# PAIUTE PIPELINE CO — Warning Letter

- **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:** Not available
- **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.

Official case documents:

520101006W_warning letter_09212010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101006W/520101006W_warning%20letter_09212010.pdf

520101006W_warning letter_09212010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520101006W/520101006W_warning%20letter_09212010_text.pdf

520101006W_warning letter_09212010_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 21, 2010
Mr. Edward McMurtrie
Vice President
Paiute Pipeline Company
P.O. Box 98510
Las Vegas, Nevada 89150
CPF 5-2010-1006W
Dear Mr. McMurtrie:
Between May 17 and 21, 2010, and July 26 and 30, 2010, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United
States Code inspected your Paiute Pipeline Company (Paiute) facilities in Nevada. In May, our
representative reviewed the Operation and Maintenance Manual and implementing records in
Carson City, Nevada. In July, our representative conducted a field inspection of your northern
pipeline facilities between the Nevada/Idaho border and Lovelock, Nevada.
As a result of the inspection, it appears that Paiute has committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
1. §192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include procedures for
handling abnormal operations. This manual must be reviewed and updated by the
operator at intervals not exceeding 15 months, but at least one each calendar year. This
manual must be prepared before operations of a pipeline system commence. Appropriate



parts of the manual must be kept at locations where operations and maintenance activities
are conducted.
Paiute did not follow their leak survey procedures presented in their Operations and Maintenance
(O&M) manual. Their O&M manual states that leak surveys will be conducted in Class 3 areas
two times each calendar year. At the time of the inspection, the operator’s records indicate that
two Class 3 leakage surveys in 2008 were late. Specifically, the late leakage surveys were:
1. The first survey in 2008 for the pipeline segment bounded between main line (ML)
mileage reference ML 141.94 to ML 142.40. There is approximately one half miles of
pipeline right-of-way near the Rye Patch Reservoir campground where Paiute was late in
conducting the leak survey by two (2) days.
2. The first survey in 2008 for the pipeline segment on the Elko Lateral (EL) bounded by
mileage reference EL 8.13 to EL 8.36. There is approximately ¼ miles of transmission
pipeline right-of-way near an industrial facility where Paiute was late in conducting the
leakage survey by twelve (12) days.
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 put controls in place to ensure
compliance with Federal regulations, including implementation of all parts of your O&M manual
as identified in this letter. Failure to do so will result in Paiute being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2010-1006W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies 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 believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 B. Brown (#128404)
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