# GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.491(c), 192.605(a).
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- **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.

Official case documents:

220181006W_Warning Letter_11022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220181006W/220181006W_Warning%20Letter_11022018.pdf

220181006W_Warning Letter_11022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220181006W/220181006W_Warning%20Letter_11022018_text.pdf

220181006W_Warning Letter_11022018_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 2, 2018
Mr. Richard Keyser
Senior Vice President of Operations
Gulf South Pipeline Company, L.P.
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
CPF 2-2018-1006W
Dear Mr. Keyser:
From July 9 to July 12, 2018, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety, inspected Gulf South Pipeline Company
(Gulf South) facilities in Louisiana, Mississippi, and Alabama, pursuant to Chapter 601 of 49
United States Code (U.S.C.). Gulf South is a subsidiary of Boardwalk Pipeline Partners
(Boardwalk).
As a result of the inspection, it is alleged that Gulf South has committed probable violations
of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:
1. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include procedures
for handling abnormal operations. This manual must be reviewed and updated by the
operator at intervals not exceeding 15 months, but at least once each calendar year.
This manual must be prepared before operations of a pipeline system commence.
Appropriate parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
Gulf South failed to comply with the regulation because it did not follow its manual of
written procedures for conducting operations and maintenance activities. As stated above,
Gulf South is a subsidiary of Boardwalk, and incorporates its operations and maintenance
program. Specific examples are below:



 Gulf South personnel did not follow Boardwalk’s procedures to document the
inspection of an internal pipe surface when a portion of the pipeline was exposed
during the removal of a 4-inch valve on Gulf South’s Index 300-35-2 on November
28, 2016.
Boardwalk procedure, titled “8030 – Internal Corrosion Control,” dated April 17,
2017, prescribes how to perform internal corrosion inspections, as required by
§192.475. The referenced procedure requires the following:
“Whenever any portion of any pipeline, vessel or meter tube is removed or opened
to where the internal surface can be inspected, the portion exposed is to be
examined by Operations Personnel for evidence of internal corrosion and a
documented visual corrosion inspection performed.”
Furthermore, the procedure requires the condition of the internal pipe surface for each
exposure to be documented on Boardwalk Form 8000-01, titled “Facility Inspection
and Repair Report.”
Section 7 of Boardwalk Form 8000-01, titled “Internal Corrosion Information”,
includes fields to document internal corrosion inspections. PHMSA’s review of
records documenting the above-referenced valve removal project revealed that “N/A”
was entered for the fields “Section Completed By,” “Company,” and “Date” included
in Section 7 of the completed Form 8000-01 associated with the project. No other
fields in this section were completed. The vacant fields would capture information
regarding the corrosion type, location, and depth, type of facility exposed, as well as
verify that the inside of the facility was exposed.
 Gulf South personnel did not follow Boardwalk’s procedures to document the
inspection of the external pipe surface and coating condition when a portion Gulf
South’s Index 300-35 was exposed on March 16, 2016.
Boardwalk procedure, titled “8020 – External Corrosion Control,” dated
August 1, 2015, prescribes how to perform an examination of a buried pipeline when
exposed, as required by §192.459. The referenced procedure requires the following:
“Whenever any portion of any buried pipeline has been exposed for any reason, the
portion exposed is to be examined for evidence of external corrosion and, if coated,
the condition of external coating. The condition of the external pipe surface and
coating for each exposure shall be documented on the Pipeline Inspection Report. –
Form 8000-01: Facility Inspection and Repair Report.”
Section 4, titled “Existing Coating Information,” and Section 6, titled “External
Corrosion,” of Boardwalk Form 8000-01 each include fields to document external
coating condition and external corrosion information, respectively. PHMSA’s review
of records documenting the above-referenced project revealed that Sections 4 and 6 of
the accompanying Form 8000-01 were not completed.
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2. §192.491 Corrosion Control Records.
(c) Each operator shall maintain a record of each test, survey, or inspection required
by this subpart in sufficient detail to demonstrate the adequacy of corrosion control
measures or that a corrosive condition does not exist. These records must be retained
for at least 5 years, except that records related to §§ 192.465 (a) and (e) and
192.475(b) must be retained for as long as the pipeline remains in service.
Gulf South failed to comply with the regulation because it did not maintain a record of
each test, survey, or inspection required by this subpart in sufficient detail to demonstrate
the adequacy of corrosion control measures. Specifically, Gulf South did not maintain
documentation of internal corrosion inspections stemming from 3 separate projects detailed
below, as required by §192.475(b).
Boardwalk procedure, titled “8030 – Internal Corrosion Control,” dated April 17, 2017,
prescribes how to perform internal corrosion inspections, as required by §192.475. The
referenced procedure requires the following:
“The condition of the internal pipe surface for each exposure will be documented on
Form 8000-01: Facility Inspection and Repair Report.”
Section 7 of Boardwalk Form 8000-01, titled “Internal Corrosion Information,” includes
fields to document the condition of the internal pipe surface. PHMSA’s review of records
documenting the projects below revealed that “N/A” was entered for the fields “Section
Completed By,” “Company,” and “Date” included in Section 7 of the completed Form
8000-01 associated with each project. No other fields in Section 7 were completed for any
of the projects. The vacant fields would capture information regarding the corrosion type,
location, and depth, type of facility exposed, as well as verify that the inside of the facility
was exposed.
 March 16, 2016 – Removal of 1” Riser on Gulf South Index 300-35 at Station 248+05
 March 30, 2016 – Removal of 2” Riser on Gulf South Index 300 at Station 4924+28
 October 12, 2016 – Removed valves and pipe on Gulf South Index 300-35-2 at
Station 20+82
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022
for a related series of violations. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to correct the items
identified in this letter. Failure to do so will result in Gulf South being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 2-2018-1006W. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any
portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),
along with the complete original document you must provide a second copy of the document
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with the portions you believe qualify for confidential treatment redacted and an explanation of
why you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
552(b).
Sincerely,
James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region
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