# MAGELLAN PIPELINE COMPANY, LP — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420125010
- **title:** MAGELLAN PIPELINE COMPANY, LP — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-03-23
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(a), 195.406(a), 195.406(b), 195.410, 195.430, 195.432, 195.567(b), 195.571, 195.573(c), 195.573(d), 195.575(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420125010
**body:**

Notice of Probable Violation involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.406(a),  195.406(b),  195.410,  195.430,  195.432,  195.567(b),  195.571,  195.573(c),  195.573(d),  195.575(a). The case was opened on 2012-03-23 and is reported as closed as of 2016-03-04. Proposed civil penalty: $149,800. Assessed civil penalty: $149,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420125010_Closure Letter_03042016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_Closure%20Letter_03042016.pdf

420125010_Closure Letter_03042016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_Closure%20Letter_03042016_text.pdf

420125010_Final Order_09022014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_Final%20Order_09022014.pdf

420125010_Final Order_09022014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_Final%20Order_09022014_text.pdf

420125010_NOPV PCP PCO_03232012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_NOPV%20PCP%20PCO_03232012.pdf

420125010_NOPV PCP PCO_03232012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_NOPV%20PCP%20PCO_03232012_text.pdf

420125010_Operator_Response_and_Request_for_Hearing_04272012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125010/420125010_Operator_Response_and_Request_for_Hearing_04272012.pdf

420125010_NOPV PCP PCO_03232012_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 23, 2012
Mr. Larry Davied
Vice President, Technical Services
Magellan Pipeline Company
One Williams Center
Tulsa, OK 74172
CPF 4-2012-5010
Dear Mr. Davied:
Between March 22, 2010 and April 22, 2011, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
were on site and inspected your operations and maintenance procedures and ten pipeline
inspection units in Oklahoma and 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
probable violation(s) are:
1. 195.575 Which facilities must I electrically isolate and what inspections, tests, and
safeguards are required?
(a) You must electrically isolate each buried or submerged pipeline from other
metallic structures, unless you electrically interconnect and cathodically protect the
pipeline and the other structures as a single unit. (b) You must install one or more
insulating devices where electrical isolation of a portion of a pipeline is necessary to
facilitate the application of corrosion control. (c) You must inspect and electrically



test each electrical isolation to assure the isolation is adequate. (d) If you install an
insulating device in an area where a combustible atmosphere is reasonable to
foresee, you must take precautions to prevent arcing. (e) If a pipeline is in close
proximity to electrical transmission tower footings, ground cables, or counterpoise,
or in other areas where it is reasonable to foresee fault currents or an unusual risk
of lightning, you must protect the pipeline against damage from fault currents or
lightning and take protective measures at insulating devices.
Magellan (the Operator) failed to isolate each buried pipeline from other metallic structures as
required by §195.575 and confirmed in the written procedures required under §195.402. As
discussed below, the Operator has both metallically and electrolytically shorted casings in the
units inspected (including Longhorn, Duncan to Ft. Smith, Cimarron Pipeline, Orion West,
Oklahoma City, and Tulsa) and has not consistently taken measures to achieve electrical
isolation between the casings and carrier pipes.
Metallically shorted casings are addressed by Magellan Corrosion Control Program procedures,
7.04-ADM-001, Section 2.9.4, which states that metallically shorted casings require actions
when the casing potential is within 100 millivolts of the carrier pipe. Magellan’s annual surveys
of pipe-to-soil and casing-to-soil readings show some casing-to-soil readings taken at the same
test station or a nearby test station to be within 100 mV of the pipe-to-soil readings. According
to Magellan records, testing performed by the Operator has confirmed that some of these casings
are metallically shorted but actions have not been taken to achieve the electrical isolation
required to comply with the requirements of 195.575. In addition, the Operator has not followed
its procedures to clear the short or fill the casing annulus with dielectric material for each
metallically shorted casing.
A sample of the Magellan annual cathodic protection survey records, included as evidence, show
the inspection date, the name of the pipeline segment, the milepost, a description of the location,
the pipe-to-soil and casing-to-soil readings in volts and the casing status. Some examples in the
Magellan records with casing-to-soil reading within 100 mV of the pipe-to-soil reading,
indicating the potential for the casing to be metallically shorted, include the following:
Segment Name MP/Station Year(s) Comments
Ponca City to Barnsdall 22+24 2005, 2006, 2007, 2008, 2009 (2009) P/S -2.175V, C/S -2.181V
Enid to Oklahoma City 74+06 2005, 2006, 2007, 2008, 2009 (2009) P/S -1.612V, C/S -1.602V
Allen to Drumright 16+27 20072, 20082, 20091 (2009) P/S -0.926V, C/S -0.844V
Tulsa Jct. to Kansas St. Line 119.223 20053,20064,20074,20084,20094 (2009) P/S -1.620V, C/S -1.617V
Barnsdall to Kansas City #3-8 1+06 20052, 20072, 20084, 20092 (2008) P/S -1.205V, C/S -1.109V
West Tulsa to Glenpool 4.38 20054,20064,20074,20084,20091 (2009) P/S -0.901V, C/S -0.900V
West Tulsa to Glenpool 4.58 20054,20064,20074,20084,20091 (2009) P/S -0.943V, C/S -0.930V
Clyde to DeLeon 156.302 2010 P/S -1.127V, C/S -1.124V
1 Casing-to-soil within 100 mV of pipe-to-soil but shown in Magellan records to be clear.
2 >100 mV difference and shown in Magellan records as electrolytically shorted.
3 Casing-to-soil within 100 mV of pipe-to-soil and shown in Magellan records to be metallically shorted.
4 Casing-to-soil within 100 mV of pipe-to-soil and shown in Magellan records to be electrolytically shorted.
The Magellan records show casing status test designations using “C” for clear (not shorted), “E”
for electrolytically shorted, “S” for metallically shorted, and “I” for inhibited (the annulus of the
casing has been filled with a dielectric material). These designations have sometimes changed2



from year to year between metallically shorted, electrolytically shorted, and clear. For example,
the shorted casing at station 22+24 on the Ponca City to Barnsdall segment was designated to be
metallically shorted (S) as early as 2005, was changed to electrolytically shorted (E) in 2006,
then back to metallically shorted (S) in 2007, 2008, and 2009. The operator does not explain
these inconsistencies.
Research on corrosion of cased pipes supports the need to achieve electrical isolation between
the carrier pipe and casing and a discussion is provided in the associated Violation Report.
Magellan does not have a procedure specifically addressing the issue of electrolytically shorted
casings, but the records indicate that the Operator has recognized the issue given the many
casings in their records designated to be electrolytically shorted. The records, however, do not
indicate the operator has taken consistent actions to address these electrolytic shorts and achieve
electrical isolation as required by 195.575. Out of the many shorted casings (electrolytically) on
the Magellan system where the casing-to-soil readings are not within 100 mV of the pipe-to-soil
readings some specific examples are as follows:
Segment Name MP/Station Year(s) Comments
Ponca City to Barnsdall 0+04,44+22,52+08 20051,20061,2007,2008,2009 (00+04,2009) P/S -1.395V,C/S -1.102V
Enid to Oklahoma City 69+14,80+26 20062,20072,2008,2009 (69+14,2009) P/S -1.271V,C/S -1.062V
Allen to Drumright 68+25,69+16,75+15 2007,2008,2009 (68+25,2009) P/S-1.692V, C/S -1.466V
Tulsa Jct. to Kansas St. Line 110.878,151.557 20053,2006,2007,2008,20091 (110.87,2009) P/S-1.519V,C/S -0.992V
Barnsdall to Kansas City (#3-8) 29+44 2006,2007,2008,2009 (2009) P/S -1.791V, C/S -0.953V
Cushing to Drumright 8+15 2006,2007,2008,2009,2010 (2010) P/S -1.457V, C/S -1.177V
Drumright to Tulsa 0+24, 28+40, 32+29 20055,20061,20074,20084,2009 (2009,0+24) P/S -1.349V, C/S -0.896V
Concord to East Houston 170.6 2006,2007,2008,2009,2010 (2010) P/S -1.171V, C/S -1171V
Clyde to DeLeon 187.200 2010 P/S -1.201V, C/S -0.972V
1 Casing(s) designated as clear even though casing-to-soil reading is significantly more electronegative than native steel in soil.
2 Casing at 80+26 designated as clear.
3 Casing at 110.878 designated as metallically shorted.
4 Casing at 32+29 designated as clear.
5 Casings at 0+24 designated as clear even though casing-to-soil reading is significantly more electronegative than native steel in soil.
None of the casings were intentionally bonded to the carrier pipe or connected to the cathodic
protection system to cathodically protect the casings. Therefore, it was not the intent of the
Operator to protect the pipe and casing as a unit. In addition, no records were presented
documenting the installation of galvanic anodes to cathodically protect the casings which could
result in elevated casing-to-soil readings.
2. 195.410 Line Markers.
(1) Markers must be located at each public road crossing, at each railroad crossing,
and in sufficient number along the remainder of each buried line so that its location
is accurately known. (c) Each operator shall provide line marking at locations
where the line is above ground in areas that are accessible to the public.
The Operator did not meet the requirements of §195.410 by placing a sufficient number of
markers along the buried pipeline so that its location is accurately known. Magellan also did not
follow its “Pipeline Marking Procedure, 7.05-ADM-002, pages 1-5 of 5” dated January 1, 2010
3



regarding its criteria to “Effectively delineate the pipeline corridor.” This procedure also states
that “Markers must be placed and maintained over each buried pipeline at the following
locations: 3.3.4 in sufficient numbers along the remainder of each buried line so that its location
is accurately known.”
During the field inspection there were locations on the Magellan pipeline system where there
were an inadequate number of pipeline markers in order to accurately know the location of the
pipeline, even when turning 360 degrees. At each of the sites listed below and by walking in
various directions from each of the specific known pipeline locations identified by the operator,
it was impossible to ascertain with any certainty the ongoing pipeline path through the further
observation of pipeline markers that would accurately show the location of the pipeline.
Locations where there were inadequate pipeline markers include segments in the Barnsdall,
Tulsa, Oklahoma City, Odessa to El Paso, and Cimarron inspection units. Some examples are
included in the following table:
Date Unit Pipeline Segment Approximate Location Comments
08/10/2010 Tulsa Tulsa to State Line Oologah, OK near Road E0390 Pipeline near house, apt. bldg.
09/24/2010 Oklahoma City Allen to Drumright County Road 3261 near 81+05 Pipeline near corral, residence
09/28/2010 Oklahoma City Wynnewood to OKC County road crossing near MP 11 Pipeline near residence
09/21/2010 Oklahoma City Tulsa to Drumright 56th Street near 26+48
08/10/2010 Tulsa Tulsa to State Line ROW near MP 138 Near Oologah Lake block valve
08/10/2010 Tulsa Tulsa to State Line ROW near MP 148
08/10/2010 Tulsa Tulsa to State Line ROW near MP 144 Near old Alluwe Station site
05/11/2010 Duncan-Ft. Smith Duncan to Ft. Smith ROW near 94+07 Near east end of Sander Road
05/11/2010 Duncan-Ft. Smith Duncan to Ft. Smith ROW near 128+96 Near county road crossing
05/11/2010 Duncan-Ft. Smith Duncan to Ft. Smith ROW near 142+31 Near Massey Point gate valve
05/11/2010 Duncan-Ft. Smith Duncan to Ft. Smith ROW near 199+32 Near Havener gate valve
05/11/2010 Duncan-Ft. Smith Duncan to Ft. Smith ROW near MP 201 Near Spiro rectifier
05/14/2010 Duncan-Ft. Smith Duncan to Ft. Smith ROW near 213+21 Near RR x-ing
06/09/2010 Orion West Frost to Odessa ROW near MP 310 Near Frost Station
06/09/2010 Orion West Frost to Odessa ROW near MP 202 Near Highway 8 crossing
06/09/2010 Orion West Frost to Odessa ROW near MP 174
06/09/2010 Orion West Frost to Odessa ROW near MP 163 Near county road 483
06/09/2010 Orion West Frost to Odessa ROW near MP 162 Near state highway 283
06/09/2010 Orion West Frost to Odessa ROW near MP 73 Near Colorado River crossing
06/10/2010 Orion West Frost to Odessa ROW near MP 72 Near Colorado River crossing
07/27/2010 Odessa-El Paso Odessa to El Paso ROW near MP 44
07/27/2010 Odessa-El Paso Odessa to El Paso ROW near MP 46 Damaged marker
07/27/2010 Odessa-El Paso Odessa to El Paso ROW near MP 61 Damaged marker
07/27/2010 Odessa-El Paso Odessa to El Paso ROW near rectifier E-8 Near 355+00
07/29/2010 Odessa-El Paso Odessa to El Paso ROW near rectifier E-40 Near 11208+95
08/10/2010 Tulsa Tulsa to State Line ROW near MP 168 Near Highway 10 crossing
08/10/2010 Tulsa Tulsa to State Line ROW near MP 158 Near county road crossing
08/10/2010 Tulsa Tulsa to State Line ROW near MP 147
08/10/2010 Tulsa Tulsa to State Line ROW near MP 139
08/10/2010 Tulsa Tulsa to State Line ROW near MP 130
08/10/2010 Tulsa Tulsa to State Line ROW near MP 118 Pipeline near residence
08/10/2010 Tulsa Tulsa to State Line ROW near 49th Street North
08/10/2010 Tulsa Tulsa to State Line ROW near MP 105 Near Million Dollar Casino
08/10/2010 Tulsa Glenpool to W. Tulsa ROW near MP 10
08/11/2010 Tulsa Glenpool to W. Tulsa ROW near MP 2 Old Koch tie-in
09/21/2010 Tulsa Tulsa to Drumright 56th Street area
09/21/2010 Tulsa Tulsa to Drumright MP 19 area
09/23/2010 Oklahoma City OKC to Wynnewood MP 34 area
09/23/2010 Oklahoma City OKC to Wynnewood Wynnewood tank farm area
09/23/2010 Oklahoma City Allen to Drumright ROW near 1+42
09/24/2010 Oklahoma City Allen to Drumright MP 74 area
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09/24/2010 Oklahoma City Allen to Drumright MP 40 area County road 108
09/24/2010 Oklahoma City Allen to Drumright MP 29 area
10/05/2010 Cimarron Crude Glenpool to Tulsa MP 3 area
10/05/2010 Cimarron Crude Glenpool to Tulsa South I-44 and railroad tracks
3. 195.567 Which pipelines must have test leads and what must I do to install and
maintain the leads?
(b) Installation. You must install test leads as follows: (1) Locate the leads at
intervals frequent enough to obtain electrical measurements indicating the
adequacy of cathodic protection.
(c) Maintenance. You must maintain the test lead wires in a condition that enables
you to obtain electrical measurements to determine whether cathodic protection
complies with §195.571.
Magellan failed to maintain its test lead wires in a condition that enabled Magellan to obtain
electrical measurements to determine whether cathodic protection complies with §195.571.
During the field inspection, Magellan was observed to have cathodic protection test stations
listed in their records as annual test points that were damaged but had not yet been repaired so
that electrical measurements to determine the adequacy of cathodic protection could be made.
For example:
• The test station on the Wynnewood to Allen segment of the Duncan to Ft. Smith
12-inch and 10-inch pipeline located on Racetrack Road north of County Road
357 was destroyed and had not been repaired at the time of the inspection.
• The test station at 7705+00 on the Black river to Hueco segment of the Odessa to
El Paso pipeline had been destroyed and not repaired at the time of the inspection.
• The test station on the Cimarron pipeline near County Road 4804 read -707mV at
the time of the inspection and the analysis performed by the corrosion technician
indicated that the test leads may not have been solidly connected to the pipe.
These actions also show that the Operator failed to follow its procedure for installing and
maintaining test leads as required in their procedure titled “Corrosion Control Program, 7.04-
ADM-001, pages 1-21 of 21, dated January 1, 2010, section 2.10 Test Leads 195.567, 192.460,
and 192.471.”
4. 195.406 Maximum operating pressure.
(a) Except for surge pressures and other variations from normal operations, no
operator may operate a pipeline at a pressure that exceeds any of the following: (1)
The internal design pressure of the pipe determined in accordance with §195.106.
However, for steel pipe in pipelines being converted under §195.5, if one or more
factors of the design formula (§195.106) are unknown, one of the following pressures
5



is to be used as design pressure: (i) Eighty percent of the first test pressure that
produces yield under section N5.0 of Appendix N of ASME B31.8, reduced by the
appropriate factors in §§195.106(a) and (e); or (ii) If the pipe is 323.8 mm (12¾ in)
or less outside diameter and is not tested to yield under this paragraph, 1379 kPa
(200 psig). (2) The design pressure of any other component of the pipeline. (3)
Eighty percent of the test pressure for any part of the pipeline which has been
pressure tested under Subpart E of this part. (4) Eighty percent of the factory test
pressure or of the prototype test pressure for any individually installed component
which is excepted from testing under §195.305. (5) For pipelines under
§§195.302(b)(1) and (b)(2)(i), that have not been pressure tested under Subpart E of
this part, 80 percent of the test pressure or highest operating pressure to which the
pipeline was subjected for 4 or more continuous hours that can be demonstrated by
recording charts or logs made at the time the test or operations were conducted.
(b) No operator may permit the pressure in a pipeline during surges or other
variations from normal operations to exceed 110 percent of the operating pressure
limit established under paragraph (a) of this section. Each operator must provide
adequate controls and protective equipment to control the pressure within this limit.
Magellan has allowed pipeline pressures to exceed the maximum operating pressure in violation
of the requirements in §195.406. Specifically, according to records submitted by the Operator in
response to the PHMSA March 3, 2011, Request for Specific Information, Magellan has allowed
their pipeline system to exceed the Maximum Operating Pressure (MOP) for ten (10) minutes, or
longer, seventeen (17) times since 2007. Magellan states that it is standard practice per their
System Integrity Plan procedure 13.01-ADM-008, Abnormal Operating Conditions List, to alarm
as an abnormal operating condition when exceeding MOP on a ten minute basis. However,
allowing the pressure to remain over the MOP for ten minutes is not consistent with a reasonable
definition of surge pressure.
Another issue involving an overpressure situation occurred when the Magellan control center
received an alarm indicating that the MOP +110% had been exceeded at the Ponca City facility.
The Operator determined that a pressure relief valve had been incorrectly set at 1,440 psig for a
pipeline with a MOP of 480 psig. A Magellan technician also found during an inspection at the
Sooner Road facility that the numbered tags identifying the pressure relief devices did not match
the numbers on the Pipeline and Instrumentation Drawing (P&ID). In addition to showing the
configuration of the piping, valves, and relief devices, the P&ID ties the MOP of the pipeline
segment to the relief valve so that the correct settings can be established. Incorrect tagging may
result in incorrect setpoints for the pressure relief devices.
Magellan records also show that at the Drumright facility the overpressure devices were set to
activate at pressures higher than the designated pressure on the inspection form (07-FORM-
0741). For example, the inspection form indicates that device MLMF-0033 on the East Pig
Bypass should be set to activate at a pressure of 1,050 psig. However, on September 24, 2009,
the pressure was set at 1,448 psig. Another example is device UNT2-0012 was set to activate at
6



809 psig but the maximum pressure indicated on the form is 800 psig. The inspection form for
the Oklahoma City Reno facility shows that device PSV-1221 was found to be set to relieve at
500 psig but the maximum pressure is 305 psig. Improperly setting the relief device pressures
may allow an overpressure condition and could result in a failure of the pipeline facilities.
5. 195.402(a) Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline commence, and
appropriate parts shall be kept at locations where operations and maintenance
activities are conducted.
Magellan failed to follow its Inspection of Right-of-way Procedure, 7.05-ADM-006, which
requires the Operator to identify activity along the right-of-way that could, if not corrected, pose
a hazard or compromise the safety, integrity or operation of pipelines and right-of-way.
Specifically, several encroachments were observed during the field inspection with large
quantities of junk on the right-of-way (abandoned trucks and cars, and oil storage tanks) in West
Tulsa and near Drumright, OK. While barn construction predates the Magellan acquisition of the
pipeline, there are other indications of encroachment and overgrowth indicating Magellan is not
following its Inspection of Right-of-way Procedure for identifying conditions on the pipeline
right-of-way that could pose a hazard or compromise safety.
Specific locations where problems were found related to encroachment activities found on or adjacent to the pipeline
ROW include:
1. Sandler Road, tank on the ROW
2. Race Track Road, encroachment of equipment on the ROW
3. County Road 145, barn on the ROW
4. Commercial business wareyard on the ROW
5. Cushing 8”, truck and storage facilities encroaching on the ROW
6. Cushing 8”, oil field debris on the ROW
7. Wynnewood 12”, metal debris on the ROW
8. Cushing to Glenpool, abandoned vehicles on the ROW
9. West Tulsa Area, miscellaneous materials in yard over ROW
10. Tulsa to Drumright 8”, facility encroachment on the ROW
Major overgrowth which obscured the ROW was found at the following locations identified as follows:
1. 39th street
2. Caney River
3. 49th street
4. Glenpool to PSO
5. Glenpool to West Tulsa
7



6. South Ok City
7. Allen to Drumright 8”, MP68
6. 195.402(a) Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline commence, and
appropriate parts shall be kept at locations where operations and maintenance
activities are conducted.
Magellan did not install pipeline markers where the pipe is to remain exposed as specified by its
procedures, Corrosion Control Program, 7.04-ADM-001, 2.11.4. The Magellan procedures state
that if the pipe is to remain exposed, proper pipeline markers shall be installed. During the field
inspection exposures were observed without pipeline markers and without stated plans for
reburial. The Operator was found to have unmarked exposures on the Glenpool to West Tulsa,
Tulsa to Drumright, Drumright to Cushing, Cushing to Glenpool, Barnsdall to El Dorado, and
Odessa to El Paso pipelines.
7. 195.571 What criteria must I use to determine the adequacy of cathodic protection?
Cathodic protection required by this subpart must comply with one or more of the
applicable criteria and other considerations for cathodic protection contained in
paragraphs 6.2 and 6.3 of NACE Standard RP 0169 (incorporated by reference, see
§195.3).
Magellan did not meet one of the applicable cathodic protection criteria required by §195.571 for
portions of its pipeline system. With regard to §195.571, the Operator was unable to adequately
show how IR drop is considered in the pipe-to-soil readings as required by the referenced
standard (NACE RP 0169). Magellan also did not follow its Corrosion Control Program
procedure, 7.04-ADM-001, Sections 2.3 and 2.4. During the field portion of the inspection,
some pipe-to-soil readings were not meeting the criterion chosen by the Operator for determining
the adequacy of the cathodic protection. Examples of inadequate readings were found on the
Cimarron 8-inch pipeline at MP 53 (-683mV), MP 54 (-768mV), MP 61 (-696mV), MP 71 (-
707mv), the Odessa to El Paso pipeline at 9899+72 (-700mV), 9700+19 (-771mV), 9747+19 (-
500mV), 10123+95 (-500mV), 10264+00 (-654mV), the Cushing to Oklahoma City pipeline at
MP 30.5 (-781mV), MP 0.7 (-817mV), the Glenpool to PSO pipeline at MP 16.7 (-822mV), the
Tulsa to State Line pipeline at MP 110.5 (-500mV), MP 128.4 (-746mV).
8. 195.573 What must I do to monitor external corrosion control?
8



(d) Breakout tanks. You must inspect each cathodic protection system used to
control corrosion on the bottom of an aboveground breakout tank to ensure that
operation and maintenance of the system are in accordance with API Recommended
Practice 651. However, this inspection is not required if you note in the corrosion
control procedures established under §195.402(c)(3) why compliance with all or
certain operation and maintenance provisions of API Recommended Practice 651 is
not necessary for the safety of the tank.
Magellan did not meet one of the applicable cathodic protection criteria required by §195.573 for
some breakout tanks. For the breakout tanks not meeting the cathodic protection requirements,
the operator has not demonstrated why compliance with API 651 is unnecessary as required by
§195.573. Magellan also did not follow its Corrosion Control Program procedure, 7.04-ADM-
001, Sections 2.3 and 2.4. During the field portion of the inspection, some tank-to-soil readings
were not meeting the criterion chosen by the Operator for determining the adequacy of the
cathodic protection. With regard to §195.573, structure-to-soil readings for breakout tanks 533,
535, and 868 in Oklahoma City were found to not meet the criterion chosen by the operator.
9. 195.573 What must I do to monitor atmospheric corrosion control?
(c) If you find atmospheric corrosion during an inspection, you must provide
protection against the corrosion as required by Sec. 195.581.
Magellan failed to provide protection against atmospheric corrosion as required by §195.581.
The operator also did not follow its Corrosion Control Program procedure, 7.04-ADM-001,
Section 3.0. There were areas of oxidation observed on the chime area of some breakout tanks,
above ground valves and piping, flange bolts, pipe/soil interfaces, and spans at various locations
on the Magellan Pipeline System. Evidence includes photographs taken during the field inspection.
These photographs indicate ongoing atmospheric corrosion at the following locations:
1. Allen Station Breakout Tank (BOT) 880
2. Barnsdale BOT 1214
3. Barnsdale BOT 416
4. Barnsdale BOT 729
5. Barnsdale BOT 730
6. Enid BOT 1231
7. Enid BOT 1232
8. Enid BOT 1238
9. Odessa BOT 574
10. Odessa piping
11. Odessa BOT 586
12. Odessa BOT 225
13. Odessa BOT 228
14. Odessa BOT 229
15. Line #1, 8” MP 21
16. P/S Interface on Old Tulsa line
9



17. Orion West Unit
18. Orion West MP 312
19. Pipeline span near Black River Station
20. Glenpool to West Tulsa
21. MLV @ MP 21
22. Pipeline Span @ MP 46
10. 195.430 Firefighting equipment.
Each operator shall maintain adequate firefighting equipment at each pump station
and breakout tank area. The equipment must be-
(a) In proper operating condition at all times;
(b) Plainly marked so that its identity as firefighting equipment is clear; and,
(c) Located so that it is easily accessible during a fire.
Magellan does not maintain adequate firefighting equipment at each pump station and breakout
tank area. The Operator has only fire extinguishers at most pump stations and breakout tank
areas as required under its Portable Fire Extinguishers Administrative Procedure, 5.05-ADM-
076, which states that “equipment shall be adequate to extinguish fires that are in the early stages
of development and in no case shall be expected to fight a fully engulfed fire.” The Operator
relies on public firefighting agencies or firefighting cooperatives to respond to fires at their
breakout facilities. However, liaison documentation is not adequate to show that Magellan has
confirmed that these agencies have adequate training, equipment, and supplies to respond to fires
at their pump stations and breakout tank areas.
11. 195.432 Inspection of in-service breakout tanks.
(a) Except for breakout tanks inspected under paragraphs (b) and (c) of this section,
each operator shall, at intervals not exceeding 15 months, but at least once each
calendar year, inspect each in-service breakout tank.
(b) Each operator must inspect the physical integrity of in-service atmospheric and
low-pressure steel aboveground breakout tanks according to API Standard 653
(incorporated by reference, see §195.3). However, if structural conditions prevent
access to the tank bottom, the bottom integrity may be assessed according to a plan
included in the operations and maintenance manual under §195.402(c)(3).
The Magellan breakout tank inspection program and methodology to establish in-service and
out-of-service inspections does not meet the requirements for a risk-based inspection process
defined by API 653, incorporated into Part 195 by reference. Specifically, the Magellan Tank
Integrity Risk Based Inspection Procedure, 7.10-ADM-013, does not adequately incorporate
some of the factors in the referenced version of API 653, including the materials of construction,
the as-built standard, the accuracy and completeness of determining bottom plate thickness, the
methods used to determine the product side and soil side corrosion rates and accuracy of the
10



methods, the availability, accuracy and need for leak detection, the effectiveness of corrosion
mitigation measures, and the quality of maintenance including previous repairs. Magellan
personnel administering the risk-based program do not have formal training in risk-based
inspection methodology and no records showing initial and subsequent assessments of the
program by an authorized inspector and tank engineer were presented. Also, the Magellan
routine breakout tank inspections failed to identify issues that should be addressed by the
Operator’s breakout tank maintenance program such as plugged telltale holes, corrosion near the
floor to shell weld, corrosion of the extension, soil or gravel covering the extension, corrosion
around the perimeter of the reinforcing plates, cracked foundations supporting equipment and
piping connected to the tanks, incomplete records of construction and repairs, and documentation
that API 653 inspection recommended repairs were evaluated and completed or determined by
the operator to not be needed.
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 has recommended that
you be preliminarily assessed a civil penalty of $149,800 as follows:
Item number PENALTY
2 $ 61,500
4 $ 55,400
5 $ 32,900
Warning Items
With respect to item(s) 3, and 6 through 11 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 promptly correct these item(s).
Be advised that failure to do so may result in Magellan Pipeline Company being subject to
additional enforcement action.
Proposed Compliance Order
With respect to item(s) 1, 2, 4, and 5, pursuant to 49 United States Code § 60118, the Pipeline
and Hazardous Materials Safety Administration proposes to issue a Compliance Order to
Magellan Pipeline Company. 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 you11



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). If 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 4-2012-5010 and for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
12



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Magellan Pipeline Company a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Magellan
Pipeline Company with the pipeline safety regulations:
1. In regard to Item Number 1 of the Notice pertaining to electrical isolation where Magellan failed
to address metallically and electrolytically shorted casings, the Operator must perform tests to
determine if each casing is metallically or electrolytically shorted. If a casing is determined to be
metallically or electrolytically shorted, the Operator must evaluate any existing ILI data to
determine if there are metal loss indications and make any required repairs to the carrier pipe. If
no ILI data is available from studies made within the past five years, Magellan must perform
studies using ILI or an alternative technology to determine for each casing if there is metal loss
requiring repairs. The Operator must also clear the shorts, purge the casings of electrolyte, and
replace the end seals as described in NACE SP0200. The Operator must also develop a
procedure that specifically addresses the issue of electrolytically shorted casings.
2. In regard to Item Number 2 of the Notice pertaining to line markers where Magellan failed to
adequately mark its pipeline, the Operator must install additional line markers in the Barnsdall,
Tulsa, Oklahoma City, Odessa to El Paso, and Cimarron inspection units so that the location of
the pipeline is accurately known as required by 195.410.
3. In regard to Item Number 4 of the Notice pertaining to maximum operating pressure where
Magellan allowed the pipeline pressure to exceed the MOP for durations longer than indicated by
a surge event, the Operator must review the design of its overpressure protection and make
changes necessary to prevent recurrence. Magellan must also perform a review of the MOP’s for
each pipeline segment, check the setpoints of each overpressure device, ensure each overpressure
device is correctly tagged, and check each inspection form to ensure the tag numbers, maximum
pressures, and setpoints are all correct.
4. In regard to Item Number 5 of the Notice pertaining to patrolling the rights-of-way where
Magellan failed to identify activity along the right-of-way that could, if not corrected, pose a
hazard or compromise the safety, integrity or operation of pipelines and right-of-way specified
by its inspection of right-of-way procedure. The Operator also failed to remedy overgrowth that
prevents the inspection of the surface condition on or adjacent to the pipeline right-of-way, also
as specified by its right-of-way procedure. Magellan must make modifications to its patrolling
practices to ensure that its procedures are followed. The Operator must also remedy existing
encroachments that impair observation of the right-of-way and safety of the pipeline system.
The operator must also perform maintenance on areas of the right-of-way that are obscured by
vegetation.
5. Magellan must complete all items within 180 days following receipt of the Final Order.
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6. It is requested (not mandated) that Magellan Pipeline Company maintain documentation of the
safety improvement costs associated with fulfilling this Compliance Order and submit the total to
R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost
associated with replacements, additions and other changes to pipeline infrastructure.
14

420125010_Final Order_09022014_text.pdf

SEPTEMBER 2, 2014
Mr. Michael N. Mears
President and Chief Executive Officer
Magellan Midstream Partners, LP
Magellan Pipeline Company, LP
One Williams Center
Tulsa, OK 74172
Re: CPF No. 4-2012-5010
Dear Mr. Mears:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $149,800, and specifies corrective action that must be
completed. The penalty payment terms are set forth in the Final Order. When the civil penalty
has been paid and the terms of the compliance order completed, as determined by the Director,
Southwest Region, this enforcement action will be closed. Service of the Final Order is made
pursuant to 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. R.M. Seeley, Director, Southwest Region, OPS
Ms. Bizunesh Scott, Steptoe & Johnson LLP
1330 Connecticut Ave. NW, Washington, D.C. 20036
CERTIFIED MAIL – RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
___________________________________
In the Matter of )
Magellan Pipeline Company, LP, ) CPF No. 4-2012-5010
)
)
)
Respondent. )
___________________________________ )
FINAL ORDER
Between March 22, 2010, and April 22, 2011, pursuant 
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