{"operation":"document","citation":"CPF 520136002W","title":"WYOMING PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-06-26","effective_on":null,"summary":"CLOSED warning letter citing 195.404(c)(3), 195.420(c), 195.434, 195.436, 195.438, 195.575(c), 195.581(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520136002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520136002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520136002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520136002W","body":"Warning Letter involving WYOMING PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.404(c)(3),  195.420(c),  195.434,  195.436,  195.438,  195.575(c),  195.581(a). The case was opened on 2013-06-26 and is reported as closed as of 2013-06-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520136002W_warning letter_06262013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520136002W/520136002W_warning%20letter_06262013.pdf\n\n520136002W_warning letter_06262013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520136002W/520136002W_warning%20letter_06262013_text.pdf\n\n520136002W_warning letter_06262013_text.pdf\n\nWARNING LETTER\nVIA UPS 2ND DAY DELIVERY- 1Z WR2 578 02 9840 7727\nJune 26, 2013\nMr. Robert Neufeld\nVice President\nEnvironmental and Governmental Affairs\nWyoming Pipeline Co.\n1600 Broadway, Suite 2300\nDenver, CO 80202\nCPF 5-2013-6002W\nDear Mr. Neufeld:\nOn October 22-26, 2012, representatives 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 facilities in Newcastle, Wyoming.\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. §195.404 Maps and Records.\n(c) Each operator shall maintain the following records for the periods specified:\n(3) A record of each inspection and test required by this subpart shall be\nmaintained for at least 2 years or until the next inspection or test is performed,\nwhichever is longer.\n\n\n\nPer §195.404(c) (3), an operator shall maintain records of each inspection and test required by\nthis subpart for at least 2 years or until the next inspection or test is performed, whichever is\nlonger. At the time of the inspection, records of valve inspections in according to §195.420 were\nnot maintained as required by §195.404(c) (3).\n2. §195.420 Valve maintenance.\n(c) Each operator shall provide protection for each valve from unauthorized\noperation and from vandalism.\nPer §195.420(c), an operator shall provide valve protection to prevent unauthorized operation\nand vandalism. At the time of the inspection, several valves at the stations were not secured\nand/or locked from unauthorized operation and vandalism. Wyoming Pipeline Company (WPC)\nmust provide protection for each valve to prevent unauthorized operation and vandalism of their\nfacilities.\n3. §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 at\nall times.\nPer §195.434, an operator must maintain signs visible to the public and each sign must contain\nthe telephone number, including area code, where the operator can be reached at all times. At the\ntime of the inspection, WPC did not have the warning signs at several pump stations and\nbreakout tank facilities, e.g. Mush Creek and Mush Creek Junction.\n4. §195.436 Security of facilities.\nEach operator shall provide protection for each pumping station and breakout tank\narea and other exposed facility (such as scraper traps) from vandalism and\nunauthorized entry.\nPer §195.436, an operator must provide protection for each pump station and breakout tank area.\nAt the time of the inspection, there was minimal or no protection (fences) at most of the\nfacilities, e.g. Mush Creek and Mush Creek Junction.\n2\n\n\n\n5. §195.438 Smoking or open flames.\nEach operator shall prohibit smoking and open flames in each pump station area\nand each breakout tank area where there is a possibility of the leakage of a\nflammable hazardous liquid or of the presence of flammable vapors.\nPer §195.438, an operator shall prohibit smoking and open flames at each pump station and\nbreakout tank area. At the time of the inspection, the warning signs prohibiting smoking and\nopen flames were not visible at all applicable facilities.\n6. §195.575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n(c) You must inspect and electrically test each electrical isolation to assure the\nisolation is adequate.\nPer §195.575, an operator must electrically isolate each buried or submerged pipeline\nfrom other metallic structures, and install one or more insulating devices where electrical\nisolation of a pipeline is necessary. Each electrical isolation must be inspected and electrically\ntested to assure isolation is adequate. At the time of inspection, WPC did not perform tests to\nensure electrical isolation of each buried or submerged pipeline from other metallic structures,\nunless they electrically interconnect and cathodically protect the pipeline and the other structures\nas a single unit. Meanwhile, there is at least one casing at the US Highway 16 crossing near the\nend of the HCA segment in Newcastle in which the casing-to-soil potential reading is unknown.\nWPC must inspect and electrically test the US Highway 16 casing and others if they exist, to\nensure the isolation is adequate.\n7. §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.\nPer §195.581(a), an operator shall protect against atmospheric corrosion on the aboveground\nfacilities. At the time of the inspection, there were several locations where pipe at the air-to-soil\ninterface was not coated. In addition, some of the breakout tanks were not painted to protect\natmospheric corrosion, and an extensive surface rust and significant corrosion were visible at the\nchime and near the annular ring.\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\n3\n\n\n\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Wyoming Pipeline Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2013-6002W. 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 C. Allen/D. Hubbard (#139527)\n4","truncated":false,"body_characters":7619}