IDAHO PIPELINE CORP — Warning Letter

520131005W_warning letter_04252013_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 25, 2013 Mr. Robert Rose President Idaho Pipeline Corporation P.O. Box 35236 Sarasota, FL 34242 CPF 5-2013-1005W Dear Mr. Rose: On November 26-29, 2012, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your operations and maintenance (O&M) procedures, records and performed a field evaluation of your facility in Boise, Idaho. 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 items inspected and the probable violation(s) are: 1. §195.410 Line markers. (a) Except as provided in paragraph (b) of this section, each operator shall place and maintain line markers over each buried pipeline in accordance with the following: (1) The marker must state at least the following on a background of sharply contrasting color: (ii) The name of the operator and a telephone number (including area code) where the operator can be reached at all times. Per §195.410, the operator must maintain line markers over each buried pipeline and must#

520131005W_warning letter_04252013_text.pdf, page 2include the number, including area code, where the operator can be reached. At the time of inspection, Boise Aviation Fuel Pipeline (BAFP) had several right-of-way (ROW) markers which had an incorrect number. In one instance, the sign was flipped over upside down. Idaho Pipeline Corporation (IPC) must maintain their ROW markers to have the correct phone number and ensure they are maintained properly, so as to be visible at all times by the general public and emergency response officials. 2. §195.434 Signs. Each operator must maintain signs visible to the public around each pumping station and breakout tank area. Each sign must contain the name of the operator and a telephone number (including area code) where the operator can be reached at all times. Per §195.434, the operator must maintain signs visible to the public and each sign must contain the telephone number, including area code. At the time of the inspection BAFP had several signs around the facility which did not have the updated phone number, or did not include the area code. One sign was completely faded and illegible. IPC must maintain their signage with the correct phone numbers and maintain them so that they are legible to the general public and emergency response officials. 3. §195.436 Security of facilities. Each operator shall provide protection for each pumping station and breakout tank area and other exposed facility (such as scraper traps) from vandalism and unauthorized entry. Per §195.436, the operator must ensure it provides protection for its facilities from vandalism and unauthorized entry. At the time of the inspection BAFP had its back gate on the airport side held together by two pieces of loosely wrapped metal wire. This rendered the gate nearly inoperable and allows the facility to be easily accessed. IPC must maintain their fencing and gates to ensure that they are not subject to vandalism or unauthorized entry. 4. §195.581 Which pipelines must I protect against atmospheric corrosion and what coating material may I use? (a) You must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section. (b) Coating material must be suitable for the prevention of atmospheric corrosion. (c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces, you need not protect against atmospheric corrosion any pipeline for which 2#

520131005W_warning letter_04252013_text.pdf, page 3you demonstrate by test, investigation, or experience appropriate to the environment of the pipeline that corrosion will- (1) Only be a light surface oxide; or (2) Not affect the safe operation of the pipeline before the next scheduled inspection. Per §195.581, the operator must clean and coat each pipeline that is exposed to the atmosphere. At the time of the inspection BAFP had several instances where the coating at the pipe-to-soil interface was compromised, and several instances where the coating was non- existent. IPC must maintain the pipe-to-soil wraps and coatings to prevent atmospheric corrosion. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a 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 Idaho Pipeline Corporation 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 5-2013-1005W. 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 D. Hubbard (#138087) 3#