{"operation":"document","citation":"CPF 520135016W","title":"PLAINS PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-12-24","effective_on":null,"summary":"CLOSED warning letter citing 195.446(j)(1), 195.446(j)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520135016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520135016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520135016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520135016W","body":"Warning Letter involving PLAINS PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulations as 195.446(j)(1),  195.446(j)(2). The case was opened on 2013-12-24 and is reported as closed as of 2013-12-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520135016W_warning letter_12242013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520135016W/520135016W_warning%20letter_12242013.pdf\n\n520135016W_warning letter_12242013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520135016W/520135016W_warning%20letter_12242013_text.pdf\n\n520135016W_warning letter_12242013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 24, 2013\nMr. Troy Valenzuela\nVice President of Environmental Health and Safety\nPlains Pipeline, L.P.\n333 Clay Street, Suite 1600\nP.O. Box 4638\nHouston, TX 77002\nCPF 5-2013-5016W\nDear Mr. Valenzuela:\nOn March 19-21, 2013 and June 11-12, 2013, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Railroad Commission of Texas and New Mexico\nPublic Regulation Commission pursuant to Chapter 601 of 49 United States Code inspected your\nControl Room Facilities in Midland, Texas. We inspected your control room personnel, control\nsystems, procedures and records.\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 the\nprobable violations are:\n1. §195.446 (j)(2) Control room management\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n\n\n\n(2) Documentation to demonstrate that any deviation from the procedures required\nby this section was necessary for the safe operation of the pipeline facility.\nPlains did not follow Management of Change (MOC) procedures when changes were made to\nthe Pipeline Control Procedure Manual procedures. Additionally, changes were made to the\ncritical alarm type description and response priority.\nPlains did not follow their Change Management Procedure, Section 7 of the Midland Control\nRoom Management Plan. Section 7.2, Communication During Changes to Pipeline Equipment\nstates that “pipeline systems/processes which are generally covered by the MOC process include\nbut are not limited to: purchase or sale of physical assets, new equipment coming online, retired\nequipment going offline, operations and maintenance manuals, new or revised procedures,\noperating responsibilities between pipeline controllers and field personnel or third-party\noperations, field maintenance activity affecting pipeline control room operations, control system\nchanges, SCADA system changes.” At the time of the inspection, PHMSA representatives\ndiscovered that several procedures from different manuals were consolidated into a Pipeline\nControl Procedure Manual. The lack of documentation and interviews with control room staff\ndemonstrates that Plains did not follow their MOC procedure for modifying their Pipeline\nController Procedure Manual.\n2. §195.446(j)(1) Control room management\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n(1) Records that demonstrate compliance with the requirements of this section;\nAt the time of inspection, PHMSA representatives discovered several Abnormal Operations\nforms (Form 103) were not completely filled out. The missing information included Maximum\nOperating Pressure (MOP) information, signatures and dates, and the reviewer’s signature.\n3. §195.446(j)(1) Control room management\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n(1) Records that demonstrate compliance with the requirements of this section;\n2\n\n\n\nThere were not any records produced to demonstrate complying with this requirement to review\nthe controller training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 month.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2013-5016W. 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 K. Nguyen (#142641)\n3","truncated":false,"body_characters":5251}