# MAGELLAN AMMONIA PIPELINE, L.P. — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 195.589(c).
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- **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.

Official case documents:

320135017W_Warning Letter_06202013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320135017W/320135017W_Warning%20Letter_06202013.pdf

320135017W_Warning Letter_06202013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320135017W/320135017W_Warning%20Letter_06202013_text.pdf

320135017W_Warning Letter_06202013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 20, 2013
Mr. Michael Pearson
Magellan Ammonia Pipeline, L.P.
Vice President – Technical Services
One Williams Center, MD27
Box 22186
Tulsa, OK 74172
CPF 3-2013-5017W
Dear Mr. Pearson:
On August 6-10, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your NH3
IMP records in Tulsa, OK.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. §195.589 What corrosion control information do I have to maintain?
(c) You must maintain a record of each analysis, check, demonstration, examination,
inspection, investigation, review, survey, and test required by this subpart in sufficient detail
to demonstrate the adequacy of corrosion control measures or that corrosion requiring control
measures does not exist. You must retain these records for at least 5 years, except that
records related to Secs. 195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be
retained for as long as the pipeline remains in service.



Magellan did not document the inspection of the inside of the pipe when they replaced pipe
as a result of their IMP assessments.
Review of the repair records from the hydrostatic test of the NH3 line found that Magellan’s
personnel either left the section documenting the internal condition of the pipe empty, or they
wrote N/A in the section. Each repair noted involved a cutout which would require the
internal inspection. The line section and the number of reports that were missing the
documentation are as follows:
Line section # of Reports
Linn to Beatrice 3
Beatrice to Greenwood 3
Greenwood to Valley 7
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 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 item(s) identified in this letter.
Failure to do so will result in Magellan Ammonia Pipeline, L.P. 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 3-2013-5017W. 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 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,
David Barrett
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
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