{"operation":"document","citation":"CPF 520126001W","title":"SFPP, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-01-18","effective_on":null,"summary":"CLOSED warning letter citing 195.589(a)(2), 195.589(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520126001W","body":"Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulations as 195.589(a)(2),  195.589(b). The case was opened on 2012-01-18 and is reported as closed as of 2012-01-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520126001W_warning letter_01182012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126001W/520126001W_warning%20letter_01182012.pdf\n\n520126001W_warning letter_01182012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126001W/520126001W_warning%20letter_01182012_text.pdf\n\n520126001W_warning letter_01182012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 18, 2012\nMr. Ron McClain\nVice President of Operations and Engineering\nKinder Morgan Energy Partners, L. P., Products Pipelines\n500 Dallas Street\nHouston, TX 77002\nCPF 5-2012-6001W\nDear Mr. McClain:\nOn June 22, 2011, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), the California State Fire Marshal (CSFM), and the Arizona\nCorporation Commission (ACC) representing the U.S. Department of Transportation, Pipeline\nand Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49\nUnited States Code, performed a follow-up inspection of Item #13C of the Consent Agreement.\nAs part of this inspection, we reviewed records at your offices in Orange, California.\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. §195.589 What corrosion control information do I have to maintain?\n(a) You must maintain current records or maps to show the location of--\n(2) Cathodic protection facilities, including galvanic anodes, installed after\nJanuary 28, 2002;\n\n\n\nDuring the records review of item #13C of the Consent Agreement, it was noted that Kinder\nMorgan did not update their maps and/or records in a timely manner. Specifically, the 2008\ninstallation of Electrolysis Test Station (ETS) on the CalNev 8-inch between Bracken Jct and\nLas Vegas was not included on Kinder Morgan’s maps and records after more than three (3)\nyears. Therefore, we consider the maps reviewed not to be current.\n2. §195.589 What corrosion control information do I have to maintain?\n(b) Records or maps showing a stated number of anodes, installed in a stated\nmanner or spacing, need not show specific distances to each buried anode.\nDuring the records review of item #13C of the Consent Agreement, it was noted that Kinder\nMorgan did not update their maps and/or records in a timely manner. Specifically, the 2009\ninstallation of sacrificial anodes on the 6”/4” Adelando to George Terminal pipeline and the 6”\nGeorge Terminal to Edwards AFB pipeline were not included after two (2) years.\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 5-2012-6001W. 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 H. Nguyen (#117865)","truncated":false,"body_characters":4278}