{"operation":"document","citation":"CPF 220161001W","title":"GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-03-02","effective_on":null,"summary":"CLOSED warning letter citing 192.706(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220161001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220161001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220161001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220161001W","body":"Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.706(a). The case was opened on 2016-03-02 and is reported as closed as of 2016-03-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220161001W_Warning Letter_03022016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220161001W/220161001W_Warning%20Letter_03022016.pdf\n\n220161001W_Warning Letter_03022016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220161001W/220161001W_Warning%20Letter_03022016_text.pdf\n\n220161001W_Warning Letter_03022016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 2, 2016\nMr. Richard Keyser\nGulf South Pipeline Company, LP\nSenior Vice President of Operations\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 2-2016-1001W\nDear Mr. Keyser:\nOn October 19-22, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nGulf South Pipeline Company’s (Gulf South) records in Petal, Mississippi.\nAs a result of the inspection, it appears that Gulf South has committed a probable violation of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violation is:\n1. §192.706 Transmission lines: Leakage surveys.\nLeakage surveys of a transmission line must be conducted at intervals not exceeding\n15 months, but at least once each calendar year. However, in the case of a\ntransmission line which transports gas in conformity with §192.625 without an odor\nor odorant, leakage surveys using leak detector equipment must be conducted–\n(a) In Class 3 locations, at intervals not exceeding 7½ months, but at least twice each\ncalendar year;\nGulf South did not provide evidence that it conducted leakage surveys using leak detector\nequipment on a transmission pipeline, which transports gas without an odor or odorant, in\nClass 3 locations at least twice each calendar year, at intervals not exceeding 7 ½ months.\nGulf South records did not indicate leakage surveys were conducted in 2014 and 2015 for\nall Class 3 locations on line MS100-001 where gas is transported without an odor or\nodorant, as required. On April 29, 2014, Gulf South determined sections of Line MS100-\n001 (which transports gas without an odor or odorant) were within Class 3 locations. Gulf\nSouth’s leak survey records for 2014 and 2015, reviewed in October 2015, did not\n\n\n\ndocument all Class 3 locations along Line MS100-001 were surveyed using leak detector\nequipment. Gulf South records documented the following:\n• On July 7, 2014, a leakage survey using gas detection equipment was conducted\non line MS100-001 from Mile Post 0.937 (Station 49+47) to Mile Post 2.207\n(Station 116+53). The records do not document instrumented leakage surveys\nwere conducted on line MS100-001 in the following Class 3 locations:\no Station 26+93 to station 32+69\no Station 47+71 to Station 49+47\no Station 116+53 to Station 152+85 (north of Forrest Compressor Station)\no Station 136+75 to Station 208+85 (west of Forrest Compressor Station)\n• On January 26 and February 26, 2015, leakage surveys using gas detection\nequipment were conducted on Line MS100-001 from Station 49+48 to Station\n116+57, Station 71+79 to Station 152+85, and Station 136+75 to Station 208+85.\nThe records do not document instrumented leakage surveys were conducted on\nline MS100-001 in the Class 3 location from Station 26+93 to Station 32+69.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Gulf South being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2016-1001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Taylor\nActing Director, Office of Pipeline Safety\nPHMSA Southern Region\n2","truncated":false,"body_characters":5067}