# GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420071003
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-03-27
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.605(b)(1), 192.909(a), 192.911(k), 192.911(l), 192.911(m), 192.915, 192.917(a), 192.917(b), 192.917(c), 192.917(e)(3), 192.919(b), 192.921, 192.921(a)(1), 192.933(c), 192.935(a), 192.935(c), 192.937(b).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420071003
**body:**

Notice of Probable Violation involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.909(a),  192.911(k),  192.911(l),  192.911(m),  192.915,  192.917(a),  192.917(b),  192.917(c),  192.917(e)(3),  192.919(b),  192.921,  192.921(a)(1),  192.933(c),  192.935(a),  192.935(c),  192.937(b). The case was opened on 2007-03-27 and is reported as closed as of 2012-05-30. Proposed civil penalty: $183,000. Assessed civil penalty: $85,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420071003_Closure_05302012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/420071003_Closure_05302012.pdf

420071003_Closure_05302012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/420071003_Closure_05302012_text.pdf

420071003_Final Order_11022011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/420071003_Final%20Order_11022011.pdf

420071003_Final Order_11022011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/420071003_Final%20Order_11022011_text.pdf

420071003_Notice Letter_03272007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/420071003_Notice%20Letter_03272007.pdf

420071003_Operator_Response_11082007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/420071003_Operator_Response_11082007.pdf

Gulf South Request for Hearing.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420071003/Gulf%20South%20Request%20for%20Hearing.pdf

420071003_Closure_05302012_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 30, 2012
Mr. David Goodwin
Vice President, Compliance and Operations Services
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
CPF 4-2007-1003
Dear Mr. Goodwin:
On November 2, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Gulf South Pipeline Company, LP a Final Order in the above-referenced case. This
Order included a Compliance Order and Civil Penalty assessment. Payment of the civil penalty
was received on November 17, 2011. Based on our review of the documentation you provided,
it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
R. M. Seeley
Director, Southwest region
Pipeline and Hazardous
Materials Safety Administration

420071003_Notice Letter_03272007.pdf

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U.S. Deporlment
of Tronsportqlion
Plpellne ond
Hozqrdous mqterlols Soteiy
Adminlslrqiion
8701 South Gessnsr, Suite 1110
Houston, TX 77074
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED GOMPLIANCE ORDER
GERTIFIED MAIL. RETURN RECEIPT REQUESTED
March 27.2007
Mr. John Earley
Senior Vice President
Gulf South Pipeline
20 E. Greenway Plaza
Suite 900
Houston, Texas 77046
cPF 4-2007-1003
Dear Mr. Earley:
During the weeks of January 23 - 27, and February 6 - 10, 2006, representatives of the
Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of
49 United States Code inspected your integrity management program in Houston, Texas.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the orobable violations are:
1. S 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 bythe 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.



(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with
each of the requirements of this subpart and subpart M of this part.
S 192.713 Transmission lines: Permanent field repair of imperfections and
damages.
(a) Each imperfection or damage that impairs the serviceability of pipe in a steel
transmission line operating at or above 40 percent of SMYS must be -
(1) Removed by cutting out and replacing a cylindrical piece of pipe; or
(2) Repaired by a method that reliable engineering tests and analyses show
can permanently restore the serviceability of the pipe.
(b) Operating pressure must be at a safe level during repair operations.
A. On September 24 - 25, 2003, Gulf South personnel recoated a section of pipe on
their Pipeline # l-129 Agua Dulce line ai SS 123+13 which exhibited localized
corrosion pitting in the seam and in the girth weld. Gulf South did not repair the
defects either in accordance with their own O&M procedures or in accordance with a
method that reliable engineering tests and analyses shows can permanently restore
the serviceability of the pipe. Gulf South's O&M procedure, 10.8 Repair of Leaks
and Defective Pipe, requires per Table 2 - Repair Methods for Environmentally
Caused Defects, that the corrosion be repaired with a Type B Sleeve. Similarly, the
current industry standard for reliable engineering tests is the 1994 "Pipeline Repair
Manual" developed for the American Gas Association, and Table 1, "Summary of
Repair Applications", from that manual indicates that a Type B Sleeve is the only
accepted method for Factor 20 (ERW Selective Corrosion). Similarly, for Factor 27
(Girth-Weld Defect), the accepted repair applications include Grinding, Deposited
Weld Metal and Type B Sleeve.
B. On October 2-3, 2003, Gulf South personnel repaired a section of pipe on their
Pipeline # l-129 Agua Dulce line at SS 286+05 which exhibited localized and general
corrosion pitting in the seam by using a composite repair method. Gulf South did not
repair the defects in accordance with their own O&M orocedures or in accordance
with a method that reliable engineering tests and analyses shows can permanently
restore the serviceability of the pipe. Gulf South personnel repaired a section of pipe
exhibiting localized and general corrosion pitting in a longitudinal weld using a
composite sleeve by the name of PermaWrap. The current standard for reliable
engineering tests is the 1994 "Pipeline Repair Manual" developed for the American
Gas Association (A newer version has not been published to date). Table 1.
Summary of Repair Applications, from that manual indicates that a Type B Sleeve is
the only accepted method for Factor 20. ERW Selective Corrosion.



2. 5192.909 How can an operator change its integrity management program?
3.
(a) General. An operator must document any change to its program and the
reasons for the change before implementing the change.
Gulf South IMP did not have procedures and documentation requirements for
addressing changes to the lMP. Gulf South has described its overall process for
Management of Change in Section 14 of the lMP, with the process flow identified in
Figure 14.1-1. Section 14.7 indicates that modifications to the IMP follow the process in
Figure '14.1-1
. Further, changes have been made to the IMP to date, but these changes
have not been performed and documented in accordance with Gulf South's program
statements made in Figure 14.1-1 of the lMP. Gulf South did not have proper
procedures and it did not execute rule required actions even against their own process
flow descriotion.
With regard to other changes, the Gulf South IMP did not include procedures and
documentation requirements for the management of change process to address
technical, physical, procedural, and organizational changes as stated in the lMP. Gulf
South did not have any verification that they executed any management of change
activities against any elements of their program according to rule requirements.
5192.911 What are the elements of an integrity management program? An
operator's initial integrity management program begins with a framework (see
5192.907) and evolves into a more detailed and comprehensive integrity
management program, as information is gained and incorporated into the
program. An operator must make continual improvements to its program. The
initial program framework and subsequent program must, at minimum, contain
the following elements. (When indicated, refer to ASME/ANSI 831 .8S (incorporated
by reference, see $192.7) for more detailed information on the listed element.)
(k) A management of change process as outlined in ASME/ANSI 831.8S, section
11.
The Gulf South IMP did not include a procedure to keep the BAP up-to-date with respect
to newly arising information that may require changes to the segment prioritization or
assessment method. CE's IMP Section 4.7 requires that risk assessment be updated
when new information is obtained and that the changes be evaluated to determine if
changes to the BAP are warranted but there is no procedure to ensure the process is
implemented.
IMP Section 5.'1 requires that all changes to the Baseline Assessment Plan have a
reason, be approved by the proper authority, be analyzed for implications of the changes
and be properly communicated to involved individuals but there are no detailed
procedures describing how these requirements are to be implemented, Documentation
of changes implemented since the initial baseline assessment plan developed
1211712004 has not been prepared that reflect the reason for the change, approval of the
change, analysis of the implications of the change, or the communication of the change
to stakeholders.



4. 5192.911 (see above)
(l) A quality assurance process as outlined in ASME/ANSI B31 .8S, section 12.
Gulf South did not have sufficiently comprehensive QfuQC procedures and is evidenced
by their failed QA/QC procedures for threat management as described for Index 130
below. The IMP has inadequate specification for the performance and documentation of
program reviews, both internal and external reviews, in that no definition is provided for
the scope of the proposed reviews and the periodicity expected for these reviews. The
Quality Assurance Plan for the IMP (found in Section 12.6 of the Plan) did not
adequately address the requirements of ASME 831 .8S, Chapter 12 for each element of
the lMP. There is no specification of what constitutes the set of QA/QC activities
associated with conduct of the IMP and no identification of responsibilities for those
activities. An example of inadequate QA process controls is noted in the fact that
applicable threats have not been assessed for Index 130 piping for which an lll has
been performed and credited, but no assessment has been performed to assess the
primary threat of third party damage. This threat is normally assessed by the use of
caliper pigs. This line was credited in the BAP as having been assessed, but this cannot
be complete until a caliper pig has been run. lt would be expected that the quality
assurance process would identify this discrepancy.
5.
6.
5192.911 (see above)
(l) A quality assurance process as outlined in ASME/ANSI 831 .8S, section 12,
Gulf South hired a consultant to conduct an external/independent review of the Gulf
South IMP (Review of Integrity Management Program, August 15,2005, Process
Performance lmprovement Consultants, LLC), but there is no evidence that corrective
measures recommended by this review were performed and completed and no process
exists by which to track these corrective measures to completion (e.9., as may be
evidenced by the proper use of an IMP change log). Gulf South did not have procedures
which ensure that contractors are required to have appropriate OA/AC controls. The
Tuboscope ISA did not have QA/QC specifications.
S192.911 (see above)
(m) A communication plan that includes the elements of ASME/ANSI B31 .8S,
section 10, and that includes procedures for addressing safety concerns raised
by--
(1) OPS;and
(2) A State or local pipeline safety authority when a covered segment is
located in a State where OPS has an interstate agent agreement.
Gulf South did not have procedures to address how it will regularly and routinely
communicate and document IMP issues internally and how it will execute against
requests made by PHMSA and State/Local officials.
Gulf South has no formal procedures or requirements to adequately provide for regular
internal communications on a specified interval nor is an ongoing effort prescribed which



7. 8.
enables a broad internal understanding and buy-in to the lMP. The Gulf South Internal
Communications Plan simply consists of an information session provided to Field VPs,
Area Business Leaders, and the Operations group personnel during various regular staff
meetings.
Subsection 11.2.2 of the Gulf South IMP states that safety concerns raised by PHMSA
or State/local officials are to be addressed, but there are no programmatic procedures or
requirements for how this process is to be carried out and documented. IMP Section
1 1.1 references the company's Integrity Management Awareness Program. However,
this program was not made available during the inspection.
5192.915 What knowledge and training must personnel have to carry out an
integrity management program?
(b) Persons who carry out assessments and evaluate assessment results. The
integrity management program must provide criteria for the qualification of any
person--
(1) Who conducts an integrity assessment allowed under this subpart; or
(2) Who reviews and analyzes the results from an integrity assessment and
evaluation; or
(3) Who makes decisions on actions to be taken based on these
assessments.
(c) Persons responsible for preventive and mitigative measures. The integrity
management program must provide criteria for the qualification of any person--
(1) Who implements preventive and mitigative measures to carry out this
subpart, including the marking and locating of buried structures; or
(2) Who directly supervises excavation work carried out in conjunction with
an integrity assessment?
Gulf South did not have procedures or program qualification requirements documented
in the IMP for personnel that carry out assessments and review assessment results or
for other personnel who carry out IMP activities. Qualification requirements must be
defined for necessary lM functions - resumes or training records may then demonstrate
that qualification requirements have been met.
5192.917 How does an operator identify potential threats to pipeline integrity and
use the threat identification in its integrity program?
(a) Threat identification. An operator must identify and evaluate all potential
threats to each covered pipeline segment. Potential threats that an operator must
consider include, but are not limited to, the threats listed in ASME/ANSI 831.8S
(incorporated by referencet see S 192.7), section 2, which are grouped under the
following four categories:
(1) Time dependent threats such as internal corrosion, external corrosion,
and stress corrosion cracking;



9.
(2) Static or resident threats, such as fabrication or construction defects;
(3) Time independent threats such as third party damage and outside force
damage; and
(4) Human error.
Gulf South did not have procedures to properly evaluate and/or eliminate threats, and
Gulf South eliminated threats improperly. The basis for elimination of cyclic fatigue or
other loading conditions as a threat for all pipeline segments has not been adequately
justified in program documentation. No systematic process is described or implemented
that demonstrates how threats are evaluated for specific segments and their applicability
or non-applicability documented for use in other elements of the program.
Gulf South did not have a procedure not analyze interacting threats as required by the
regulations such as corrosion related to LF-ERW pipe or accelerated by third party or
outside force damage. Each threat has been analyzed separately, but the potential
worsening of the impact of the threats due to interaction has not been analyzed or
considered in the risk model or program documentation.
5192.917 (see above)
(b) Data gathering and integration. To identify and evaluate the potential threats to
a covered pipeline segment, an operator must gather and integrate existing data
and information on the entire pipeline that could be relevant to the covered
segment, In performing this data gathering and integration, an operator must
follow the requirements in ASME/ANSI 831 .8S, section 4. At a minimum, an
operator must gather and evaluate the set of data specified in Appendix A to
ASME/ANSI 831 .8S, and consider both on the covered segment and similar non-
covered segments, past incident history, corrosion control records, continuing
surveillance records, patrolling records, maintenance history, internal inspection
records and all other conditions specific to each pipeline.
Gulf South did not have procedures to gather and integrate data. No
process/procedures exist to describe the requirements to gather and/ or integrate data or
QA/QC procedures to ensure data quality.
Gulf South has not developed procedures or program controls to ensure that the data
sources listed in ASME B3'l .8S, Table 2 have been utilized forthe lMP. lf data sources
are ruled out. the basis for their exclusion must be documented. Gulf South has no
record of assumptions that have been made when missing or inadequate data has been
identified.
Gulf South has not developed procedures or program requirements to address the basis
for assumptions made when data is missing or suspect. Specifically, the following four
elements are not addressed:
r Each threat covered by the missing or suspect data is assumed to apply to the
segment being evaluated. The unavailability of identified data elements is not a
justification for exclusion of a threat.
. Conservative assumptions are used in the risk assessment for that threat and
segment or the segment is given higher priority.



10.
11.
12.
r Records are maintained that identify how unsubstantiated data are used, so that
the impact on the variability and accuracy of assessment results can be
considered.
. Depending on the importance of the data, additional inspection actions or field
data collection efforts may be required.
5192.917 (see above)
(b) Data gathering and integration. (see above)
Gulf South has not explicitly analyzed and reviewed for each covered segment the
complete data sets specified in ASME 831.8S Appendix A and summarized in Table 1
and the additional 7 data sets prescribed by the lM Rule. Where data elements have
been ruled out, the basis for their exclusion must be documented
5192.917 (see above)
(c) Risk assessment. An operator must conduct a risk assessment that follows
ASME/ANSI 831 .8S, section 5, and considers the identified threats for each
covered segment. An operator must use the risk assessment to prioritize the
covered segments for the baseline and continual reassessments ($192.919,
192.921, 192.937), and to determine what additional preventive and mitigative
measures are needed (S192.935) for the covered segment.
Gulf South did not have orocedures to address how risk data is used to accomplish the
following objectives and it did not perform the following objectives according to rule
req uirements:
. assessing the benefits derived from mitigating action
r determining the most effective mitigation measures for the identified threats
. assessing of the integrity impact from modified inspection intervals
o assessing of the use of or need for alternative inspection methodologies
o effective resource allocation
. facilitating decisions to address risks along a pipeline or within a facility
Risk values generated by the risk model are exclusively being used to prioritize
assessments in the BAP. This adequately addresses the objective of prioritization of
segments for scheduling integrity assessments but not other requirements. IMP Section
4.1 states that the risk information is to be used to accomplish these objectives, but
there is no documentation describino how this is done.
5192.917 (see above)
(e) Actions to address particular threats. lf an operator identifies any of
the
following threats, the operator must take the following actions to address
thethreat.



13.
14.
(3) Manufacturing and construction defects. lf an operator identifies the
threat of manufacturing and construction defects (including seam defects)
in the covered segment, an operator must analyze the covered segment to
determine the risk of failure from these defects. The analysis must consider
the results of prior assessments on the covered segment. An operator may
consider manufacturing and construction related defects to be stable
defects if the operating pressure on the covered segment has not
increased over the maximum operating pressure experienced during the
five years preceding identification of the high consequence area, lf any of
the following changes occur in the covered segment, an operator must
prioritize the covered segment as a high risk segment for the baseline
assessment or a subsequent reassessment,
(i) Operating pressure increases above the maximum operating
pressure experienced during the preceding five years;
(ii) MAOP increases; or
(iii) The stresses leading to cyclic fatigue increase.
Gulf South did not have defined processes or procedures to address Manufacturing and
Construction defects. The IMP specifically did not include defined processes or
procedures describing how to monitor operating pressure increases that may occur
above the maximum operating pressure experienced during the preceding five years,
MAOP increases, or the stresses leading to cyclic fatigue increases that may have
occurred in covered segments.
5192.919 What must be in the baseline assessment plan?
An operator must include each of the following elements in its written baseline
assessment plan:
(b) The methods selected to assess the integrity of the line pipe, including an
explanation of why the assessment method was selected to address the identified
threats to each covered segment. The integrity assessment method an operator
uses must be based on the threats identified to the covered segment. (See
5192.917.) More than one method may be required to address all the threats to the
covered pipeline segment.
Gulf South did not properly assess for relevant threats or conduct the proper baseline
assessments. Gulf South pipeline Index 130 is credited with a prior lll assessment.
However, Gulf South did not have a documented process or analysis showing that all
applicable threats have been addressed by the prior assessment. The assessment did
not include a caliper run to address potential third party damage which the risk
assessment identified as a primary threat. As such, this assessment may not be credited
as a completed assessment.
5192.921 How is the baseline assessment to be conducted?
(a) Assessment methods. An operator must assess the integrity of the line pipe in
each covered segment by applying one or more of the following methods
8



15.
16,
depending on the threats to which the covered segment is susceptible. An
operator must select the method or methods best suited to address the threats
identified to the covered segment (See $192.917).
(1) Internal inspection tool or tools capable of detecting corrosion, and any
other threats to which the covered segment is susceptible. An operator
must follow ASME/ANSI 831 .8S (incorporated by reference, see 5192.7),
section 6.2 in selecting the appropriate internal inspection tools for the
covered segment.
Gulf South's IMP did not include procedures or programmatic requirements describing
the process for analysis and documentation of lLl tool selection nor did it perform the
associated rule required actions as is evidenced by lndex 130 and described in both
items 4. and 13. above. Gulf South's Evaluation and Remediation Practice #4, Inline
Inspection Practice, recognizes that lLl tools have an average of 80% accuracy
confidence, but processes do not specify the use of a tool tolerance to compensate for
potential tool and grading inaccuracies for lLl results. Gulf South did not have
procedures or programmatic requirements for quality assurance and vendor personnel
qualifications for evaluation of lLl results. There is no documented procedure or process
for recording decisional information regarding assessment methods to address identified
threats for each covered seoment.
5192.921 (see above)
(fl Newly identified areas. When an operator identifies a new high consequence
area (see 5192.905), an operator must complete the baseline assessment of the
line pipe in the newly identified high consequence area within ten (10) years from
the date the area is identified,
(g) Newly installed pipe. An operator must complete the baseline assessment of a
newly-installed segment of pipe covered by this subpart within ten (10) years from
the date the pipe is installed. An operator may conduct a pressure test in
accordance with paragraph (a)(2) of this section, to satisfy the requirement for a
baseline assessment.
Gulf South did not have procedures or programmatic requirements to complete a
baseline assessment for segment[s] having newly identified HCAs and newly installed
segments within ten [10] years from the date of identification. Procedures and process
descriptions must describe how the baseline assessment plan is updated to reflect the
reo uired assessment sched ule.
5192.933 What actions must be taken to address integrity issues?
(c) Schedule for evaluation and remediation. An operator must complete
remediation of a condition according to a schedule that prioritizes the conditions
for evaluation and remediation. Unless a special requirement for remediating
certain conditions applies, as provided in paragraph (d) of this section, an
operator must follow the schedule in ASME/ANSI 831 .8S (incorporated by
reference, see $ 192.7), section 7, Figure 4. lf an operator cannot meet the
schedule for any condition, the operator must justify the reasons why it cannot
9



17.
18.
meet the schedule and that the changed schedule will not jeopardize public
safety. An operator must notify OPS in accordance with $ 192.949 if it cannot meet
the schedule and cannot provide safety through a temporary reduction in
operating pressure or other action. An operator must also notify a State or local
pipeline safety authority when either a covered segment is located in a State
where OPS has an interstate agent agreement, or an intrastate covered segment is
regulated by that State.
Gulf South did not have procedures to implement their lM plan which does define the
process used when justifying why a remediation schedule cannot be met and why the
changed schedule will not jeopardize public safety. There is no identification of who is to
develop this justification, the contents of the justification, where the record is to be
maintained, etc. Gulf South stated that it is expected that these justifications will be
placed in dig packets, but it is also noted that there is no documented procedure or
process used for developing dig packets. Procedures for controlling both processes
need to be established to ensure repeatability.
5192.933 (see above)
(c) Schedule for evaluation and remediation. (see above)
Gulf South did not develop a prioritized schedule for remediation activities as required by
the regulations and as specified in the Gulf South IMP Section 7.5. There was no
schedule record.
5192.935 What additional preventive and mitigative measures must an operator
take to protect the high consequence area?
(a) General requirements. An operator must take additional measures beyond
those already required by Part 192 to prevent a pipeline failure and to mitigate the
consequences of a pipeline failure in a high consequence area. An operator must
base the additional measures on the threats the operator has identified to each
pipeline segment. (See $192.917) An operator must conduct, in accordance with
one of the risk assessment approaches in ASME/ANSI 831.8S (incorporated by
reference, see $192.7), section 5, a risk analysis of its pipeline to identify
additional measures to protect the high consequence area and enhance public
safety. Such additional measures include, but are not limited to, installing
Automatic Shut-off Valves or Remote Control Valves, installing computerized
monitoring and leak detection systems, replacing pipe segments with pipe of
heavier wall thickness, providing additional training to personnel on response
procedures, conducting drills with local emergency responders and implementing
additional inspection and maintenance programs.
Gulf South did not have formal procedures or documentation to identify the required
additional P&M measures will be selected or imolemented and which also considers
both the likelihood and conseouences of a failure.
10



19. 5192.935 (see above)
(a) General requirements. (see above)
Gulf South has completed baseline assessments for several HCA segments but the
threats to those segments have not been evaluated to identify appropriate and required
P&M Measures.
20.
5192.935 (see above)
(c) Automatic shut-off valves (ASV) or Remote control valves (RGV). lf an operator
determines, based on a risk analysis, that an ASV or RCV would be an efficient
means of adding protection to a high consequence area in the event of a gas
release, an operator must install the ASV or RGV. In making that determination, an
operator must, at least, consider the following factors-swiftness of leak detection
and pipe shutdown capabilities, the type of gas being transported, operating
pressure, the rate of potential release, pipeline profile, the potential for ignition,
and location of nearest response personnel.
Gulf South did not have a documented risk analysis-based procedure to determine if
automatic shut-off valves or remote control valves should be added to their system.
21.
5192.937 What is a continual process of evaluation and assessment to maintain a
pipeline's integrity?
(b) Evaluation. An operator must conduct a periodic evaluation as frequently as
needed to assure the integrity of each covered segment. The periodic evaluation
must be based on a data integration and risk assessment of the entire pipeline as
specified in $192.917. For plastic transmission pipelines, the periodic evaluation is
based on the threat analysis specified in 5192.917(d). For all other transmission
pipelines, the evaluation must consider the past and present integrity assessment
results, data integration and risk assessment information ($192.917), and
decisions about remediation ($192.933) and additional preventive and mitigative
actions (S192.935). An operator must use the results from this evaluation to
identify the threats specific to each covered segment and the risk represented by
these threats.
Gulf South did not have procedures and documentation requirements for performing
periodic evaluations based on a data integration and risk assessment of the entire
pipeline nor did it perform the required actions per the rule requirements. The
evaluations must consider past and present assessment results, data integration, risk
assessment information, decisions about remediation, and additional preventive and
mitigative actions.
Gulf South did not have procedures and documentation requirements for performing
oeriodic evaluations to establish reassessment methods and schedules nor had it
properly established reassessment methods and schedules per rule requirements.
l1



22.
§192.937 (b) (see above).
Gulf South has not conducted periodic evaluations for those baseline assessments that
have been reported as complete per the Gulf South IMP Section 6.5.2 which specifies
that the required periodic evaluations will be conducted annually.
23.
§192.937 (see above)
(b) Evaluation. (see above)
Gulf South did not have procedures and documentation requirements for the review of
completed periodic evaluation results to determine if new information warrants changes
to reassessment intervals and/or methods.
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any related series of violations. The Compliance Officer has reviewed the circumstances
and supporting documentation involved in the above probable violation(s) and ha
ecommended that you be preliminarily assessed a civil penalty of $183,000 as follows
Item number
PENALTY
1.A.
$30,000
1.B.
$30,000
4.
$16,000
10.
11.
$16,000
13.
$16,000
$16,000
14.
$16,000
17.
$16,000
22
19.
$11,000
$16,000
Proposed Compliance Order
With respect to items 1 - 23 pursuant to 49 United States Code § 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Gulf South
Pipeline. Please refer to the Proposed Compliance Order, which is enclosed and made a part
of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Compliance Proceedings. Please refer to this document and note the response options. 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
12



qualifies for confidential treatment under 5 U.S.C. 552(b). lf you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.
In your correspondence on this matter, please refer to CPF 4-2007-1003 and for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
q&,2,4,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
Enclosures: ProposedComplianceOrder
Response Options for Pipeline Operators in Compliance Proceedings
I J



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code S 601 18, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Gulf South a Compliance Order incorporating the
following remedial requirements to ensure the compliance of Gulf South with the pipeline safety
req ulations:
1.
2.
4.
5.
6.
7.
8.
9.
10.
In regard to ltem Number 1.A of the Notice pertaining to the actions on
September 24-25,2003, where Gulf South personnel recoated a section of pipe
on their Pipeline #l-129 Agua Dulce line at SS 123+13 which exhibited localized
corrosion pitting in the seam and in the girth weld, Gulf South did not repair the
defects by following their O&M procedures or by using a method that reliable
engineering tests and analyses show can permanently restore the serviceability
of the pipe. Gulf South must excavate and make proper repairs.
In regard to ltem Number 1.B of the Notice pertaining to the actions taken on
October 2-3, 2003, where Gulf South personnel repaired a section of pipe on
their Pipeline # l-129 Agua Dulce line at SS 286+05 which exhibited localized
and general corrosion pitting in the seam, Gulf South did not repair the defects by
following their O&M procedures or by using a method that reliable engineering
tests and analyses show can permanently restore the serviceability of the pipe.
Gulf South must excavate and make proper repairs.
In regard to ltem Number 2 of the Notice pertaining to Management of Change
procedures, Gulf South must develop and implement appropriate Management of
Change procedures to cover the issues addressed.
In regard to ltem Number 3 of the Notice pertaining to BAP procedures, Gulf
South must develop and implement appropriate BAP procedures to cover the
issues addressed.
In regard to ltem Number 4 of the Notice pertaining to QfuQC procedures, Gulf
South must develop and implement appropriate QfuOC procedures to cover the
issues addressed.
ln regard to ltem Number 5 of the Notice pertaining to findings from the
external/independent review, Gulf South must detail their plans with regard to
each of the findings in the review. ln regard to ltem Number 5 of the Notice
pertaining to QAI/QC procedures for contractors, Gulf South must develop and
implement appropriate QfuQC procedures to cover the issues addressed.
In regard to ltem Numbers 6 of the Notice pertaining to internal and external
communications, Gulf South must develop and implement appropriate
Communication procedures to cover the issues addressed.
In regard to ltem Number 7 of the Notice pertaining to expected Knowledge and
Training of company personnel, Gulf South must develop and implement
appropriate Training procedures to cover the issues addressed.
In regard to ltem Numbers 8 of the Notice pertaining to Threat ldentification, Gulf
South must develop and implement appropriate Threat Assessment procedures
to cover the issues addressed.
In regard to ltem Numbers 9 of the Notice pertaining to Data Gathering and
l +



11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
2 5 .
2 4 .
Integration, Gulf South must develop and implement appropriate procedures to
cover the issues addressed.
In regard to ltem Numbers 10 of the Notice pertaining to Data Gathering and
Integration, Gulf South must develop and implement appropriate procedures to
cover the issues addressed.
In regard to ltem Number 11 of the Notice pertaining to Risk Assessment, Gulf
South must develop and implement procedures to cover the issues addressed.
In regard to ltem Number 12 of the Notice pertaining to Manufacturing and
Construction Defects, Gulf South must develop and implement procedures to
cover the issues addressed.
In regard to ltem Number 13 of the Notice pertaining to proper assessments for
prior lll assessments, Gulf South must review the discussed BAP of Index 130
and all other prior assessments and determine and document their ability to be
included as prior assessments and where necessary Gulf South must address
any shortfalls discovered during the review.
In regard to ltem Number 14 of the Notice pertaining to Assessment Methods,
Gulf South must develop and implement procedures to cover the issues
addressed.
ln regard to ltem Number 15 of the Notice pertaining to Baseline Assessments
for Newly ldentified HCA Areas, Gulf South must develop and implement
appropriate procedures to cover the issues addressed.
In regard to ltem Number 16 of the Notice pertaining to Evaluaiion and
Remediation schedules, Gulf South must develop and implement appropriate
procedures to cover the issues addressed.
In regard to ltem Number 17 of the Notice pertaining to Evaluation and
Remediation schedules, Gulf South must develop and implement appropriate
schedules to cover the issues addressed.
In regard to ltem Number 18 of the Notice pertaining to preventive and mitigative
measures, Gulf South must develop and implement appropriate procedures to
cover the issues addressed.
In regard to ltem Number 19 of the Notice pertaining to preventive and mitigativ
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