# GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation

**Citation:** CPF 220051014  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2005-09-26

CLOSED notice of probable violation citing 192.465(d), 192.481(c), 192.613(a), 192.615(c), 192.619(a), 192.709(c), 192.739(a), 192.745(a).

## Document text

Notice of Probable Violation involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192,  192.465(d),  192.481(c),  192.613(a),  192.615(c),  192.619(a),  192.709(c),  192.739(a),  192.745(a). The case was opened on 2005-09-26 and is reported as closed as of 2006-07-20. Proposed civil penalty: $59,000. Assessed civil penalty: $59,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220051014_Final Order_06292006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220051014/220051014_Final%20Order_06292006.pdf

220051014_final order_06292006_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220051014/220051014_final%20order_06292006_text.pdf

CPF NO 2-2005-1014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220051014/CPF%20NO%202-2005-1014.pdf

220051014_final order_06292006_text.pdf

U S Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
400 Seventh Street, S W
Weehrngton, D C 20590
Mr John Earley
Seiuor Vice President
Gulf South Ptpelme Company, L P
20 East Greenway Plaza
Smte 900
Houston, Texas 77074
RE CPF No 2-2005-1014
Dear Mr Earley
Enclosed is the Final Order issued by the Associate Administrator for Pipehne Safety in
the above-referenced case It makes findings of violation and assesses a civil penalty of
$59, 000 The penalty payment terms are set forth in the Fmal Order This enforcement action
closes automattcally upon payment Your receipt of the Fmal Order constitutes service of that
document under 49 C F R I1 '190 5
Stncerely,
James Reynolds
Pipehne Comphance Registry
Office of Pipelme Safety
Enclosure
cc Ms Linda Daugherty, Director, Southern Region, OPS
CERTIFIED MAIL - RETURN RECEIPT RE UESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D. C. 20590
In the Matter of ) )
GULF SOUTH PIPELINE COMPANY, L. P.
, ) CPF No. 2-2005-1014
)
Respondent.
FINAL ORDER
Between October 12 -15, October 25-29 and December 6-10, 2004, pursuant to 49 U S C ht 60117,
representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Southern
Region, Office of Pipeline Safety conducted an on-site pipeline safety inspection of Respondent's
phpehne facdines m Alabama, Flortda, and Mississippi and reviewed records at Respondent's
Mobde, Alabama, Flowood, Mississippi, and Petal Mississippi offices As a result of the inspection,
the Director, Southern Region, OPS, issued to Respondent, by letter dated September 26, 2005, a
Notice of Probable Violation, and Proposed Civil Penalty (Notice) In accordance with 49 C F R
h'1 190 207, the Notice proposed finding that Respondent committed violations of 49 C. F R Part 192
and proposed assessing a total civil penalty of $59, 000 for the alleged violations
Respondent responded to the Notice by letter dated November 28, 2005 (Response) Respondent
dhd not contest the allegations of violation but offered an explanation and provided information
conceriung the corrective actions it has taken Respondent dkd not request a hearing, and therefore
has waived hts rtght to one
FINDINGS OF VIOLATION
Uncontested Violations
Respondent dhd not contest the alleged violations in Items 3 and 8 o f the Notice Accordingly, I find
that Respondent violated the following sections of 49 C F R Part 192 as more fully described m the
Notice
49 C F R 5 192 465(a) and (d) — failure to test each pipehne that hs under cathodic
protection at least once each calendar year, but with intervals not exceeding 15
months, to determine whether cathodic protection meets the requirements of Q
192 463 Respondent also failed to take prompt remedial action to correct any
deficiencies indicated by the monitormg,



49 C F R g 192 619(a) 1-4 — failure to operate a segment of steel or plastic pipehne
at a pressure that does not exceed the maximum allowable operating pressure On
November 6, 2004, a regulator and moiutor failed at Respondent's iYtustler's
Junction facihty causing an overpressure situation on its Pensacola 16" lme and
Courtaulds hne The pressure on the Pensacola 16" hne and Courtaulds lme
exceeded the line MAOP for 5 hours and 44 mmutes and exceeded 110% of MAOP
for 4 hours and 26 minutes
These findings of violation will be considered pnor offenses in any subsequent enforcement action
taken agiunst Respondent
ASSESSMENT OF PENALTY
Under 49 U S C tJ 60122, Respondent is subJect to a civil penalty not to exceed $100, 000 per
violation for each day of the violation up to a maximum of $1, 000, 000 for any related senes of
violations
49 U S C $ 60122 and 49 C F R $ 190 225 require that, in determining the amount of the civil
penalty, I consider the following cnteria nature, circumstances, and gravity of the violation, degree
of Respondent's culpability, history of Respondent's pnor offenses, Respondent's abdity to pay the
penalty, good faith by Respondent m attempting to achieve comphance, the effect on Respondent's
abdity to continue m business, and such other matters as Justice may require The Notice proposed
a total civil penalty of $59, 000 for violations of 49 C F R Part 192
Item 3 of the Notice proposed a civil penalty of $9, 000 for violation of 49 C F R g 192 465(a) and
(d), as Respondent fiuled to test each pipehne that is under cathodic protection at least once each
calendar year, but with intervals not exceeding 15 months, to determine whether cathodic protechon
meets the reqmrements of Q 192 463 Respondent also failed to take prompt remedial schon to
correct any deficiencies indicated by the mointonng Respondent did not contest the violation or the
civil penalty The risk of corrosion on the pipehne significantly increases without proper cathodic
protection systems Preventive maintenance is cntical to the safety of the public, environment and
property Accordingly, having reviewed the record and considered the assessment cntena, I assess
Respondent a civd penalty of $9, 000 for violation of 49 C F R. $ 192 465(a) and (d)
Item 8 of the Notice proposed a civil penalty of $50, 000 for violation of 49 C F R g 192 619(a), as
Respondent failed to operate a segment of steel or plastic pipehne at a pressure that does not exceed
the maximum allowable operating pressure On November 6, 2004, a regulator and momtor failed
at Respondent's Whistler's Junction facihty causing an overpressure situation on its Pensacola 16"
hne and Courtaulds hne The pressure on the Pensacola 16" lme and Courtaulds hne exceeded the
hne MAOP for 5 hours and 44 nunutes and exceeded 110% of MAOP for 4 hours and 26 minutes
Respondent did not contest the violation or the civil penalty Accordingly, having reviewed the
record and considered the assessment cnteria, I assess Respondent a civil penalty of $50, 000 for
violation for 49 C F R g 192 619(a)



Accordingly, having reviewed the record and considered the assessment cntena, I assess Respondent
a total civil penalty of $59, 000
Payment of the civil penalty must be made within 20 days of service Federal regulations
(49 C F R $ 89 21(b)(3)) require this payment be made by wire transfer, through the Federal Reserve
Communications System (Fedwtre), to the account of the U S Treasury Detmled instruchons are
contamed in the enclosure Questions concenung wire transfers should be duected to Financial
Operations Division (AMZ-300), Federal Aviation Administration, Mike Monroney Aeronautical
Center, P 0 Box 25082, Oklahoma City, OK 73125, (405) 954-8893
Fadure to pay the $59, 000 civil penalty will result m accrual of interest at the current annual rate m
accordancewtth31U S C 1'1 3717, 31 C F R 11 901 9and49C F R tt 89 23 Pursuanttothosesame
authonnes, a late penalty charge of six percent (6%) per annum will be charged if payment is not
made within 110 days of service Furthermore, failure to pay the civil penalty may result m referral
of the matter to the Attorney General for appropnate action m a United States Distnct Court
WARNING ITEMS
The Notice did not propose a civil penalty or comphance action for Items I, 2, 4, 5, 6 and 7 in the
Notice, therefore, these are considered warning items Respondent is warned that if it does not take
appropnate action to correct these items, enforcement action will be taken if a subsequent inspection
reveals a violation
Under 49 C F R tt 190 215, Respondent has a nght to submit a Petition for Reconsideration of this
Final Order The petition must be received within 20 days of Respondent's receipt of this Final
Order and must contain a bnef statement of the issue(s) The filmg of the petition automatically
stays the payment of any civil penalty assessed However if Respondent subnuts payment for the
civd penalty, the Final Order becomes the final administrative decision and the right to petition for
reconsideration is waived The terms and condktions of this Final Order are effective on receipt
JUN 29 ~00u
Date Issued
tac Gerard
so ate Administrator
ipelme Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220051014>
- Source ID: `phmsa-enforcement`
- SHA-256: `92d7a38e81f935b3335852a3b16fbfbaaebbac6d64056eede80b15482d03a537`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T20:59:47.197Z
- Document slug: `phmsa-enforcement-220051014`

### Source metadata

```json
{
  "cpf": "220051014",
  "operator": "GULF SOUTH PIPELINE COMPANY, LLC",
  "region": "Southern",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.465(d)",
    "192.481(c)",
    "192.613(a)",
    "192.615(c)",
    "192.619(a)",
    "192.709(c)",
    "192.739(a)",
    "192.745(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
  "attachments": [
    {
      "name": "220051014_Final Order_06292006.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220051014/220051014_Final%20Order_06292006.pdf",
      "bytes": 145121,
      "category": "agency_document"
    },
    {
      "name": "220051014_final order_06292006_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220051014/220051014_final%20order_06292006_text.pdf",
      "bytes": 156945,
      "category": "agency_document"
    },
    {
      "name": "CPF NO 2-2005-1014.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220051014/CPF%20NO%202-2005-1014.pdf",
      "bytes": 188223,
      "category": "case_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "GULF SOUTH PIPELINE COMPANY, LLC"
}
```
