{"operation":"document","citation":"CPF 520155009W","title":"OLYMPIC PIPE LINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-03-27","effective_on":null,"summary":"CLOSED warning letter citing 195.573(a)(1), 195.573(c), 195.583(a), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155009W","body":"Warning Letter involving OLYMPIC PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.573(a)(1),  195.573(c),  195.583(a),  195.589(c). The case was opened on 2015-03-27 and is reported as closed as of 2015-03-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520155009W_warning letter_03272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155009W/520155009W_warning%20letter_03272015.pdf\n\n520155009W_warning letter_03272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155009W/520155009W_warning%20letter_03272015_text.pdf\n\n520155009W_warning letter_03272015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 27, 2015\nMr. Donald Porter\nPresident\nOlympic Pipe Line Company\nBP Pipeline NA\n150 W. Warrenville Rd.\nNaperville, IL 60563\nCPF 5-2015-5009W\nDear Mr. Porter:\nBetween August 11, 2014 and August 29, 2014, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) and Washington Utilities and Transportation\nCommission (WUTC), pursuant to Chapter 601 of 49 United States Code, inspected your Olympic\nPipe Line (OPL) system in the States of Oregon and Washington.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolations are:\n1. §195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195.571:\n(1) Conduct tests on the protected pipeline at least once each calendar year, but with\nintervals not exceeding 15 months. However, if tests at those intervals are impractical\nfor separately protected short sections of bare or ineffectively coated pipelines, testing\nmay be done at least once every 3 calendar years, but with intervals not exceeding 39\nmonths.\n\n\n\nOlympic Pipe Line Co (OPL) did not comply with §195.573(a)(1) in 2012 and 2013. Prior to our\ninspection, OPL personnel met with WUTC representatives to disclose that their annual pipe-to-soil\npotential tests conducted between 2012 and 2013 exceeded the maximum testing interval of 15\nmonths. Our review of OPL’s test records for annual pipe-to-soil potential readings, which\ndetermine adequacy of cathodic protection (CP), confirmed that the CP inspections exceeded the\nmaximum inspection frequency a total of 121 times between 2012 and 2013.\nSpecifically, the number of late test readings are as follows:\n• 78 late annual pipe-to-soil readings in 2013 for the North Unit of Washington State (Cherry\nPt. to Renton Station), and\n• 20 late annual pipe-to-soil readings in 2012, and 23 late annual pipe-to-soil readings in\n2013 for the South Unit of Washington State (Renton Station to WA/OR State Boundary).\n2. §195.573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper performance\neach device in the first column at the frequency stated in the second column.\nAt least six times each calendar year,\nbut with intervals not exceeding 2 ½\nmonths\nDevice Check frequency\nRectifier……………………………\nReverse current switch.\nDiode.\nInterference bond whose failure would\njeopardize structural protection\n(critical bond).\nOther interference bond…………. At least once each calendar year, but\nwith intervals not exceeding 15\nmonths.\nOPL did not comply with Part 195.573(c) which requires checking the rectifier and critical bond\ndevices for proper performance. OPL personnel met with WUTC representatives to disclose their\nrectifier and critical bond checks exceeded the time monitoring intervals required by Part\n195.573(c). Our review of records confirmed there was a total of six (6) rectifier or bond checks\nthat exceeded the maximum time monitoring intervals for inspection. The late readings are as\nfollows:\n• Three (3) late rectifier readings and two (2) late critical bond readings in 2013 for the OPL\nNorth Unit of Washington State, and\n• One (1) late critical bond readings in 2013 for the OPL South Unit of Washington State\n2\n\n\n\n3. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in sufficient\ndetail to demonstrate the adequacy of corrosion control measures or that corrosion\nrequiring control measures does not exist. You must retain these records for at least 5\nyears, except that records related to Secs. 195.569, 195.573(a) and (b), and\n195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service.\nOPL failed to fully follow their corrosion control procedures, OPL Procedure P195.551.2.2 states,\n“Any AC interference on pipeline 15 Volts AC or greater will be investigated and remediated as\nnecessary.” Furthermore, investigation records were not produced during the inspection to show\nimplementation of your corrosion control procedures. It was noted that OPL did not maintain\nrecords for investigating potential AC interference. The number of AC readings that exceeded 15\nVolts AC is as follows:\n• Four (4) in 2011 and ten (10) in 2013 for the North Unit of Washington State, and\nEight (8) in 2011 and six (6) in 2013 for the South Unit of Washington State (primarily in\nKing County).\n4. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection\nis:\nOnshore…………………………………. At least once every 3 calendar years, but\nwith intervals not exceeding 39 months.\nOffshore………………………………… At least once each calendar year, but with\nintervals not exceeding 15 months.\nOPL did not comply with Part 195.583(a) for inspecting each pipeline or portion of pipeline for\nevidence of atmospheric corrosion. During the field inspection, it was noted that metal jacketed\ninsulation on prover pipe at several of the pump stations prevented actual inspection of the pipeline\nfor atmospheric corrosion. Pipelines with removable insulation jackets or non-removable jackets\nwith inspection ports must be inspected at least once every 3 years (not to exceed 15 months) for\nevidence of atmospheric corrosion.\n3\n\n\n\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 exceed\n$100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in\nthis case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the items identified in this letter. Failure to do\nso will result in Olympic Pipe Line Co being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2015-5009W. 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 you\nbelieve qualify for confidential treatment redacted and an explanation of why you believe the\nredacted 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 and WUTC\nItem 1 through 4 – Activity #147690 and #147691\n4","truncated":false,"body_characters":8134}