# MAGELLAN TERMINALS HOLDINGS, LP — Warning Letter

- **operation:** document
- **citation:** CPF 120076003W
- **title:** MAGELLAN TERMINALS HOLDINGS, LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-09-07
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.567(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120076003w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120076003w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120076003w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120076003W
**body:**

Warning Letter involving MAGELLAN TERMINALS HOLDINGS, LP. PHMSA's enforcement data identifies the cited regulation as 195.567(a). The case was opened on 2007-09-07 and is reported as closed as of 2007-09-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120076003W_Warning Letter_09072007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120076003W/120076003W_Warning%20Letter_09072007.pdf

120076003w_warning letter_09072007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120076003W/120076003w_warning%20letter_09072007_text.pdf

120076003w_warning letter_09072007_text.pdf

u S Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
409 3rd Street, SW, Suite 300
Washington, DC 20024
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
September 7, 2007
Mr Rick A Olson
Vice President
Pipehne Operations and Technical Services
Magellan Terminals Holdings, LP
One Wtlhams Center
PO Box 22186 MD 28-6
Tulsa, OK 74121-2186
CPF I-2007-6003W
Dear Mr Olson
Dunng the week of June 11, 2007, a representative of the Pipehne and Hazardous Matenals
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
your hquid pipehne and associated breakout tanks in New Haven and Hamden, CT
As a result of the inspection, it appears that you have committed a probable violation of the
Pipehne Safety Regulations, Title 49, Code of Federal Regulanons The items inspected and the
probable violation is



1. (1195. 567 Which pipelines must have test leads and what must I do to install and
maintain the leads?
(a) General. Except for offshore pipelines, each buried or submerged pipeline or
segment of pipeline under cathodic protection required by this subpart must have
electrical test leads for external corrosion control. However, this requirement does
not apply until December 27, 2004 to pipelines or pipeline segments on which test
leads were not required by regulations in effect before January 28, 2002.
Magellan has 23 test stations to monitor external corrosion on the 2 67 iiule pipehne of which
one mile of the pipehne is belowground That one mde of belowground pipehne consists of
numerous segments that go below the ground and resurface Magellan monitors for external
corrosion at the points where the pipehne enters and leaves the ground The Magellan pipehne
was not required to have test leads pnor to January 28, 2002, but has been reqmred by
IJ 1 95 567(a) to have test leads by December 27, 2004
With the exception of two test points with leads, the inspector observed Magellan talang pipe to
soil readings with the test probe contacting the pipe at coating flaws identified as test stations
Repeatedly using the pipe as test points may create a location for the development of
atmospheric corrosion
Under 49 United States Code, f 60122, you are subiect to a civd penalty not to exceed $100, 000
for each violation for each day the violation persists up to a maximum of $1, 000, 000 for any
related series of violations We have reviewed the cucumstances and supporting documents
involved in tlus case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this tune We advise you to correct the item identified in this letter
Failure to do so will result in Magellan being subiect to additional enforcement action
No reply to this letter is required If you choose to reply, in your correspondence please refer to
CPF 1-2007-6003W. Be advised that all matenal you submit m response to this enforcement
action is subiect to being made pubhcly available If you beheve that any portion of your
responsive material quahfies for confidential treatment under 5 U S C 552(b), along with the
complete ongtnal 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 beheve
the redacted information quahfies for confidential treatment under 5 U S C 552(b)



Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipehne and Hazardous Materials Safety Adnurustratron
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