{"operation":"document","citation":"CPF 520155007W","title":"TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-02-25","effective_on":null,"summary":"CLOSED warning letter citing 195.432(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155007W","body":"Warning Letter involving TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC. PHMSA's enforcement data identifies the cited regulation as 195.432(b). The case was opened on 2015-02-25 and is reported as closed as of 2015-02-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520155007W_warning letter_02252015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155007W/520155007W_warning%20letter_02252015.pdf\n\n520155007W_warning letter_02252015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155007W/520155007W_warning%20letter_02252015_text.pdf\n\n520155007W_warning letter_02252015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 25, 2015\nMr. Hugh Harden\nV.P. Operations Engineering EHS\nTrans Mountain Pipeline (Puget Sound), LLC\n2700, 300 - 5th Ave, SW\nCalgary, AB, Canada\nT2P 5J2\nCPF 5-2015-5007W\nDear Mr. Harden:\nOn October 7-10, 2014, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nTrans Mountain Pipeline system in Bellingham, Washington.\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 violation is:\n1. § 195.432 Inspection of in-service breakout tanks.\n(b) Each operator must inspect the physical integrity of in-service atmospheric and\nlow-pressure steel aboveground breakout tanks according to API Standard 653\n(incorporated by reference, see § 195.3). However, if structural conditions prevent\naccess to the tank bottom, the bottom integrity may be assessed according to a plan\nincluded in the operations and maintenance manual under § 195.402(c)(3).\n\n\n\nAt the time of the inspection, Trans Mountain Pipeline exceeded the 5-year in-service inspection\ninterval requirement for breakout tanks T-130, T-170, and T-180 as required by API Standard\n653. Although these tanks were inspected in 2014, the 5-year in-service inspection for these\nbreakout tanks was required to be performed by the end of the year 2013 to meet API Standard\n653.\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 5-2015-5007W. 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 D. Mulligan\nActivity #149232 (I05)\n2","truncated":false,"body_characters":3444}