{"operation":"document","citation":"CPF 220181001W","title":"GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-01-24","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220181001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220181001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220181001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220181001W","body":"Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2018-01-24 and is reported as closed as of 2018-01-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220181001W_Warning Letter_01242018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220181001W/220181001W_Warning%20Letter_01242018.pdf\n\n220181001W_Warning Letter_01242018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220181001W/220181001W_Warning%20Letter_01242018_text.pdf\n\n220181001W_Warning Letter_01242018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 24, 2018\nMr. Richard Keyser\nSenior Vice President of Operations\nGulf South Pipeline Company, L.P.\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 2-2018-1001W\nDear Mr. Keyser:\nFrom November 13 to November 17, 2017, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety, inspected Gulf South\nPipeline Company (Gulf South) facilities in Mississippi, pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.).\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item\ninspected and the probable violation is:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\n\n\n\nGulf South failed to meet the regulation because it did not follow its manual of written\nprocedures for conducting operations and maintenance activities for each pipeline.\nGulf South is a subsidiary of Boardwalk Pipeline Partners, LP. (Boardwalk), and\nincorporates Boardwalk’s Operations and Maintenance (O&M) manual.\nBoardwalk procedures, titled “Roads and Railroads Class 3 (Cased and Uncased) Task\nList” and “Roads and Railroads Class 1 & 2 Task List (Natural Gas),” both dated\nSeptember 1, 2017, prescribe actions required to demonstrate compliance with §192.705\n(Transmission Lines: Patrolling) and §192.706 (Transmission Lines: Leakage Surveys).\nBoth procedures require operator personnel to “Check condition of vent pipe…” and to\ncomplete the required documentation for the results of the patrols and surveys. The\ndocumentation is managed in Gulf South’s Operations Management System (OMS) as the\nreport titled “DOT Highway and Railroad Inspection Reports.” The referenced report\nincludes a data field for documenting the casing vent condition (“Casing Vents Good?\n(where applicable)”).\nPHMSA’s review of the above-referenced reports documenting the required transmission\nline patrolling and leakage surveys revealed that the casing vent status at 36 locations\nwere incorrectly documented for multiple patrols and leak surveys from January 1, 2015,\nthrough November 10, 2017, as follows:\n 34 locations reported “Casing Vents Good?\" as “Y” (yes) where no casing existed\n 2 locations reported “Casing Vents Good?\" as “NA” (not applicable) where\ncasings existed\n 31 of the 36 locations documented with inconsistent casing vent statuses in\nconsecutive inspections by the same inspector\nGulf South personnel provided detailed asset sheets for each of the 36 locations,\nconfirming the existence, or lack thereof, of a vented casing.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a\ncivil penalty not to exceed $209,002 per violation per day the violation persists up to a\nmaximum of $2,090,022 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in Gulf\nSouth being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2018-1001W. 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,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n3","truncated":false,"body_characters":5270}