{"operation":"document","citation":"CPF 520171003W","title":"SFPP, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-02-24","effective_on":null,"summary":"CLOSED warning letter citing 192.467(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520171003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520171003W","body":"Warning Letter involving SFPP, LP. PHMSA's enforcement data identifies the cited regulation as 192.467(c). The case was opened on 2017-02-24 and is reported as closed as of 2017-02-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520171003W_Operator Response to Notice_04212017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171003W/520171003W_Operator%20Response%20to%20Notice_04212017.pdf\n\n520171003W_Warning Letter_02242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171003W/520171003W_Warning%20Letter_02242017.pdf\n\n520171003W_Warning Letter_02242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520171003W/520171003W_Warning%20Letter_02242017_text.pdf\n\n520171003W_Warning Letter_02242017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 24, 2017\nMr. Wayne Simmons\nChief Operating Officer – Products Piplines\nKinder Morgan Energy Partners\n1001 Louisiana St., Suite 1000\nHouston, TX, 77002\nCPF 5-2017-1003W\nDear Mr. Simmons:\nOn April 18, 2016 and June 24, 2016, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), and the Arizona Corporation Commission\n(AZCC), pursuant to Chapter 601 of 49 United States Code, inspected your KM SFPP, L.P.\nSouth System in California and Arizona.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation is:\n1. §192.467 External corrosion control: Electrical isolation\n(c) Except for unprotected copper inserted in ferrous pipe, each pipeline must be\nelectrically isolated from metallic casings that are in part of the underground\nsystem. However, if isolation is not achieved because it is impractical, other\nmeasures must be take to minimize corrosion of the pipeline inside the casing.\nAs revealed by the annual Cathodic Protection Surveys, the case crossing on the LS111\npipeline segment located at MP95.280 is “shorted” to the pipeline and not electrically isolated\n\n\n\nas required by §192.467 External corrosion control: Electrical isolation. The casing must\neither be electrically isolated from the carrier pipeline or cathodically protected as a single\nunit.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the item identified in this letter. Failure to do so will\nresult in Kinder Morgan Energy Partners being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-1003W. Be advised that all material you submit in response to this\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 (#152446)\n2","truncated":false,"body_characters":4134}