{"operation":"document","citation":"CPF 520105004W","title":"TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-02-18","effective_on":null,"summary":"CLOSED warning letter citing 195.432(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520105004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520105004W","body":"Warning Letter involving TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC. PHMSA's enforcement data identifies the cited regulation as 195.432(b). The case was opened on 2010-02-18 and is reported as closed as of 2010-02-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520105004W_operator response_03122010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105004W/520105004W_operator%20response_03122010.pdf\n\n520105004W_warning letter_02182010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105004W/520105004W_warning%20letter_02182010.pdf\n\n520105004W_warning letter_02182010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520105004W/520105004W_warning%20letter_02182010_text.pdf\n\n520105004W_warning letter_02182010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 18, 2010\nMr. Hugh Harden\nVP Operations & Engineering & EHS\nKinder Morgan Canada Inc.\nSuite 2700, Stock Exchange Building\n300 5th Ave. SW\nCalgary, Alberta T2P5J2\nCanada\nCPF 5-2010-5004W\nDear Mr. Harden:\nFrom September 25 to 29, 2009, representatives of the Washington Utilities and Transportation\nCommission (WUTC), pursuant to Chapter 601 of 49 United States Code, inspected your\nWashington crude oil pipeline facilities. As part of this inspection, they reviewed operation and\nmaintenance records at your Laurel office. The WUTC representatives also performed a field\ninspection of your breakout tanks T-170 & T-180 at the Laurel Station, T-130 at the Ferndale\nStation, and T-7 inside the Shell refinery.\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. §195.432 Breakout tanks.\n(b) Each operator shall inspect the physical integrity of in-service atmospheric and\nlow-pressure steel aboveground breakout tanks according to section 4 of API\nStandard 653. However, if structural conditions prevent access to the tank bottom,\nthe bottom integrity may be assessed according to a plan included in the operations\nand maintenance manual under §195.402(c)(3).\n\n\n\nDuring the field inspection it was observed that the mastic along the external chime area has\ndeteriorated. This allowed the water to get under the chime to create corrosion on the chime. In\naddition, the drainage around the tank is poor thereby allowing standing water to collect on one\nside of the tank, especially during the rainy season.\nThe referenced Section 4 of API Standard 653 requires:\n“4.3.1 Routine In-Service Inspections\n4.3.1.3 This routine in-service inspection shall include a visual inspection of the tank’s\nexterior surfaces. Evidence of leaks; shell distortions; signs of settlement; corrosion;\nand condition of the foundation, paint coatings, insulation systems, and appurtenances\nshould be documented for follow-up action by an authorized inspector.”\nThe need for follow-up actions are not being documented or implemented.\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 Canada 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 5-2010-5004W. 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 T. Finch (#123860) and R. Reineke\nWashington Utilities Commission - David Lykken\n2","truncated":false,"body_characters":4489}