{"operation":"document","citation":"CPF 420135022W","title":"MAGELLAN PIPELINE COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-10-09","effective_on":null,"summary":"CLOSED warning letter citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135022w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135022w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135022w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420135022W","body":"Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2013-10-09 and is reported as closed as of 2013-10-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420135022W_Warning_10092013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135022W/420135022W_Warning_10092013.pdf\n\n420135022W_Warning_10092013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135022W/420135022W_Warning_10092013_text.pdf\n\n420135022W_Warning_10092013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 9, 2013\nMr. Michael Pearson\nVice President, Technical Services\nMagellan Pipeline Company\nOne Williams Center, MD 27\nTulsa, OK 74172\nCPF 4-2013-5022W\nDear Mr. Pearson:\nDuring the month of March 2013, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the construction\nof 24 inch diameter pipeline at Speed Station to Genoa Junction (South Houston Crude System) as the\npart of Longhorn Reversal Project. The inspection consisted of both field and record audits related to the\nconstruction pursuant to Chapter 601 of 49 United States Code.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable\nviolation is:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nMagellan Pipeline Company failed to follow their written construction specification, document Pipeline\nConstruction Horizontal Directional Drilling, revised on 9/9/2009.\nMagellan’s construction procedure, Section 5.0 (Ream and pull back); Paragraph 5.2 states:\n“The entire pull section shall be subjected to a 4-hour hydrostatic pretest prior to installation in\nthe hole. The pretest pressure shall be equal to or exceed that required for final certification but\nshall not exceed 98% of SMYS. The hydrostatic pretest shall be conducted and documented\naccording to the cleaning, testing and drying section of this specification.”\n\n\n\nDuring the record inspection, PHMSA identified two locations where Magellan failed to conduct\nhydrostatic pretest of the pipe segments used for the installation of the boring and/or Horizontal\nDirectional Drills (HDDs) applications at Speed Station to Genoa Junction (South Houston Crude\nSystem) as the part of Longhorn Reversal Project. The identified locations are as follow-\nProject\nnumber\nHDD\ncrossing\nStation Mile post Total length\n3590 Ave F, Ave G\nand Ave H\n176 + 38 3.34 950 feet\n3590 Gilpin St,\nHCFCD and\nHinds St\n242 +28 4.59 950 feet\nOn July 1, 2013, Magellan conducted the post-hydrostatic test (8 hours) of the aforementioned locations\nand passed the test successfully. Magellan provided the test reports to PHMSA on August 26, 2013.\nPHMSA reviewed the hydrostatic test documentation and found it acceptable.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item identified in this letter. Failure to do so will result in Magellan being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-\n2013-5022W. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4710}