{"operation":"document","citation":"CPF 520131005W","title":"IDAHO PIPELINE CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-04-25","effective_on":null,"summary":"CLOSED warning letter citing 195.410(a)(1), 195.434, 195.436, 195.581.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520131005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520131005W","body":"Warning Letter involving IDAHO PIPELINE CORP. PHMSA's enforcement data identifies the cited regulations as 195.410(a)(1),  195.434,  195.436,  195.581. The case was opened on 2013-04-25 and is reported as closed as of 2013-04-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520131005W_warning letter_04252013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131005W/520131005W_warning%20letter_04252013.pdf\n\n520131005W_warning letter_04252013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520131005W/520131005W_warning%20letter_04252013_text.pdf\n\n520131005W_warning letter_04252013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 25, 2013\nMr. Robert Rose\nPresident\nIdaho Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 5-2013-1005W\nDear Mr. Rose:\nOn November 26-29, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\noperations and maintenance (O&M) procedures, records and performed a field evaluation of\nyour facility in Boise, Idaho.\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 violation(s) are:\n1. §195.410 Line markers.\n(a) Except as provided in paragraph (b) of this section, each operator shall place\nand maintain line markers over each buried pipeline in accordance with the\nfollowing:\n(1) The marker must state at least the following on a background of sharply\ncontrasting color:\n(ii) The name of the operator and a telephone number (including area\ncode) where the operator can be reached at all times.\nPer §195.410, the operator must maintain line markers over each buried pipeline and must\n\n\n\ninclude the number, including area code, where the operator can be reached. At the time of\ninspection, Boise Aviation Fuel Pipeline (BAFP) had several right-of-way (ROW) markers\nwhich had an incorrect number. In one instance, the sign was flipped over upside down. Idaho\nPipeline Corporation (IPC) must maintain their ROW markers to have the correct phone\nnumber and ensure they are maintained properly, so as to be visible at all times by the general\npublic and emergency response officials.\n2. §195.434 Signs.\nEach operator must maintain signs visible to the public around each pumping\nstation and breakout tank area. Each sign must contain the name of the operator\nand a telephone number (including area code) where the operator can be reached\nat all times.\nPer §195.434, the operator must maintain signs visible to the public and each sign must\ncontain the telephone number, including area code. At the time of the inspection BAFP had\nseveral signs around the facility which did not have the updated phone number, or did not\ninclude the area code. One sign was completely faded and illegible. IPC must maintain their\nsignage with the correct phone numbers and maintain them so that they are legible to the\ngeneral public and emergency response officials.\n3. §195.436 Security of facilities.\nEach operator shall provide protection for each pumping station and breakout\ntank area and other exposed facility (such as scraper traps) from vandalism and\nunauthorized entry.\nPer §195.436, the operator must ensure it provides protection for its facilities from vandalism\nand unauthorized entry. At the time of the inspection BAFP had its back gate on the airport\nside held together by two pieces of loosely wrapped metal wire. This rendered the gate nearly\ninoperable and allows the facility to be easily accessed. IPC must maintain their fencing and\ngates to ensure that they are not subject to vandalism or unauthorized entry.\n4. §195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(a) You must clean and coat each pipeline or portion of pipeline that is exposed to\nthe atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric\ncorrosion.\n(c) Except portions of pipelines in offshore splash zones or soil-to-air interfaces,\nyou need not protect against atmospheric corrosion any pipeline for which\n2\n\n\n\nyou demonstrate by test, investigation, or experience appropriate to the\nenvironment of the pipeline that corrosion will-\n(1) Only be a light surface oxide; or\n(2) Not affect the safe operation of the pipeline before the next scheduled\ninspection.\nPer §195.581, the operator must clean and coat each pipeline that is exposed to the\natmosphere. At the time of the inspection BAFP had several instances where the coating at the\npipe-to-soil interface was compromised, and several instances where the coating was non-\nexistent. IPC must maintain the pipe-to-soil wraps and coatings to prevent atmospheric\ncorrosion.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a 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 Idaho Pipeline Corporation\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2013-1005W. 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. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Hubbard (#138087)\n3","truncated":false,"body_characters":6530}