# GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 420141001W
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-01-10
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.619(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420141001W
**body:**

Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.619(a). The case was opened on 2014-01-10 and is reported as closed as of 2014-01-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420141001W_Warning_01102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141001W/420141001W_Warning_01102014.pdf

420141001W_Warning_01102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141001W/420141001W_Warning_01102014_text.pdf

420141001W_Warning_01102014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 10, 2014
Mr. Richard Keyser
Senior Vice President of Operations
Gulf South Pipeline Company, LP
9 Greenway Plaza
Suite 2800
Houston, Texas 77046
CPF 4-2014-1001W
Dear Mr. Keyser:
Between September 27, 2013 and December 19, 2013, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code, reviewed Safety Related Condition Report 2013-0107 submitted September 27,
2013, by Gulf South Pipeline Company, L. P. (Gulf South) for a safety related incident that
occurred in St. Charles, Louisiana.
As a result of the review, 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. § 192.619 Maximum allowable operating pressure: Steel or plastic pipelines.
(a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a
maximum allowable operating pressure determined under paragraph (c) or (d) of this
section…



As indicated in your Safety Related Condition Report, Gulf South experienced an overpressure
condition that met the reporting criteria for a safety related condition. On September 24, 2013, a
portion of your Luling to Barataria (Index 291) pipeline was operated at a pressure that exceeded
the maximum allowable operating pressure for the line. The established MAOP for the line, at
the time of the event and report was 490 PSIG. The MAOP was exceeded for approximately 29
minutes with maximum pressures climbing into the 708 PSIG range. The maximum pressures
exceeded 110% of the MAOP of the line at the time of the event.
This event is reflected in the Safety Related Condition Report you filed with PHMSA, as well as
provided other documentation related to the event.
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.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2014-1001W. 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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