# GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 420171001W
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-02-09
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.22(c)(2)(iii).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420171001w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420171001w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420171001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420171001W
**body:**

Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 191.22(c)(2)(iii). The case was opened on 2017-02-09 and is reported as closed as of 2017-02-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420171001W_Warning Letter_02092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171001W/420171001W_Warning%20Letter_02092017.pdf

420171001W_Warning Letter_02092017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171001W/420171001W_Warning%20Letter_02092017_text.pdf

420171001W_Warning Letter_02092017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 9, 2017
Jeffrey McMaine
Manager Codes and Standards
Gulf South Pipeline Company, LP.
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
CPF 4-2017-1001W
Dear Mr. McMaine:
In December 2016, representatives of the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code reviewed the notification reports filed
electronically by Gulf South Pipeline Company, LP (Gulf South). As a result of this review, it
appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49,
Code of Federal Regulations. The item reviewed and the probable violation is:
1. §191.22 National Registry of Pipeline and LNG Operators.
(c) Changes. Each operator must notify PHMSA electronically through the National
Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of certain
events.
(2) An operator must notify PHMSA of any following event not later than 60
days after the event occurs:
(iii) A change in the entity (e.g., company, municipality) responsible for
an existing pipeline, pipeline segment, pipeline facility, underground
natural gas storage facility, or LNG facility;



Gulf South failed to file notification of divestiture for 31 miles of gas transmission pipeline no
later than 60 days following the divestiture. Gulf South submitted an Operator Registry
Notification Type B for 31 miles of Onshore, Interstate pipeline, located in Beauregard County,
LA and Newton and Jasper Counties, TX. According to the information submitted, the divestiture
was completed on December 31, 2015, and the notification was not received until April 4, 2016
(94 days). This notification was required by March 1, 2016.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638
per violation per day the violation persists up to a maximum of $2,056,380 for a related series of
violations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum
penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed
$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012,
the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty
not to exceed $1,000,000 for a related series of violations. 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. We advise you to correct the
item identified in this letter. Failure to do so will result in Gulf South being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2017-1001W. 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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