{"operation":"document","citation":"CPF 12024060NOA","title":"GULF SOUTH PIPELINE COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-12-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024060noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024060noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12024060noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12024060NOA","body":"Notice of Amendment involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2024-12-20 and is reported as closed as of 2025-05-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12024060NOA_Closure Letter_05132025_(24-296383).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024060NOA/12024060NOA_Closure%20Letter_05132025_(24-296383).pdf\n\n12024060NOA_Closure Letter_05132025_(24-296383)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024060NOA/12024060NOA_Closure%20Letter_05132025_(24-296383)_text.pdf\n\n12024060NOA_Notice of Amendment_12202024_(24-296383).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024060NOA/12024060NOA_Notice%20of%20Amendment_12202024_(24-296383).pdf\n\n12024060NOA_Notice of Amendment_12202024_(24-296383)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024060NOA/12024060NOA_Notice%20of%20Amendment_12202024_(24-296383)_text.pdf\n\n12024060NOA_Operator Response to Notice_01172025_(24-296383).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024060NOA/12024060NOA_Operator%20Response%20to%20Notice_01172025_(24-296383).pdf\n\n12024060NOA_Notice of Amendment_12202024_(24-296383)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nDecember 20, 2024\nMr. Scott Hallam\nPresident and Chief Executive Officer\nGulf South Pipeline Company, LLC\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 1-2024-060-NOA\nDear Mr. Hallam:\nFrom May 29th\n, 2024 to June 13th, 2024 of the inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected Gulf South Pipeline Company, LLC’s (Gulf South) procedures for\nunderground natural storage in Petal and Jackson, Mississippi.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within Gulf\nSouth’s plans or procedures. The item inspected and the inadequacy is described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare and\nfollow for each facility one or more manuals of written procedures for\nconducting operations, maintenance, and emergency preparedness and\nresponse activities under paragraphs (a) and (b) of this section. Each\noperator must keep records necessary to administer such procedures and\nreview and update these manuals at intervals not exceeding 15 months, but\nat least once each calendar year. Each operator must keep the appropriate\nparts of these manuals accessible at locations where UNGSF work is being\nperformed. Each operator must have written procedures in place before\ncommencing operations or beginning an activity not yet implemented.\nGulf South’s written procedures for conducting operations and maintenance activities were\ninadequate to ensure safe operation of a pipeline facility. Specifically, Gulf South failed to provide\n\n\n\nadequate procedures that describe the process for converting maximum and minimum pressure at\nthe casing seat to a maximum and minimum wellhead pressure pursuant to API RP 1170, Section\n9.1 (Section 9.1).\nSection 9.1 states in part that “[m]aximum storage operating pressures shall be established by the\noperator. The operator shall then convert the maximum and minimum pressure at the casing seat\nto a maximum and minimum wellhead pressure if the wellhead is the monitoring point of record.”\nDuring the inspection, PHMSA reviewed Gulf South’s procedure 1170-9-1 Operating Limits,\neffective 05/01/2024, which Gulf South uses for establishing the maximum storage operating\npressure and found that the procedures were inadequate. The provided procedures did not describe\nthe specific process used by Gulf South to determine the maximum pressure of the cavern.\nPHMSA also reviewed the procedures for converting the maximum and minimum pressure at the\ncasing seat to a maximum and minimum wellhead pressure. The procedures were inadequate and\ndid not describe the process used to convert these pressures.\nTherefore, Gulf South’s written procedures required by § 192.12(c) were inadequate. Gulf South\nmust revise its procedures to address the deficiency outlined above.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Gulf South Pipeline Company, LLC maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n\n\n\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2024-060-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n12024060NOA_Closure Letter_05132025_(24-296383)_text.pdf\n\nVIA ELECTRONIC MAIL TO: scott.hallam@bwpipelines.com\nMay 13, 2025\nMr. Scott Hallam\nPresident and Chief Executive Officer\nGulf South Pipeline Company, LLC\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 1-2024-060-NOA\nDear Mr. Hallam:\nFrom May 29th, 2024 to June 13th, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Gulf South Pipeline Company, LLC’s (Gulf South) procedures for underground natural\nstorage in Petal and Jackson, Mississippi. As a result of the inspection, Gulf South was issued a\nNotice of Amendment on December 20, 2024.\nGulf South Pipeline Company, LLC submitted its amended procedures on January 17, 2025. My\nstaff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice\nof Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7985}