# PLAINS PIPELINE, L.P. — Warning Letter

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

Official case documents:

520135016W_warning letter_12242013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520135016W/520135016W_warning%20letter_12242013.pdf

520135016W_warning letter_12242013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520135016W/520135016W_warning%20letter_12242013_text.pdf

520135016W_warning letter_12242013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 24, 2013
Mr. Troy Valenzuela
Vice President of Environmental Health and Safety
Plains Pipeline, L.P.
333 Clay Street, Suite 1600
P.O. Box 4638
Houston, TX 77002
CPF 5-2013-5016W
Dear Mr. Valenzuela:
On March 19-21, 2013 and June 11-12, 2013, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Railroad Commission of Texas and New Mexico
Public Regulation Commission pursuant to Chapter 601 of 49 United States Code inspected your
Control Room Facilities in Midland, Texas. We inspected your control room personnel, control
systems, procedures and records.
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 violations are:
1. §195.446 (j)(2) Control room management
(j) Compliance and deviations. An operator must maintain for review during
inspection:



(2) Documentation to demonstrate that any deviation from the procedures required
by this section was necessary for the safe operation of the pipeline facility.
Plains did not follow Management of Change (MOC) procedures when changes were made to
the Pipeline Control Procedure Manual procedures. Additionally, changes were made to the
critical alarm type description and response priority.
Plains did not follow their Change Management Procedure, Section 7 of the Midland Control
Room Management Plan. Section 7.2, Communication During Changes to Pipeline Equipment
states that “pipeline systems/processes which are generally covered by the MOC process include
but are not limited to: purchase or sale of physical assets, new equipment coming online, retired
equipment going offline, operations and maintenance manuals, new or revised procedures,
operating responsibilities between pipeline controllers and field personnel or third-party
operations, field maintenance activity affecting pipeline control room operations, control system
changes, SCADA system changes.” At the time of the inspection, PHMSA representatives
discovered that several procedures from different manuals were consolidated into a Pipeline
Control Procedure Manual. The lack of documentation and interviews with control room staff
demonstrates that Plains did not follow their MOC procedure for modifying their Pipeline
Controller Procedure Manual.
2. §195.446(j)(1) Control room management
(j) Compliance and deviations. An operator must maintain for review during
inspection:
(1) Records that demonstrate compliance with the requirements of this section;
At the time of inspection, PHMSA representatives discovered several Abnormal Operations
forms (Form 103) were not completely filled out. The missing information included Maximum
Operating Pressure (MOP) information, signatures and dates, and the reviewer’s signature.
3. §195.446(j)(1) Control room management
(j) Compliance and deviations. An operator must maintain for review during
inspection:
(1) Records that demonstrate compliance with the requirements of this section;
2



There were not any records produced to demonstrate complying with this requirement to review
the controller training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 month.
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.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 2013-5016W. 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 K. Nguyen (#142641)
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