# MAGELLAN PIPELINE COMPANY, LP — Warning Letter

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

Official case documents:

420135022W_Warning_10092013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135022W/420135022W_Warning_10092013.pdf

420135022W_Warning_10092013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135022W/420135022W_Warning_10092013_text.pdf

420135022W_Warning_10092013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 9, 2013
Mr. Michael Pearson
Vice President, Technical Services
Magellan Pipeline Company
One Williams Center, MD 27
Tulsa, OK 74172
CPF 4-2013-5022W
Dear Mr. Pearson:
During the month of March 2013, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the construction
of 24 inch diameter pipeline at Speed Station to Genoa Junction (South Houston Crude System) as the
part of Longhorn Reversal Project. The inspection consisted of both field and record audits related to the
construction pursuant to Chapter 601 of 49 United States Code.
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 item inspected and the probable
violation is:
1. §195.202 Compliance with specifications or standards.
Each pipeline system must be constructed in accordance with comprehensive written
specifications or standards that are consistent with the requirements of this part.
Magellan Pipeline Company failed to follow their written construction specification, document Pipeline
Construction Horizontal Directional Drilling, revised on 9/9/2009.
Magellan’s construction procedure, Section 5.0 (Ream and pull back); Paragraph 5.2 states:
“The entire pull section shall be subjected to a 4-hour hydrostatic pretest prior to installation in
the hole. The pretest pressure shall be equal to or exceed that required for final certification but
shall not exceed 98% of SMYS. The hydrostatic pretest shall be conducted and documented
according to the cleaning, testing and drying section of this specification.”



During the record inspection, PHMSA identified two locations where Magellan failed to conduct
hydrostatic pretest of the pipe segments used for the installation of the boring and/or Horizontal
Directional Drills (HDDs) applications at Speed Station to Genoa Junction (South Houston Crude
System) as the part of Longhorn Reversal Project. The identified locations are as follow-
Project
number
HDD
crossing
Station Mile post Total length
3590 Ave F, Ave G
and Ave H
176 + 38 3.34 950 feet
3590 Gilpin St,
HCFCD and
Hinds St
242 +28 4.59 950 feet
On July 1, 2013, Magellan conducted the post-hydrostatic test (8 hours) of the aforementioned locations
and passed the test successfully. Magellan provided the test reports to PHMSA on August 26, 2013.
PHMSA reviewed the hydrostatic test documentation and found it acceptable.
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 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-
2013-5022W. 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
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