{"operation":"document","citation":"CPF 320175002W","title":"MAGELLAN PIPELINE COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-03-30","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320175002W","body":"Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2017-03-30 and is reported as closed as of 2017-03-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320175002W_Warning Letter_03302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175002W/320175002W_Warning%20Letter_03302017.pdf\n\n320175002W_Warning Letter_03302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175002W/320175002W_Warning%20Letter_03302017_text.pdf\n\n320175002W_Warning Letter_03302017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 30, 2017\nMr. Michael Pearson\nSr. Vice President, Technical Services\nMagellan Pipeline Company, LP\nOne Williams Center\nPO Box 22186\nMD 27\nTulsa, OK 74172\nCPF 3-2017-5002W\nDear Mr. Pearson:\nOn August 30, 2016, a representative of the Minnesota Office of Pipeline Safety (MNOPS),\nacting as an interstate agent for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code investigated a spill at a trap at the\nMankato Terminal in Mankato, Minnesota.\nAs a result of the investigation, it is alleged that you have committed a probable violation of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected\nand the probable violation is:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\nsystem commence, and appropriate parts shall be kept at locations where\noperations and maintenance activities are conducted.\n\n\n\nMagellan Pipeline Company, LP personnel (Magellan) did not follow their procedure\n9.01-ADM-110 Performing Pigging Operations – Receiving Pigs when they completed\ntheir maintenance work on a scraper trap and put it back in service.\nMagellan was changing a corrosion coupon in a scraper trap and utilized procedure 9.01-\nADM-110 to ensure that the trap was depressurized before changing out the coupon.\nUpon completion of any work to a trap, the procedure contains clear steps to be followed\nbefore placing the trap back into service. Step 11 of procedure 9.01-ADM-110 required\nthe pressure warning device be secure and that the lock out/tag out be removed.\nAfter Magellan completed changing out the coupon, the pressure warning device was not\nsecured when they put the trap back into operation. A leak occurred at the pressure\nwarning device resulting in a spill of approximately 0.2 barrels.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the item(s) identified in this letter. Failure to do so will\nresult in Magellan Pipeline Company, LP being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2017-5002W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4774}