# GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 420141003W
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-03-20
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.5(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420141003W
**body:**

Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 191.5(a). The case was opened on 2014-03-20 and is reported as closed as of 2014-03-20. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420141003W_Warning Letter_03202014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141003W/420141003W_Warning%20Letter_03202014.pdf

420141003W_Warning Letter_03202014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141003W/420141003W_Warning%20Letter_03202014_text.pdf

420141003W_Warning Letter_03202014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 20, 2014
Richard Keyser
Sr. Vice President of Operations
Gulf South Pipeline, LP
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
CPF 4-2014-1003W
Dear Mr. Keyser:
Between September 4, 2013 and February 28, 2014, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United
States Code, investigated a natural gas incident that occurred on March 3, 2013, at the Hall
Summit Compressor Station near Ringgold, Louisiana.
As a result of the review of the information provided, 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. §191.5 Immediate notice of certain incidents.
(a) At the earliest practicable moment following discovery, each operator shall give notice
in accordance with paragraph (b) of this section of each incident as defined in §191.3.
Gulf South failed to make telephonic notification as soon as practical following the unintentional
release of 23.79 MMCF of natural gas at the Hall Summit compressor station near Ringgold,
Louisiana that occurred on March 3, 2013. The release met the definition of a reportable incident



according to §191.3, and a telephonic notification was required as guided in Gulf South
Procedures (BWP-0009 (Part I), Event Notification Report.)
The release occurred due to a failed electrical wiring connection on the valve actuator controls
causing a coil to drop out which resulted in the valve opening to the fail safe open position. The
incident was confirmed by Gulf South at 12:37 a.m. on March 3, 2013, and the incident was not
reported to the National Response Center until 8:35 a.m., 8 hours after confirmed discovery.
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 4-2014-1003W. 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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