{"operation":"document","citation":"CPF 420135010W","title":"MAGELLAN PIPELINE COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-04-18","effective_on":null,"summary":"CLOSED warning letter citing 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420135010W","body":"Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulation as 195.589(c). The case was opened on 2013-04-18 and is reported as closed as of 2013-04-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420135010W_Warning_04182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135010W/420135010W_Warning_04182013.pdf\n\n420135010W_Warning_04182013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135010W/420135010W_Warning_04182013_text.pdf\n\n420135010W_Warning_04182013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 18, 2013\nMr. Mike Pearson\nVice President, Technical Services\nMagellan Pipeline Company, L.P.\nOne Williams Center\nTulsa, OK 74172\nDear Mr. Pearson: CPF 4-2013-5010W\nOn multiple occasions between July 16 and October 24, 2012, a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\npursuant to Chapter 601 of 49 United States Code was onsite and inspected your Longhorn\nPipeline facilities from El Paso, TX to Houston, TX.\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,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to §§ 195.569,\n195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the\npipeline remains in service.\nMagellan failed to maintain a record of each Pipe to Soil (P/S) Cathodic Protection (CP)\nsurvey in sufficient detail to demonstrate the adequacy of corrosion control measures or\nthat corrosion requiring control measures does not exist. Specifically, Magellan failed to\n\n\n\nrecord seven (7) of the pipe to soil potentials taken at Cottonwood Station on the station\npiping.\nThese locations include:\n1. Incoming Mainline Block Valve\n2. Receiver Bypass Riser\n3. Receiver Kicker Riser\n4. Check Valve Inlet Riser\n5. Check Valve Outlet Riser\n6. Launcher Kicker Riser\n7. Launcher Bypass Riser\n8. Outgoing Mainline Block Valve\nUpon reviewing the historical CP reads for Cottonwood, PHMSA staff noted that only a\nsingle read was being recorded as “MP 576.320 Cottonwood Station Gate Valve.” This\ndescription doesn’t adequately describe this location as there are two electrically\ndiscontinuous gate valves at Cottonwood. Magellan personnel confirmed that they had in\nfact tested all eight (8) locations but only the lowest read was recorded.\nPHMSA staff reviewed the CP records for this portion of the line and identified that\nwhereas Cottonwood only had a single read; other locations such as Crane Station were\nidentified as a separate Pipeline “Segment” with station reads being recorded by different\nmilepost identifiers. Magellan personnel on site confirmed there procedural requirement\nwas to record each read separately and not just a summary read.\nMagellan’s procedure 7.04-ADM-001 Corrosion Control Program section 2.6.3\nstates:\n“2.6.3 Pipe-to-soil readings shall be obtained at pre-assigned locations\nidentified as necessary to determine the adequacy of cathodic protection.\nThese locations can include, but are not limited to, test stations, cased\ncrossings, and above ground appurtenances. Refer to Measuring a Pipe-to\nSoil Potential for more information.”\nIn an email dated February 20, 2013, Magellan provided records showing the changes to\ntheir database that allowed them to record each reading. This was accomplished by\nadding Milepost placeholders where prior inspections had been made on their above\nground appurtenances in the pipeline data rather than creating a separate “Segment” just\nfor Cottonwood station.\nThe additions to the “Test Point Inspections” record include:\n1. MP 576.320 Cottonwood Station Gate Valve Incoming\n2. MP 576.321 Incoming Pigtrap Bypass Riser\n2\n\n\n\n3. MP 576.322 Incoming Pigtrap Kicker Riser\n4. MP 576.323 Check Valve Inlet Riser\n5. MP 576.324 Check Valve Outlet Riser\n6. MP 576.325 Incoming Pigtrap Bypass Riser\n7. MP 576.326 Incoming Pigtrap Kicker Riser\n8. MP 576.327 Cottonwood Station Gate Valve Outgoing\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 being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2013-5010W. 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,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":6193}