{"operation":"document","citation":"CPF 520161003W","title":"TRANSWESTERN PIPELINE COMPANY LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-10-26","effective_on":null,"summary":"CLOSED warning letter citing 192.467(a), 192.917(e)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520161003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520161003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520161003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520161003W","body":"Warning Letter involving TRANSWESTERN PIPELINE COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 192.467(a),  192.917(e)(1). The case was opened on 2016-10-26 and is reported as closed as of 2016-10-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520161003W_Operator Response to Notice_11232016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520161003W/520161003W_Operator%20Response%20to%20Notice_11232016.pdf\n\n520161003W_Warning Letter_10262016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520161003W/520161003W_Warning%20Letter_10262016.pdf\n\n520161003W_Warning Letter_10262016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520161003W/520161003W_Warning%20Letter_10262016_text.pdf\n\n520161003W_Warning Letter_10262016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 26, 2016\nMr. Ryan Coffey\nExecutive Vice President – Operations\nTranswestern Pipeline Company, LLC\n800 E. Sonterra Blvd.\nSan Antonio, TX 78258\nCPF 5-2016-1003W\nDear Mr. Coffey:\nBetween April and December 2015, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) and the Arizona Corporation Commission, pursuant to\nChapter 601 of 49 United States Code, inspected the Transwestern Pipeline system in Texas,\nNew Mexico, Colorado, Arizona and California.\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\nthe probable violation(s) are:\n\n\n\n1. §192.917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(e) Actions to address particular threats. If an operator identifies any of the\nfollowing threats, the operator must take the following actions to address the\nthreat.\n(1) Third party damage. An operator must utilize the data integration required\nin paragraph (b) of this section and ASME/ANSI B31.8S, Appendix A7 to\ndetermine the susceptibility of each covered segment to the threat of third party\ndamage. If an operator identifies the threat of third party damage, the operator\nmust implement comprehensive additional preventive measures in accordance\nwith §192.935 and monitor the effectiveness of the preventive measures. If, in\nconducting a baseline assessment under §192.921, or a reassessment under\n§192.937, an operator uses an internal inspection tool or external corrosion direct\nassessment, the operator must integrate data from these assessments with data\nrelated to any encroachment or foreign line crossing on the covered segment, to\ndefine where potential indications of third party damage may exist in the covered\nsegment.\nAn operator must also have procedures in its integrity management program\naddressing actions it will take to respond to findings from this data integration.\nEnergy Transfer failed to track the number of locate request tickets it receives in HCAs and\nintegrate that data as part of the process to evaluate the threat of Third Party Damage.\nThis evaluation is required in order to implement and evaluate comprehensive additional\npreventive measures to mitigate the threat of third party damage.\n2. § 192.467 External corrosion control: Electrical isolation.\n(a) Each buried or submerged pipeline must be electrically isolated from other\nunderground metallic structures, unless the pipeline and the other structures are\nelectrically interconnected and cathodically protected as a single unit.\nAs revealed by the annual Cathodic Protection Surveys, casings were not electrically isolated\nor “shorted” to the pipeline at multiple pipeline locations for the time period between 2012\nand 2015, the interval covered during this inspection. The casings must either be electrically\nisolated from the carrier pipeline or cathodically protected as a single unit.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2016-1003W. Be advised that all material you submit in response to this\n2\n\n\n\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#149794)\n3","truncated":false,"body_characters":5181}