{"operation":"document","citation":"CPF 520126002W","title":"SHELL PIPELINE CO., L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-02-22","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520126002W","body":"Warning Letter involving SHELL PIPELINE CO., L.P.. PHMSA's enforcement data identifies the cited regulations as 195.428(a),  195.583(a). The case was opened on 2012-02-22 and is reported as closed as of 2012-02-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520126002W_warning letter_02222012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126002W/520126002W_warning%20letter_02222012.pdf\n\n520126002W_warning letter_02222012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126002W/520126002W_warning%20letter_02222012_text.pdf\n\n520126002W_warning letter_02222012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 22, 2012\nMr. Greg Smith\nPresident\nShell Pipeline Co., LP\nTwo Shell Plaza\n777 Walker, Rm. 1437\nHouston, TX 77002\nCPF 5-2012-6002W\nDear Mr. Smith:\nOn September 12-15, 2011, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nPortland Breakout Tanks facility in Portland, Oregon.\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 items inspected and\nthe probable violations are:\n1. §195.428 Overpressure safety devices and overfill protection systems.\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 the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed\n7½ months, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\n\n\n\nAt the time of the inspection, Shell Pipeline Co., LP staff could not provide records showing\nthey inspected and tested all of the facility’s pressure control equipment (thermal relief\ndevices) in 2008. The records were available, however, for the 2009 and 2010 years. Shell\nmust ensure that all relief device inspection and testing is conducted at the required time\ninterval.\n2. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years,\nbut with intervals not exceeding 39 months\nOffshore At least once each calendar year, but\nwith intervals not exceeding 15 months\n(b) During inspections you must give particular attention to pipe at soil-to-air\ninterfaces, under thermal insulation, under disbonded coatings, at pipe supports,\nin splash zones, at deck penetrations, and in spans over water.\nDuring the inspection, it was identified that while the pipes and supports were recently\npainted (coated), however, there is metal to metal contact between the pipe and the pipe\nsupports. The operator did not have atmospheric monitoring reports for this pipe to pipe\nsupport contact. Atmospheric corrosion monitoring is required at least once every three years,\nbut with intervals not exceeding 39 months, to demonstrate that no atmospheric corrosion at\nthe pipe to pipe support interface is taking place.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in Shell Pipeline Co., LP being\nsubject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2012-6002W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nSincerely,\nChristopher Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Coleman (#132877)","truncated":false,"body_characters":4982}