# GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter

**Citation:** CPF 420151010W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-10-13

CLOSED warning letter citing 192.619(a).

## Document text

Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.619(a). The case was opened on 2015-10-13 and is reported as closed as of 2015-10-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420151010W_Warning_10132015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151010W/420151010W_Warning_10132015.pdf

420151010W_Warning_10132015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151010W/420151010W_Warning_10132015_text.pdf

420151010W_Warning_10132015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 13, 2015
Mr. Richard Keyser
Senior Vice President of Operations
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
CPF 4-2015-1010W
Dear Mr. Keyser:
Between January 12, 2015 and August 28, 2015, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
reviewed Safety Related Condition Report 20150005 submitted January 12, 2015, by Gulf South
Pipeline Company, LP (Gulf South) for a safety related incident that occurred in St. Charles
Parish, LA.
As a result of the review, it appears that you have committed a probable violation of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable
violation is:
1. § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.
(a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a
maximum allowable operating pressure determined under paragraph (c) or (d) of this
section…
As indicated in your Safety Related Condition Report, Gulf South experienced an overpressure
condition that met the reporting criteria for a safety related condition. On January 8, 2015, a



portion of your Baton Rouge to Napoleonville Unit, Index Number 270-65 pipeline was operated
at a pressure that exceeded the maximum allowable operating pressure for the line. The
established MAOP for the line, at the time of the event and report was 376 PSIG. The MAOP
was exceeded when the maximum pressures climbing to 525 PSIG range. The maximum
pressures exceeded 110% the MAOP of the line at the time of the event.
This event is reflected in the Safety Related Condition Report you filed with PHMSA. 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.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2015-1010W. 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,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Jeff McMaine, Manager, Codes & Standards, 3800 Frederica Street, Owensboro, KY 42301
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420151010W>
- Source ID: `phmsa-enforcement`
- SHA-256: `a17f8d4a8a9f099f82b335b7d3a9946311650fc6415f0a4868e84e25174ae566`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T23:40:01.177Z
- Document slug: `phmsa-enforcement-420151010w`

### Source metadata

```json
{
  "cpf": "420151010W",
  "operator": "GULF SOUTH PIPELINE COMPANY, LLC",
  "region": "Southwest",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.619(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "420151010W_Warning_10132015.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420151010W/420151010W_Warning_10132015.pdf",
      "bytes": 401588,
      "category": "agency_document"
    },
    {
      "name": "420151010W_Warning_10132015_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420151010W/420151010W_Warning_10132015_text.pdf",
      "bytes": 7817,
      "category": "agency_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"
}
```
