GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter

420141001W_Warning_01102014_text.pdf, page 1Official PDFWARNING 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…#

420141001W_Warning_01102014_text.pdf, page 2As 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 2#