{"operation":"document","citation":"CPF 220181006W","title":"GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-02","effective_on":null,"summary":"CLOSED warning letter citing 192.491(c), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220181006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220181006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220181006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220181006W","body":"Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.605(a). The case was opened on 2018-11-02 and is reported as closed as of 2018-11-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220181006W_Warning Letter_11022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220181006W/220181006W_Warning%20Letter_11022018.pdf\n\n220181006W_Warning Letter_11022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220181006W/220181006W_Warning%20Letter_11022018_text.pdf\n\n220181006W_Warning Letter_11022018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 2, 2018\nMr. Richard Keyser\nSenior Vice President of Operations\nGulf South Pipeline Company, L.P.\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 2-2018-1006W\nDear Mr. Keyser:\nFrom July 9 to July 12, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, inspected Gulf South Pipeline Company\n(Gulf South) facilities in Louisiana, Mississippi, and Alabama, pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.). Gulf South is a subsidiary of Boardwalk Pipeline Partners\n(Boardwalk).\nAs a result of the inspection, it is alleged that Gulf South has committed probable violations\nof the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violations are:\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nGulf South failed to comply with the regulation because it did not follow its manual of\nwritten procedures for conducting operations and maintenance activities. As stated above,\nGulf South is a subsidiary of Boardwalk, and incorporates its operations and maintenance\nprogram. Specific examples are below:\n\n\n\n Gulf South personnel did not follow Boardwalk’s procedures to document the\ninspection of an internal pipe surface when a portion of the pipeline was exposed\nduring the removal of a 4-inch valve on Gulf South’s Index 300-35-2 on November\n28, 2016.\nBoardwalk procedure, titled “8030 – Internal Corrosion Control,” dated April 17,\n2017, prescribes how to perform internal corrosion inspections, as required by\n§192.475. The referenced procedure requires the following:\n“Whenever any portion of any pipeline, vessel or meter tube is removed or opened\nto where the internal surface can be inspected, the portion exposed is to be\nexamined by Operations Personnel for evidence of internal corrosion and a\ndocumented visual corrosion inspection performed.”\nFurthermore, the procedure requires the condition of the internal pipe surface for each\nexposure to be documented on Boardwalk Form 8000-01, titled “Facility Inspection\nand Repair Report.”\nSection 7 of Boardwalk Form 8000-01, titled “Internal Corrosion Information”,\nincludes fields to document internal corrosion inspections. PHMSA’s review of\nrecords documenting the above-referenced valve removal project revealed that “N/A”\nwas entered for the fields “Section Completed By,” “Company,” and “Date” included\nin Section 7 of the completed Form 8000-01 associated with the project. No other\nfields in this section were completed. The vacant fields would capture information\nregarding the corrosion type, location, and depth, type of facility exposed, as well as\nverify that the inside of the facility was exposed.\n Gulf South personnel did not follow Boardwalk’s procedures to document the\ninspection of the external pipe surface and coating condition when a portion Gulf\nSouth’s Index 300-35 was exposed on March 16, 2016.\nBoardwalk procedure, titled “8020 – External Corrosion Control,” dated\nAugust 1, 2015, prescribes how to perform an examination of a buried pipeline when\nexposed, as required by §192.459. The referenced procedure requires the following:\n“Whenever any portion of any buried pipeline has been exposed for any reason, the\nportion exposed is to be examined for evidence of external corrosion and, if coated,\nthe condition of external coating. The condition of the external pipe surface and\ncoating for each exposure shall be documented on the Pipeline Inspection Report. –\nForm 8000-01: Facility Inspection and Repair Report.”\nSection 4, titled “Existing Coating Information,” and Section 6, titled “External\nCorrosion,” of Boardwalk Form 8000-01 each include fields to document external\ncoating condition and external corrosion information, respectively. PHMSA’s review\nof records documenting the above-referenced project revealed that Sections 4 and 6 of\nthe accompanying Form 8000-01 were not completed.\n2\n\n\n\n2. §192.491 Corrosion Control Records.\n(c) Each operator shall maintain a record of each test, survey, or inspection required\nby this subpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that a corrosive condition does not exist. These records must be retained\nfor at least 5 years, except that records related to §§ 192.465 (a) and (e) and\n192.475(b) must be retained for as long as the pipeline remains in service.\nGulf South failed to comply with the regulation because it did not maintain a record of\neach test, survey, or inspection required by this subpart in sufficient detail to demonstrate\nthe adequacy of corrosion control measures. Specifically, Gulf South did not maintain\ndocumentation of internal corrosion inspections stemming from 3 separate projects detailed\nbelow, as required by §192.475(b).\nBoardwalk procedure, titled “8030 – Internal Corrosion Control,” dated April 17, 2017,\nprescribes how to perform internal corrosion inspections, as required by §192.475. The\nreferenced procedure requires the following:\n“The condition of the internal pipe surface for each exposure will be documented on\nForm 8000-01: Facility Inspection and Repair Report.”\nSection 7 of Boardwalk Form 8000-01, titled “Internal Corrosion Information,” includes\nfields to document the condition of the internal pipe surface. PHMSA’s review of records\ndocumenting the projects below revealed that “N/A” was entered for the fields “Section\nCompleted By,” “Company,” and “Date” included in Section 7 of the completed Form\n8000-01 associated with each project. No other fields in Section 7 were completed for any\nof the projects. The vacant fields would capture information regarding the corrosion type,\nlocation, and depth, type of facility exposed, as well as verify that the inside of the facility\nwas exposed.\n March 16, 2016 – Removal of 1” Riser on Gulf South Index 300-35 at Station 248+05\n March 30, 2016 – Removal of 2” Riser on Gulf South Index 300 at Station 4924+28\n October 12, 2016 – Removed valves and pipe on Gulf South Index 300-35-2 at\nStation 20+82\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in Gulf South being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2018-1006W. 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\n3\n\n\n\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\n4","truncated":false,"body_characters":8705}