{"operation":"document","citation":"CPF 420171007W","title":"GULF SOUTH PIPELINE COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-07","effective_on":null,"summary":"CLOSED warning letter citing 192.303, 192.461(a)(1), 192.461(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420171007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420171007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420171007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420171007W","body":"Warning Letter involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.461(a)(1),  192.461(a)(2). The case was opened on 2017-06-07 and is reported as closed as of 2017-06-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420171007W_Warning Letter_06072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171007W/420171007W_Warning%20Letter_06072017.pdf\n\n420171007W_Warning Letter_06072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420171007W/420171007W_Warning%20Letter_06072017_text.pdf\n\n420171007W_Warning Letter_06072017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 7, 2017\nMr. Richard Keyser\nSenior Vice President of Operations\nGulf South Pipeline Company, LP\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nCPF-4-2017-1007W\nDear Mr. Keyser:\nOn May 17-18, 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nyour Coastal Bend Header Construction Project near milepost 9 in Wharton County, TX.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.303 Compliance with specifications or standards\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\n\n\n\n§192.461 External corrosion control: Protective Coating.\nEach external protective coating, whether conductive or insulating, applied for the\npurpose of external corrosion control must –\n(1) Be applied on a properly prepared surface;\n(2) Have sufficient adhesion to the metal surface to effectively resist underfilm\nmigration of moisture;\nGulf South Pipeline failed to follow their written construction specification, #OP-CC-GS-COAT-\n002, General Coating Specifications of Below Ground Facilities Addendum, 07/08/2014 as noted\nbelow:\nGulf South Pipeline’s Coating Specification, Section 3.3 states:\n“All metal surfaces, except those specifically exempted in these specifications, shall be\nabrasive blast clean to a “Near White Blast Cleaning” in accordance with NACE 2 / SSPC-\nSP 10 or better. Contractor shall use dry abrasive and compressed air that has been passed\nthrough adequate water and oil traps. Any surface that has been blasted shall be coated the\nsame day. Abrasive blast shall result in a maximum surface profile as outlined in Table 7-\n1 and Table 7-2.”\nAt the time of the inspection, the field joint surface preparation did not meet the Near White Blast\nCleaning requirement as specified in the operators’ Coating Specification of Below Ground\nFacilities Section 3 Surface Preparation and Section 4.1 Surface Conditions, IBR NACE 2/SSPC-\nSP 10 or better. According to NACE No. 2/SSPC-SP 10, Near-White Metal Blast Cleaning is\ndefined as “A near-white metal blast cleaned surface, when viewed without magnification, shall\nbe free of all visible: Oil, Rust, Grease, Coating, Oxides, Dirt, Dust, Mil Scale, Corrosion products\nand Other foreign matter except for staining”. Visual inspection of the surface by PHMSA after\nblasting showed that the surface had abrasive residue/dust that did not comply with the\nNACE/SSPC joint surface preparation standards.\nGulf South Pipeline’s Coating Specification, Section 5.2 states:\n“Unless otherwise approved by Company inspector, a Company inspector shall inspect all\nprepared surfaces and previously coated areas and verify that the work meets coating\nspecifications before Contractor applies the first coat or additional coats. Drying time and\nrecoat schedule shall meet the manufacturer’s published recoat schedule.”\nAt the time of the inspection, the finished field joint coating revealed a low dry film thickness\n(DFT) reading which was below the required film thickness stated in the operator’s coating\nspecification. The operator’s coating specification requires 22-30 mils of FBE on the mainline.\nActual DFT readings during the observation using a Type 1 DFT gauge revealed measurements\nvarying from 16 to 18 mils.\n2\n\n\n\nAfter the above findings were identified to Gulf South Pipeline by PHMSA, the operator re-blasted\nand re-coated the field joint. The field joint coating thickness was verified again meeting the\noperator’s coating specification. The changes were confirmed during a follow-up inspection on\nMay 18, 2017.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 for a related series of violations. Also, for LNG facilities, an additional penalty of not\nmore than $76,352 for each violation may be imposed. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Gulf South Pipeline Company, LP\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2017-1007W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nJon Manning, P.E.\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6092}