# WYOMING REFINING CO — Warning Letter

- **operation:** document
- **citation:** CPF 520186010W
- **title:** WYOMING REFINING CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-03-16
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.452(g)(2), 195.452(h)(2), 195.573(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520186010w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520186010w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520186010w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520186010W
**body:**

Warning Letter involving WYOMING REFINING CO. PHMSA's enforcement data identifies the cited regulations as 195.452(g)(2),  195.452(h)(2),  195.573(c). The case was opened on 2018-03-16 and is reported as closed as of 2018-03-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520186010W_Warning Letter_03162018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186010W/520186010W_Warning%20Letter_03162018.pdf

520186010W_Warning Letter_03162018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186010W/520186010W_Warning%20Letter_03162018_text.pdf

520186010W_Warning Letter_03162018_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 16, 2018
Mr. Michael E. Farnsworth
Vice President
Wyoming Refining Company
10 Stampede Street
Newcastle, WY 82701
CPF 5-2018-6010W
Dear Mr. Farnsworth:
On September 19, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Petroleum Product Pipeline to Mule Creek at Newcastle, Wyoming.
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(s) are:
1. §195.452 Pipeline integrity management in high consequence areas.
(g) What is an information analysis? In periodically evaluating the integrity of
each pipeline segment (paragraph (j) of this section), an operator must analyze
all available information about the integrity of the entire pipeline and the
consequences of a failure. This information includes:
(2) Data gathered through the integrity assessment required under this section.
Wyoming Refining Company (WRC) failed to analyze all available information about the
integrity of the Petroleum Product Pipeline. On September 19, 2017 during the PHMSA



inspection, it was noted that the last MFL/Caliper in-line inspection (ILI) was assessed on
February 13, 2016, and the information analysis for evaluating the data gathered from the
2016 ILI result was not adequate. Information such as unity plot, calculation of safe operating
pressure based on field-verified anomaly measurements, etc. were not provided in accordance
with §195.452(g)(2).
2. §195.452 Pipeline integrity management in high consequence areas.
(h) What actions must an operator take to address integrity issues?
(2) Discovery of condition. Discovery of a condition occurs when an operator has
adequate information about the condition to determine that the condition
presents a potential threat to the integrity of the pipeline. An operator must
promptly, but no later than 180 days after an integrity assessment, obtain
sufficient information about a condition to make that determination, unless the
operator can demonstrate that the 180-day period is impracticable.
Wyoming Refining Company (WRC) failed to promptly obtain sufficient information to make
the determination that a condition presents a potential threat to the integrity of the pipeline
within an HCA. It appears that WRC did not perform discovery of condition in accordance
with 195.452(h)(2) for the Petroleum Product Pipeline within 180 days after an integrity
assessment. It was noted that an integrity assessment for the Petroleum Product Pipeline was
assessed on February 13, 2016 and the date of discovery of condition for the Petroleum
Product Pipeline exceeded by about 270 days because there was not a timely verification of
ILI accuracy of identified pipeline anomalies.
3. §195.573 What must I do to monitor external corrosion control?
(c) Rectifiers and other devices. You must electrically check for proper
performance each device in the first column at the frequency stated in the second
column.
Device Check frequency
Rectifier At least six times each calendar year, but
with intervals not exceeding 2 ½ months
Reverse current switch
Diode
Interference bond whose failure
would jeopardize structural
protection
Other interference bond At least once each calendar year, but with
intervals not exceeding 15 months.
WRC failed to check for proper performance each interference bond in accordance with
§195.573(c). At Mule Creek Junction, WRC installed an interference bond whose failure
would jeopardize structural protection (critical). It was noted that the second critical bond
reading of 2017 was 2/28/17, and it was about 2 weeks late.
2



Under 49 U.S.C. § 60122 and 49 CFR §190.223, you are subject to a civil penalty not to
exceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022
for a related series of violations. For violations occurring prior to November 2, 2015, the
maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 for a related series of violations. We have reviewed the
circumstances and supporting documents involved in this case, and have decided not to
conduct additional enforcement action or penalty assessment proceedings at this time. We
advise you to correct the item(s) identified in this letter. Failure to do so will result in
Wyoming Refining Company being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2018-6010W. 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,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 C. Allen (#153592)
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