{"operation":"document","citation":"CPF 520176015W","title":"WYOMING PIPELINE COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-16","effective_on":null,"summary":"CLOSED warning letter citing 194.107(c)(1)(viii), 195.432(b), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520176015W","body":"Warning Letter involving WYOMING PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 194.107(c)(1)(viii),  195.432(b),  195.589(c). The case was opened on 2017-05-16 and is reported as closed as of 2017-05-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520176015W_Warning Letter_05162017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176015W/520176015W_Warning%20Letter_05162017.pdf\n\n520176015W_Warning Letter_05162017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176015W/520176015W_Warning%20Letter_05162017_text.pdf\n\n520176015W_Warning Letter_05162017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 16, 2017\nMr. James Runyan\nPresident\nWyoming Pipeline Company\n10 Stampede Street\nNewcastle, WY 82701\nCPF 5-2017-6015W\nDear Mr. Runyan:\nDuring the week of December 12, 2016, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected your Wyoming Pipeline Company’s (WPC) crude oil pipeline facilities in the\nNewcastle Area of Wyoming.\nAs a result of the inspection, it is alleged 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:\n1. §194.107 General Response Plan Requirements\n(c) Each response plan must include:\n(1) A core plan consisting of-\n(viii) Equipment testing.\n\n\n\nWyoming Pipeline Company (WPC) failed to perform testing of emergency response\nequipment in 2014 as required by §194.107(c)(1)(viii).\n2. §195.432 Inspection of in-service breakout tanks.\n(b) Each operator must inspect the physical integrity of in-service atmospheric\nand low-pressure steel above-ground breakout tanks according to API Std 653\n(except section 6.4.3, Alternative Internal Inspection Interval) (incorporated by\nreference, see §195.3). However, if structural conditions prevent access to the\ntank bottom, its integrity may be assessed according to a plan included in the\noperations and maintenance manual under §195.402(c)(3). The risk- based\ninternal inspection procedures in API Std 653, section 6.4.3 cannot be used to\ndetermine the internal inspection interval.\nWPC failed to comply with §195.432(b) which requires compliance with API Standard 653.\nRecords for Routine In-Service inspections (monthly) were not produced for 28 breakout tank\ninspections in 2015:\n In June of 2015, five (5) tank inspection records missing for HA Creek and Fiddler\nbreakout tank facilities.\n In July of 2015, six (6) tank inspection records missing for HA Creek, Butte, and\nFiddler breakout tank facilities.\n In August of 2015, all 17 tank inspection records missing across this crude system’s\nbreakout tank facilities.\nFurthermore, prior to our inspection, Par Pacific Holdings, parent company to WPC, hired\nPinnacle to review the breakout tank Internal and/or External inspection records. In this\nreview, 14 of 17 breakout tanks in this crude system were found not to be in compliance with\nAPI 653 because the inspections were not performed by a certified API 653 Authorized\nInspector (AI), and there were questions about valid inspection processes.\n3. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs.\n195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as\nlong as the pipeline remains in service.\nWPC failed to comply with §195.589(c) by not sufficiently documenting corrosion control\nactivities involving inspection of internal pipe surfaces. The internal inspection of the pipe\ncutout performed on November 30, 2016 from the 6-inch Butte to Newcastle segment (log\ndistance 6157.84) was not sufficiently documented. An internal surface inspection of pipe in\n2\n\n\n\nthe vicinity of the removed pipe is required by §195.579(c) that gives sufficient information\nas to whether additional corrosion requiring remediation exists.\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(s) identified in this letter. Failure to do so will\nresult in Wyoming Pipeline Company 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 5-2017-6015W. 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 C. Allen (# 153591)\n3","truncated":false,"body_characters":6198}