{"operation":"document","citation":"CPF 420145002W","title":"MAGELLAN PIPELINE COMPANY, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-03-06","effective_on":null,"summary":"CLOSED warning letter citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420145002W","body":"Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2014-03-06 and is reported as closed as of 2014-03-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420145002W_Warning Letter_03062014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145002W/420145002W_Warning%20Letter_03062014.pdf\n\n420145002W_Warning Letter_03062014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145002W/420145002W_Warning%20Letter_03062014_text.pdf\n\n420145002W_Warning Letter_03062014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 6, 2014\nMr. Michael Pearson\nVice President, Technical Services\nMagellan Pipeline, L.P.\nOne Williams Center, MD 27\nTulsa, OK 74172\nCPF 4-2014-5002W\nDear Mr. Pearson:\nBeginning as far back as June 2013 and continuing on through 2014 representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code are inspecting the construction of BridgeTex Project. The inspections\nconsist of both field and record audits related to the construction pursuant to Chapter 601 of 49\nUnited States Code.\nSpecifically during an inspection during the week of January 14, 2014, PHMSA was onsite and it\nappears that you have committed probable violations of the Pipeline Safety Regulations, Title 49,\nCode of Federal Regulations. The item inspected and the probable violation is:\n1. §195.202 Compliance with specifications or standards.\n“Each 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, Pipeline\nConstruction Specs Coating – External, Below Grade, Revision Date 9/27/2013. Magellan’s\n\n\n\nConstruction Specification, Section 5.2.4 states:\n“For Fusion Bonded Epoxy, the test voltage can be established by using the minimum\nvoltage for a given coating thickness as determined according to the following\ncalculation: V= K√T; Where V= peak voltage in volts, K= 525 and T= nominal coating\nthickness in mils. (Reference NACE SP0490).”\nAnd there also is listed a table for the reference voltages:\nTotal DFT\nmil)\n8 to 11 Suggest\nVoltage(V)\n1,500\n12 to 15 2,000\n16 to 20 2,500\n21 to 40 3,000\n41 to 55 4,000\n56 to 80 6,000\n81 to 125 10,000\n126 to 185 15,000\nDuring the observation of coating inspection tests or “jeeping” at the tie-in location (Station\n1220+ 24), Spread-1, BridgeTex Project, PHMSA observed that the voltage of the holiday\ndetector was not being set according to the procedure. Magellan set the voltage at 2100 volts\nwithout measuring the coating thickness. The inspection revealed no holidays. When questioned\nby PHMSA, Magellan measured the coating thickness: 55 mils at 12 o’clock, 39 mils at 3\no’clock, 50 mils at 6 o’clock, and 51 mils at 9 o’clock position at the tie-in location. According\nto the procedures, Magellan then reset the voltage at 3700 volts. This inspection revealed three\nholidays at that tie-in location.\nAs a result of the above, PHMSA had a concern about other tie-in locations (6) that might have\nbeen tested at an incorrect voltage set. Magellan acknowledged PHMSA’s concern and agreed\nto re-jeep those 6 tie-in locations with the correct voltage (3700 volts). Magellan found and\nremediated one additional holiday at Station 1216+15.\nOn February 3, 2014, Magellan emailed the list of all the tie-in locations in spread-1including the\ncorrected voltage set of the holiday detector, and the test results. It appears Magellan has\nadequately addressed the issue.\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.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2014-5002W. 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\n3","truncated":false,"body_characters":5277}