# SFPP, LP — Warning Letter

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

Official case documents:

520126001W_warning letter_01182012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126001W/520126001W_warning%20letter_01182012.pdf

520126001W_warning letter_01182012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126001W/520126001W_warning%20letter_01182012_text.pdf

520126001W_warning letter_01182012_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 18, 2012
Mr. Ron McClain
Vice President of Operations and Engineering
Kinder Morgan Energy Partners, L. P., Products Pipelines
500 Dallas Street
Houston, TX 77002
CPF 5-2012-6001W
Dear Mr. McClain:
On June 22, 2011, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), the California State Fire Marshal (CSFM), and the Arizona
Corporation Commission (ACC) representing the U.S. Department of Transportation, Pipeline
and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49
United States Code, performed a follow-up inspection of Item #13C of the Consent Agreement.
As part of this inspection, we reviewed records at your offices in Orange, California.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The probable violations
are:
1. §195.589 What corrosion control information do I have to maintain?
(a) You must maintain current records or maps to show the location of--
(2) Cathodic protection facilities, including galvanic anodes, installed after
January 28, 2002;



During the records review of item #13C of the Consent Agreement, it was noted that Kinder
Morgan did not update their maps and/or records in a timely manner. Specifically, the 2008
installation of Electrolysis Test Station (ETS) on the CalNev 8-inch between Bracken Jct and
Las Vegas was not included on Kinder Morgan’s maps and records after more than three (3)
years. Therefore, we consider the maps reviewed not to be current.
2. §195.589 What corrosion control information do I have to maintain?
(b) Records or maps showing a stated number of anodes, installed in a stated
manner or spacing, need not show specific distances to each buried anode.
During the records review of item #13C of the Consent Agreement, it was noted that Kinder
Morgan did not update their maps and/or records in a timely manner. Specifically, the 2009
installation of sacrificial anodes on the 6”/4” Adelando to George Terminal pipeline and the 6”
George Terminal to Edwards AFB pipeline were not included after two (2) years.
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 correct the item(s) identified in this
letter. Failure to do so will result in Kinder Morgan Energy Partners, L.P. 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 5-2012-6001W. 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 H. Nguyen (#117865)
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