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

- **operation:** document
- **citation:** CPF 220131001
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-02-05
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.465, 192.467(d).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220131001.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220131001.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220131001
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220131001
**body:**

Notice of Probable Violation involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.465,  192.467(d). The case was opened on 2013-02-05 and is reported as closed as of 2013-12-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220131001_Closure letter_12162013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_Closure%20letter_12162013.pdf

220131001_Closure letter_12162013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_Closure%20letter_12162013_text.pdf

220131001_Final Order_06102013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_Final%20Order_06102013.pdf

220131001_Final Order_06102013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_Final%20Order_06102013_text.pdf

220131001_nopv_pco_02052013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_nopv_pco_02052013.pdf

220131001_nopv_pco_02052013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_nopv_pco_02052013_text.pdf

220131001_Operator_Response_to_Notice_03272013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220131001/220131001_Operator_Response_to_Notice_03272013.pdf

220131001_Final Order_06102013_text.pdf

JUNE 10, 2013
Mr. David Goodwin
Vice President
Compliance and Operation Services
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
Re: CPF No. 2-2013-1001
Dear Mr. Goodwin:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and specifies actions that need to be taken by Gulf South Pipeline Company, LP to
comply with the pipeline safety regulations. When the terms of the compliance order have been
completed, as determined by the Director, Southern Region, this enforcement action will be
closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing,
or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Wayne T. Lemoi, Director, Southern Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
CERTIFIED MAIL - RETURN RECEIPT REQUESTED [INSERT RECEIPT NO.]



U.S. 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, LP, ) CPF No. 2-2013-1001
)
Respondent. )
____________________________________)
FINAL ORDER
From February 27, 2012 to November 28, 2012, pursuant to 49 U.S.C. § 60117, a representative
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline
Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Gulf
South Pipeline Company, LP (Gulf South or Respondent) in Alabama, Florida, and Mississippi.
Gulf South is a subsidiary of Boardwalk Pipeline Partners, LP and operates approximately
7,240 miles of interstate natural gas pipelines across Texas, Louisiana, Mississippi, Alabama,
and Florida.1
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to
Respondent, by letter dated February 5, 2013, a Notice of Probable Violation and Proposed
Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R. § 190.205. In
accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Gulf South had violated
49 C.F.R. § 192.467(d) and proposed ordering Respondent to take certain measures to correct the
alleged violation. The warning item required no further action, but warned the operator to
correct the probable violation or face possible enforcement action.
Respondent failed to respond within 30 days of receipt of the Notice. Under
49 C.F.R. § 190.209(c), such failure to respond constitutes a waiver of Gulf South’s right to
contest the allegations in the Notice and authorizes the Associate Administrator, without further
notice, to find facts as alleged in the Notice and to issue this Final Order under § 190.213. In this
case, the Notice was received by Respondent on February 8, 2013, as shown by the certified
mailing receipt on file with PHMSA. Gulf South responded to the Notice by letter dated March
27, 2013 (Response), forty-seven days later. In its Response, the company did not contest the
allegations of violation. Respondent did not request a hearing and therefore has waived its right
to one. Under such circumstances, I find it reasonable and appropriate to enter this Final Order
without further proceedings.
1 http://www.gulfsouthpl.com/AboutUsGS.aspx (last accessed on May 17, 2013).



2
FINDING OF VIOLATION
In its Response, Gulf South did not contest the allegation in the Notice that it violated
49 C.F.R. Part 192.467(d), as follows:
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.467(d), which states in
relevant part:
§ 192.467 External corrosion control: Electrical isolation.
(a) Each buried or submerged pipeline must be electrically isolated
from other underground metallic structures, unless the pipeline and the
other structures are electrically interconnected and cathodically protected
as a single unit…
(d) Inspection and electrical tests must be made to assure that
electrical isolation is adequate.
The Notice alleged that Respondent violated 49 C.F.R. § 192.467(d) by failing to test and inspect
its facilities to assure that electrical isolation and cathodic protection were adequate. Gulf South
did not have records to demonstrate that its pipeline had been electrically inspected and tested at
the Hattiesburg Delivery Station No. 1, the Petal Compressor Station, and the metering station,
which provides lift gas to Triad Blackburn. During the OPS inspection, pipe-to-soil readings of
-530mV were noted for the Hattiesburg Delivery Station, -630 mV for the Petal Compressor
station, and -270 mV for the metering station. Respondent did not contest this allegation of
violation. Accordingly, based upon a review of all of the evidence, I find that Respondent
violated 49 C.F.R. § 192.467(d) by failing to ensure that electrical isolation and cathodic
protection levels were adequate.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
WARNING ITEM
With respect to Item 1, the Notice alleged a probable violation of Part 192 but did not propose a
civil penalty or compliance order for this item. Therefore, this is considered to be a warning
item. The warning was for:
49 C.F.R. § 192.465 (Item 1) ─ Respondent’s alleged failure to monitor its
cathodic protection test stations, rectifiers, and interference bonds within the
required intervals. Specifically, Gulf South performed the required inspections on
the Hattiesburg-Petal Storage System one month late.
If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject
to future enforcement action.



3
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 2 in the Notice for a violation of
49 C.F.R. § 192.467(d). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of
49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following
actions to ensure compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 192.467(d) (Item 2), Respondent must:
A. Conduct an inventory of all above-ground facilities with buried change
of custody locations;
B. Inspect and test Gulf South’s pipeline at the Hattiesburg Delivery Station
No. 1, the Petal Compressor station, and the metering station, which provides
lift gas to Triad Blackburn;
C. Include these three locations in Gulf South’s external corrosion control
monitoring program; and
D. Correct any deficiencies noted per Section 192.463(d).
2. Gulf South must notify the Director, Southern Region, OPS within 150 days
following the date of issuance of this Final Order that Compliance Order Items
1(A) and 1(B) have been completed. Gulf South must maintain records associated
with Item 1 above for future review by PHMSA Southern Region.
3. It is requested (not mandated) that Gulf South maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total
to Wayne Lemoi, Director, Southern Region, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses, and 2)
total cost associated with replacements, additions and other changes to pipeline
infrastructure.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

220131001_Closure letter_12162013_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 16, 2013
Mr. David Goodwin
Vice President
Compliance and Operation Services
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
CPF 2-2013-1001
Dear Mr. Goodwin:
On June 10, 2013, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS) issued to Gulf South Pipeline Company, LP (GSPL) a Final
Order in the above-referenced case. The Final Order included an attached Compliance Order
(CO) requiring GSPL to undertake certain actions to ensure compliance with the federal
pipeline safety regulations.
The OPS Southern Region has received and reviewed several written responses to the CO
from GSPL, including GSPL’s final response dated December 12, 2013. Based on our review
of these responses we have determined that GSPL has complied with the terms of the Final
Order and CO. This case is now closed and no further action is necessary with respect to the
matters involved in this case.
Notwithstanding the closure of this Final Order, it is must be noted that actions related to
CO Items 1C and 1D are ongoing maintenance activities. PHMSA inspectors will confirm
compliance with these items during future on-site pipeline safety inspections.
Please be advised that this letter refers only to the above referenced order (CPF 2-2013-1001)
and not to any other PHMSA cases, if any.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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