{"operation":"document","citation":"CPF 420135028W","title":"MAGELLAN PIPELINE COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-11-18","effective_on":null,"summary":"CLOSED warning letter citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135028w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135028w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135028w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420135028W","body":"Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2013-11-18 and is reported as closed as of 2013-11-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420135028W_Warning_11182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135028W/420135028W_Warning_11182013.pdf\n\n420135028W_Warning_11182013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135028W/420135028W_Warning_11182013_text.pdf\n\n420135028W_Warning_11182013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 18, 2013\nMr. Michael Pearson\nVice President, Technical Services\nMagellan Terminals Holdings, LP\nOne Williams Center, MD 27\nTulsa, OK 74172\nCPF 4-2013-5028W\nDear Mr. Pearson:\nDuring the week of September 23, 2013, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected\nconstruction of the El Paso Junction to Strauss 8” pipeline near El Paso, TX.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nMagellan Pipeline Company failed to follow their written construction specification, Document\nPipeline Construction Specs Coating – External, Below Grade, Revision Date 5/21/2009.\n\n\n\nMagellan’s written procedures state:\n5.2 Holiday Detection\n5.2.3 The detector shall be equipped with a visual and/or audible alarm to signal current\nflow through the apparatus. The test voltage shall be calibrated twice per shift using a\nhigh resistance and high impedence kilovolt meter. The minimum voltage output for\ncoating thickness shall be determined according to the following calculation:\nV = K√T\nWhere V = peak voltage in volts, K = a constant (525 British, 104 metric), and T =\nnominal coating thickness.\nDuring the inspection it was discovered holiday detector voltage settings were not being set\naccording to the formula specified in Magellan’s procedures. Construction personnel stated\nholiday detector voltage settings were determined by a formula other than that described in 5.2.3.\nVoltage settings were being determined by multiplying the coating thickness average of 15 mils\n(for FBE mainline pipe) by 125.\nMagellan’s written procedures also state:\n7.0 DOCUMENTATION\n7.1 Documentation of coating installation and repairs conducted per this procedure\nshould be documented Project Plan, Job Book, and/or Pipeline Maintenance Report as\napplicable.\nDuring the inspection, records to demonstrate twice per shift calibration of holiday detection\nequipment were not available for review.\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.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF4-2013-5028W. 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","truncated":false,"body_characters":4550}