# TRANS MOUNTAIN PIPELINE (PUGET SOUND) LLC — Warning Letter

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

Official case documents:

520155007W_warning letter_02252015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155007W/520155007W_warning%20letter_02252015.pdf

520155007W_warning letter_02252015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155007W/520155007W_warning%20letter_02252015_text.pdf

520155007W_warning letter_02252015_text.pdf

WARNING 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).



At 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)
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