{"operation":"document","citation":"CPF 120201008W","title":"GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-03-27","effective_on":null,"summary":"CLOSED warning letter citing 192.12(d), 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120201008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120201008W","body":"Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.12(d),  192.12(e). The case was opened on 2020-03-27 and is reported as closed as of 2020-03-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120201008W_Warning Letter_03272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201008W/120201008W_Warning%20Letter_03272020.pdf\n\n120201008W_Warning Letter_03272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120201008W/120201008W_Warning%20Letter_03272020_text.pdf\n\n120201008W_Warning Letter_03272020_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 27, 2020\nMr. Richard Keyser\nSenior Vice President of Operations\nGulf South Pipeline Company, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF 1-2020-1008W\nDear Mr. Keyser:\nFrom August 13 – 15 and September 10 – 12, 2019, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Gulf South Pipeline Company, LLC's (GSP) Petal and Lake Bistineau underground natural gas\nstorage facilities in Forrest County, Mississippi and Bienville County, Louisiana.\nAs a result of the inspections, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable\nviolations are:\n1. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(d) Each underground natural gas storage facility that uses a depleted\nhydrocarbon reservoir or an aquifer reservoir for gas storage, including those\nconstructed not later than July 18, 2017 must meet the operations,\nmaintenance, integrity demonstration and verification, monitoring, threat\nand hazard identification, assessment, remediation, site security, emergency\nresponse and preparedness, and recordkeeping requirements and\nrecommendations of API RP 1171, sections 8, 9, 10, and 11 (incorporated by\nreference, see § 192.7) by January 18, 2018.1\n1 The final rule, Pipeline Safety: Safety of Underground Natural Gas Storage Facilities, 85 FR 8104 (February 12,\n2020), revised § 192.12. This requirement is still present but is now contained in § 192.12(b)(2).\n\n\n\nCPF 1-2020-1008W\nGSP’s failed to meet the requirements of API RP 1171 Section 9. Specifically, GSP failed to request third-\nparty well integrity evaluation data, as required by API RP 1171, Section 9.3.1 Well Integrity Evaluation\n(Section 9.3.1).\nSection 9.3.1 states in part:\nThe operator shall evaluate the mechanical integrity of each active well, including each third-\nparty well, that penetrates the storage reservoir and buffer zone or areas influenced by storage\noperations.\nWell integrity evaluation methods typically used by operators include but are not limited to\nreview of design, completion, and well work records, wellhead and downhole inspection, well\npressure monitoring and testing, and gas sampling.\nThe operator shall request well integrity evaluation data from third-party well owner/operators\nfollowing the frequency established using conclusions from the risk assessment.\nActive well mechanical integrity evaluations shall include initial and subsequent evaluations\nas determined using the risk assessment and the information derived from the initial evaluation:\nDuring the inspection of the Lake Bistineau storage facility, GSP was asked to provide records showing\nthat they had requested third-party well integrity information. GSP could not provide any records\ndocumenting that they requested this information. Therefore, GSP failed to meet the requirements of\nSection 9.3.1.\n2. § 192.12 Underground natural gas storage facilities.\n(a) ….\n(e) Operators of underground gas storage facilities must establish and\nfollow written procedures for operations, maintenance, and emergencies\nimplementing the requirements of API RP 1170 and API RP 1171, as required\nunder this section, including the effective dates as applicable, and incorporate\nsuch procedures into their written procedures for operations, maintenance,\nand emergencies established pursuant to § 192.605.2\nGSP failed to follow its written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1170. Specifically, GSP failed to follow its Storage Integrity Procedures\nrequirement that all emergency shutdown devices (ESD) be installed at or very near the manual valves, in\naccordance with API RP 1170, Section 9.2.2 ESD Equipment (Section 9.2.2).\nSection 9.2.2 states in part:\nEach outlet shall have an Emergency Shutdown (ESD) Valve installed at or very near the\nmanual valves (wing valves). These valves should be part of an ESD system that automatically\nshut in the cavern in the event of an emergency.\nAn instrument flange may be used between the wing valve and ESD valve to gather real-time\npressure data when the cavern is not in use. The flange shall be rated for the same pressure as\nthe valves (see 6.4.11 and 8.4.1).\n2 This requirement is still present but is now contained in § 192.12(c).\n120201008W_Warning Letter_03272020_text Page 2 of 3\n\n\n\nCPF 1-2020-1008W\nAt the time of the field inspection in GSP’s Petal Storage, it was observed that the ESD on Cavern 7 was\ninstalled approximately 20 feet from the manual valve. Therefore, GSP failed to follow its written\nprocedures for implementing the requirements of Section 9.2.2.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $213,268\nper violation per day the violation persists, up to a maximum of $2,132,679 for a related series of violations.\nFor violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty\nmay not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For\nviolations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per\nviolation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item(s) identified in this letter. Failure to do so will result in Gulf South Pipeline Company,\nLLC being subject to additional enforcement action.\nPlease be advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide\na second copy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this matter to\nRobert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. Please refer to CPF 1-2020-1008W on each document you submit, and whenever possible provide\na signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger\nfiles should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region\nOffice.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120201008W_Warning Letter_03272020_text Page 3 of 3","truncated":false,"body_characters":7701}