# MAGELLAN PIPELINE COMPANY, LP — Warning Letter

- **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:** Not available
- **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.

Official case documents:

420135010W_Warning_04182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135010W/420135010W_Warning_04182013.pdf

420135010W_Warning_04182013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135010W/420135010W_Warning_04182013_text.pdf

420135010W_Warning_04182013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 18, 2013
Mr. Mike Pearson
Vice President, Technical Services
Magellan Pipeline Company, L.P.
One Williams Center
Tulsa, OK 74172
Dear Mr. Pearson: CPF 4-2013-5010W
On multiple occasions between July 16 and October 24, 2012, a representative of the Pipeline
and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
pursuant to Chapter 601 of 49 United States Code was onsite and inspected your Longhorn
Pipeline facilities from El Paso, TX to Houston, TX.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. 195.589 What corrosion control information do I have to maintain?
(c) You must maintain a record of each analysis, check, demonstration,
examination, inspection, investigation, review, survey, and test required by this
subpart in sufficient detail to demonstrate the adequacy of corrosion control
measures or that corrosion requiring control measures does not exist. You must
retain these records for at least 5 years, except that records related to §§ 195.569,
195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the
pipeline remains in service.
Magellan failed to maintain a record of each Pipe to Soil (P/S) Cathodic Protection (CP)
survey in sufficient detail to demonstrate the adequacy of corrosion control measures or
that corrosion requiring control measures does not exist. Specifically, Magellan failed to



record seven (7) of the pipe to soil potentials taken at Cottonwood Station on the station
piping.
These locations include:
1. Incoming Mainline Block Valve
2. Receiver Bypass Riser
3. Receiver Kicker Riser
4. Check Valve Inlet Riser
5. Check Valve Outlet Riser
6. Launcher Kicker Riser
7. Launcher Bypass Riser
8. Outgoing Mainline Block Valve
Upon reviewing the historical CP reads for Cottonwood, PHMSA staff noted that only a
single read was being recorded as “MP 576.320 Cottonwood Station Gate Valve.” This
description doesn’t adequately describe this location as there are two electrically
discontinuous gate valves at Cottonwood. Magellan personnel confirmed that they had in
fact tested all eight (8) locations but only the lowest read was recorded.
PHMSA staff reviewed the CP records for this portion of the line and identified that
whereas Cottonwood only had a single read; other locations such as Crane Station were
identified as a separate Pipeline “Segment” with station reads being recorded by different
milepost identifiers. Magellan personnel on site confirmed there procedural requirement
was to record each read separately and not just a summary read.
Magellan’s procedure 7.04-ADM-001 Corrosion Control Program section 2.6.3
states:
“2.6.3 Pipe-to-soil readings shall be obtained at pre-assigned locations
identified as necessary to determine the adequacy of cathodic protection.
These locations can include, but are not limited to, test stations, cased
crossings, and above ground appurtenances. Refer to Measuring a Pipe-to
Soil Potential for more information.”
In an email dated February 20, 2013, Magellan provided records showing the changes to
their database that allowed them to record each reading. This was accomplished by
adding Milepost placeholders where prior inspections had been made on their above
ground appurtenances in the pipeline data rather than creating a separate “Segment” just
for Cottonwood station.
The additions to the “Test Point Inspections” record include:
1. MP 576.320 Cottonwood Station Gate Valve Incoming
2. MP 576.321 Incoming Pigtrap Bypass Riser
2



3. MP 576.322 Incoming Pigtrap Kicker Riser
4. MP 576.323 Check Valve Inlet Riser
5. MP 576.324 Check Valve Outlet Riser
6. MP 576.325 Incoming Pigtrap Bypass Riser
7. MP 576.326 Incoming Pigtrap Kicker Riser
8. MP 576.327 Cottonwood Station Gate Valve Outgoing
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item(s) identified in this letter.
Failure to do so will result in Magellan being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2013-5010W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
3
- **truncated:** false
- **body characters:** 6193