{"operation":"document","citation":"CPF 520115002W","title":"SFPP, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2011-02-23","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520115002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520115002W","body":"Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulation as 195.428(a). The case was opened on 2011-02-23 and is reported as closed as of 2011-02-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520115002W_warning letter_02232011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115002W/520115002W_warning%20letter_02232011.pdf\n\n520115002W_warning letter_02232011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520115002W/520115002W_warning%20letter_02232011_text.pdf\n\n520115002W_warning letter_02232011_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 23, 2011\nMr. Ron McClain\nVice President of Operations and Engineering\nKinder Morgan Energy Partners, L. P., Products Pipelines\n500 Dallas Street\nHouston, TX 77002\nCPF 5-2011-5002W\nDear Mr. McClain:\nFrom June 1, 2010 to June 3, 2010, a representative of the California State Fire Marshal\nrepresenting the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nConcord to Sacramento (LS130) pipeline system. As part of this inspection, he reviewed\nrecords at your offices in Concord, Fairfield, and Sacramento, California.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The probable violation is:\n1. §195.428 (a) Overpressure safety devices\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in\nthe case of pipelines used to carry highly volatile liquids, at intervals not to\nexceed 7½ months, but at least twice each calendar year, inspect and test each\npressure limiting device, relief valve, pressure regulator, or other item of\npressure control equipment to determine that it is functioning properly, is in\ngood mechanical condition, and is adequate from the standpoint of capacity\nand reliability of operation for the service in which it is used.\n\n\n\nKinder Morgan failed to inspect the Wickland take-off pressure relief valve (SX-PSV-1) at the\nrequired interval. This pressure relief valve protects LS130 by bypassing the closed SX block\nvalve when shipping to Wickland. This valve was installed on August 31, 2005 but was not\ncalibrated until May 25, 2010 when Kinder Morgan added this valve to their “OPS Info”\ninspection tracking program. The May 25, 2010 calibration record for the SX-PSV-1 valve\nnoted the “found” set point as 1,115 psig and the “left” set point as 1,100 psig, demonstrating it\nwas still functioning at close to the correct set point. Regardless, this pressure relief valve\nexceeded the testing interval by approximately three years and six months.\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 Energy Partners, L.P. being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2011-5002W. 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 (Activity #128416)\nCalifornia State Fire Marshal - Mr. Bob Gorham\n2","truncated":false,"body_characters":4369}