TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC — Warning Letter

520155007W_warning letter_02252015_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED February 25, 2015 Mr. Hugh Harden V.P. Operations Engineering EHS Trans Mountain Pipeline (Puget Sound), LLC 2700, 300 - 5th Ave, SW Calgary, AB, Canada T2P 5J2 CPF 5-2015-5007W Dear Mr. Harden: On October 7-10, 2014, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Trans Mountain Pipeline system in Bellingham, Washington. 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 is: 1. § 195.432 Inspection of in-service breakout tanks. (b) Each operator must inspect the physical integrity of in-service atmospheric and low-pressure steel aboveground breakout tanks according to API Standard 653 (incorporated by reference, see § 195.3). However, if structural conditions prevent access to the tank bottom, the bottom integrity may be assessed according to a plan included in the operations and maintenance manual under § 195.402(c)(3).#

520155007W_warning letter_02252015_text.pdf, page 2At the time of the inspection, Trans Mountain Pipeline exceeded the 5-year in-service inspection interval requirement for breakout tanks T-130, T-170, and T-180 as required by API Standard 653. Although these tanks were inspected in 2014, the 5-year in-service inspection for these breakout tanks was required to be performed by the end of the year 2013 to meet API Standard 653. 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 5-2015-5007W. 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. Mulligan Activity #149232 (I05) 2#