosion requiring\ncorrective action under Sec. 195.585, you must investigate circumferentially and\nlongitudinally beyond the exposed portion (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the exposed portion.\nDocumentation of a pipeline exposure of LS 11 7 (12\" Tucson - Phoenix) was incomplete. The\nrecords failed to demonstrate that a visual inspection of the exposed pipeline was conducted to\ncheck the condition of the coating and for any evidence of external corrosion.\nOn February 1, 2007, Fishel Company, working as a contactor for Qwest Communications, was\ninstalling 2 fiber optic conduit facilities near the junction of 1-1 0 and Tangerine Road in\nMarana, AZ by means of a directional bore. The location was at the pipeline MP 329.94. The\nrecord and a photograph taken at the site show that the installation was taking place below the\nKM pipeline facilities. The photo also shows the pipeline facilities were exposed. However,\nthe record does not indicate that a visual inspection was done on the exposed pipeline facility to\ncheck the condition of the coating and to check for any external corrosion, even though there are\nlocations on the line crossing report to record information about the coating and external\ncorrosion.\nUnder 49 United States Code, tj 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 Energy Partners, L.P.\nbeing subject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-5015W. 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,,,, ,\n~hris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 T. Finch (Activity #120758)\nArizona Corporation Commission- Mr. Robert Miller","truncated":false,"body_characters":6036}