{"operation":"document","citation":"CPF 320135017W","title":"MAGELLAN AMMONIA PIPELINE, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-06-20","effective_on":null,"summary":"CLOSED warning letter citing 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320135017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320135017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320135017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320135017W","body":"Warning Letter involving MAGELLAN AMMONIA PIPELINE, L.P.. PHMSA's enforcement data identifies the cited regulation as 195.589(c). The case was opened on 2013-06-20 and is reported as closed as of 2013-06-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320135017W_Warning Letter_06202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320135017W/320135017W_Warning%20Letter_06202013.pdf\n\n320135017W_Warning Letter_06202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320135017W/320135017W_Warning%20Letter_06202013_text.pdf\n\n320135017W_Warning Letter_06202013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 20, 2013\nMr. Michael Pearson\nMagellan Ammonia Pipeline, L.P.\nVice President – Technical Services\nOne Williams Center, MD27\nBox 22186\nTulsa, OK 74172\nCPF 3-2013-5017W\nDear Mr. Pearson:\nOn August 6-10, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your NH3\nIMP records in Tulsa, OK.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in sufficient detail\nto demonstrate the adequacy of corrosion control measures or that corrosion requiring control\nmeasures does not exist. You must retain these records for at least 5 years, except that\nrecords related to Secs. 195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be\nretained for as long as the pipeline remains in service.\n\n\n\nMagellan did not document the inspection of the inside of the pipe when they replaced pipe\nas a result of their IMP assessments.\nReview of the repair records from the hydrostatic test of the NH3 line found that Magellan’s\npersonnel either left the section documenting the internal condition of the pipe empty, or they\nwrote N/A in the section. Each repair noted involved a cutout which would require the\ninternal inspection. The line section and the number of reports that were missing the\ndocumentation are as follows:\nLine section # of Reports\nLinn to Beatrice 3\nBeatrice to Greenwood 3\nGreenwood to Valley 7\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Magellan Ammonia Pipeline, L.P. being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2013-5017W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4050}