{"operation":"document","citation":"CPF 520101006W","title":"PAIUTE PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-09-21","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520101006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520101006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520101006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520101006W","body":"Warning Letter involving PAIUTE PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2010-09-21 and is reported as closed as of 2010-09-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520101006W_warning letter_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101006W/520101006W_warning%20letter_09212010.pdf\n\n520101006W_warning letter_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101006W/520101006W_warning%20letter_09212010_text.pdf\n\n520101006W_warning letter_09212010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 21, 2010\nMr. Edward McMurtrie\nVice President\nPaiute Pipeline Company\nP.O. Box 98510\nLas Vegas, Nevada 89150\nCPF 5-2010-1006W\nDear Mr. McMurtrie:\nBetween May 17 and 21, 2010, and July 26 and 30, 2010, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected your Paiute Pipeline Company (Paiute) facilities in Nevada. In May, our\nrepresentative reviewed the Operation and Maintenance Manual and implementing records in\nCarson City, Nevada. In July, our representative conducted a field inspection of your northern\npipeline facilities between the Nevada/Idaho border and Lovelock, Nevada.\nAs a result of the inspection, it appears that Paiute has committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures for\nhandling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least one each calendar year. This\nmanual must be prepared before operations of a pipeline system commence. Appropriate\n\n\n\nparts of the manual must be kept at locations where operations and maintenance activities\nare conducted.\nPaiute did not follow their leak survey procedures presented in their Operations and Maintenance\n(O&M) manual. Their O&M manual states that leak surveys will be conducted in Class 3 areas\ntwo times each calendar year. At the time of the inspection, the operator’s records indicate that\ntwo Class 3 leakage surveys in 2008 were late. Specifically, the late leakage surveys were:\n1. The first survey in 2008 for the pipeline segment bounded between main line (ML)\nmileage reference ML 141.94 to ML 142.40. There is approximately one half miles of\npipeline right-of-way near the Rye Patch Reservoir campground where Paiute was late in\nconducting the leak survey by two (2) days.\n2. The first survey in 2008 for the pipeline segment on the Elko Lateral (EL) bounded by\nmileage reference EL 8.13 to EL 8.36. There is approximately ¼ miles of transmission\npipeline right-of-way near an industrial facility where Paiute was late in conducting the\nleakage survey by twelve (12) days.\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 put controls in place to ensure\ncompliance with Federal regulations, including implementation of all parts of your O&M manual\nas identified in this letter. Failure to do so will result in Paiute 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 5-2010-1006W. 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,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#128404)\n2","truncated":false,"body_characters":4753}