# GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420181001
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-01-31
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.465(d), 192.605(a), 192.615(b)(2), 192.743(a), 192.743(b).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420181001.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420181001
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420181001
**body:**

Notice of Probable Violation involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.465(d),  192.605(a),  192.615(b)(2),  192.743(a),  192.743(b). The case was opened on 2018-01-31 and is reported as closed as of 2019-12-13. Proposed civil penalty: $62,000. Assessed civil penalty: $62,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420181001_Closure Letter_12132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_Closure%20Letter_12132019.pdf

420181001_Closure Letter_12132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_Closure%20Letter_12132019_text.pdf

420181001_Final Order_08082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_Final%20Order_08082019.pdf

420181001_Final Order_08082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_Final%20Order_08082019_text.pdf

420181001_NOPV PCP PCO_01312018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_NOPV%20PCP%20PCO_01312018.pdf

420181001_NOPV PCP PCO_01312018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_NOPV%20PCP%20PCO_01312018_text.pdf

420181001_Operator Response to Notice_02262018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181001/420181001_Operator%20Response%20to%20Notice_02262018.pdf

420181001_Closure Letter_12132019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 13, 2019
Richard Keyser
Sr. Vice President of Operations
Gulf South Pipeline, LP
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
CPF 4-2018-1001
Dear Mr. Keyser:
On August 8, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Gulf South Pipeline a Final Order in the above-referenced case. This Order included a
Compliance Order and Civil Penalty assessment. Based on our review of the documentation you
provided and confirmation of payment of the civil penalty, it has been determined that you have
complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

420181001_Final Order_08082019_text.pdf

August 8, 2019
Mr. Stanley Horton
Chief Executive Officer and President
Boardwalk Pipeline Partners, LP
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
Re: CPF No. 4-2018-1001
Dear Mr. Horton:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary, Gulf
South Pipeline, LP. It makes findings of violation and assesses a civil penalty of $62,000. This
is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated February
26, 2018. When the terms of the compliance order are completed, as determined by the Director,
Southwest Region, this enforcement action will be closed. Service of the Final Order by
certified mail is effective upon the date of mailing, as provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Richard Keyser, Sr. Vice President of Operations, Gulf South Pipeline, LP
Ms. Tina H. Baker, Manager, Compliance Services, Gulf South Pipeline, LP
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
________________________________________ ____
In the Matter of )
Gulf South Pipeline, LP, ) CPF No. 4-2018-1001
a subsidiary of Boardwalk Pipeline Partners, LP, )
)
)
)
Respondent. )
__________________________________________ )
FINAL ORDER
From May 8, 2015, through September 15, 2016, pursuant to 49 U.S.C. § 60117, representatives
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline
Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Gulf
South Pipeline, LP (Gulf South or Respondent), a wholly-owned, operating subsidiary of
Boardwalk Pipeline Partners, LP,1 in Texas and Louisiana. Gulf South is an interstate natural
gas system that gathers gas from basins between Texas and Alabama and delivers to on-system
markets in the Northeast, Midwest, and Southeast through interconnections with third-party
pipelines. The Gulf South system is composed of approximately 7,275 miles of pipeline having
an average daily throughput of approximately 2.8 billion cubic feet (of natural gas) per day in
2017. Gulf South is headquartered in Houston, Texas, with a major operations office in
Owensboro, Kentucky.2
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated January 31, 2018, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice), which also included a warning pursuant to 49
C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that
Gulf South had committed four violations of 49 C.F.R. Part 192 and proposed assessing a civil
penalty of $62,000 for the alleged violations. The Notice also proposed ordering Respondent to
take certain measures to correct the alleged violations. The warning item required no further
action, but warned the operator to correct the probable violation or face possible future
enforcement action.
Gulf South responded to the Notice by letter dated February 26, 2018 (Response). The company
did not contest the allegations of violation and paid the proposed civil penalty of $62,000. In
1 http://www.gulfsouthpl.com/ (last accessed June 24, 2019).
2 Pipeline Safety Violation Report (on file with PHMSA).



CPF No. 4-2018-1001
Page 2
accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate
Administrator to make findings of violation and to issue this final order without further
proceedings. The company also provided information concerning the corrective actions it had
agreed to complete under the proposed compliance order. Respondent did not request a hearing
and therefore has waived its right to one.
FINDINGS OF VIOLATION
In its Response, Gulf South did not contest the allegations in the Notice that it violated 49 C.F.R.
Part 192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.615(b)(2), which states:
§ 192.615 Emergency plans.
(a) ….
(b) Each operator shall: ….
(2) Train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training is
effective.
The Notice alleged that Respondent violated 49 C.F.R. § 192.615(b)(2) by failing to perform
training of personnel through mock drills to assure knowledge of the emergency procedures and
to verify effectiveness of the training as required by Gulf South Procedure 3010 – Event
Response Plan, dated June 1, 2016. Specifically, the Notice alleged that Gulf South failed to
conduct exercises and mock drills in its Hall Summit-Sarepta, Westlake, and Goodrich Units in
2014, and its Hall Summit-Sarepta, and Goodrich Units in 2015, despite its procedure and the
regulation requiring such action.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.615(b)(2) by failing to perform
training of personnel through mock drills to assure knowledge of the emergency procedures and
to verify effectiveness of the training as required.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.743(a)-(b), which states:
§ 192.743 Pressure limiting and regulating stations: Capacity of relief
devices.
(a) Pressure relief devices at pressure limiting stations and pressure
regulating stations must have sufficient capacity to protect the facilities to
which they are connected. Except as provided in § 192.739(b), the capacity
must be consistent with the pressure limits of § 192.201(a). This capacity
must be determined at intervals not exceeding 15 months, but at least once
each calendar year, by testing the devices in place or by review and
calculations.
(b) If review and calculations are used to determine if a device has



CPF No. 4-2018-1001
Page 3
sufficient capacity, the calculated capacity must be compared with the rated
or experimentally determined relieving capacity of the device for the
conditions under which it operates. After the initial calculations, subsequent
calculations need not be made if the annual review documents that
parameters have not changed to cause the rated or experimentally
determined relieving capacity to be insufficient.
The Notice alleged that Respondent violated 49 C.F.R. § 192.743(a)-(b) by failing to properly
determine the capacity of pressure-relief devices to protect the facilities to which they are
connected. Specifically, the Notice alleged that Gulf South’s control room equipment inspection
reports, which were presented as records of annual inspection of overpressure protection, failed
to reflect actual or up-to-date information related to regulator and relief-valve capacities at
several locations. The Notice stated that the required annual testing or reviews of capacities of
regulators and overpressure protection relief devices should have revealed to the reviewers that,
in some cases, capacities of regulators appeared to exceed the capacities of overpressure
protective-relief devices.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.743(a)-(b) by failing to properly
determine the capacity of pressure-relief devices to protect the facilities to which they are
connected.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d), which states:
§ 192.465 External corrosion control: Monitoring.
(a) ….
(d) Each operator shall take prompt remedial action to correct any
deficiencies indicated by the monitoring.
The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt
remedial action to remediate cathodic-protection deficiencies discovered during annual
monitoring of cathodically protected facilities. Specifically, the Notice alleged that Gulf South
failed to meet the established criteria for adequate cathodic protection for 2014 and 2015 on its
Line 64, Magasco C.S. to Call Junction, as evidenced by pipe-to-soil measurements taken at mile
pole 62.9600, and pipe-to-soil measurements taken at mile pole 63.9010, which failed to meet
adequate cathodic-protection levels for 2014, 2015, and 2016.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt
remedial action to remediate cathodic-protection deficiencies discovered during annual
monitoring of cathodically protected facilities.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.



CPF No. 4-2018-1001
Page 4
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.3 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; any effect that
the penalty may have on its ability to continue doing business; and the good faith of Respondent
in attempting to comply with the pipeline safety regulations. In addition, I may consider the
economic benefit gained from the violation without any reduction because of subsequent
damages, and such other matters as justice may require. The Notice proposed a total civil
penalty of $62,000 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $29,600 for Respondent’s violation of 49 C.F.R.
§ 192.615(b)(2), for failing to perform training of personnel through mock drills to assure
knowledge of the emergency procedures and to verify effectiveness of the training as required by
Gulf South Procedure 3010 – Event Response Plan. Gulf South neither contested the allegation
nor presented any evidence or argument justifying a reduction or elimination of the proposed
penalty. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Respondent a civil penalty of $29,600 for violation of 49 C.F.R. § 192.615(b)(2).
Item 4: The Notice proposed a civil penalty of $32,400 for Respondent’s violation of 49 C.F.R.
§ 192.465(d), for failing to take prompt action to remediate cathodic-protection deficiencies
discovered during annual monitoring of cathodically protected facilities. Gulf South neither
contested the allegation nor presented any evidence or argument justifying a reduction or
elimination of the proposed penalty. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Respondent a civil penalty of $32,400 for violation of 49 C.F.R.
§ 192.465(d).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $62,000, which amount was paid
in full by wire transfer on February 26, 2018.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 3 in the Notice for a violation of 49
C.F.R. § 192.743(a)-(b). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of hazardous liquids or who owns or operates a pipeline facility is required to
comply with the applicable safety standards established under chapter 601. Pursuant to the
authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the
following actions to ensure compliance with the pipeline safety regulations applicable to its
3 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223; Revisions to Civil Penalty Amounts,
83 Fed. Reg. 60732, 60744 (Nov. 27, 2018).



CPF No. 4-2018-1001
Page 5
operations:
1. With respect to the violation of § 192.743(a)-(b) (Item 3), Respondent must:
a. Conduct a review of pressure-reduction and relief-device capacities to
ensure adequate overpressure protection capacities are in place to maintain
downstream operating pressures within the maximum allowable operating
pressure limits and provide training to individuals responsible for the
annual reviews required by § 192.743.
b. Provide documentation of the reviews of pressure reduction and
overpressure protection capacities performed. Also provide the names and
dates of when the training was completed for individuals who would be
performing the annual reviews required by § 192.743.
2. Gulf South shall complete the items required by this Compliance Order within
120 days after receipt of the Final Order.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
It is requested (not mandated) that Respondent maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total to the
Director. It is requested that these costs be reported in two categories: (1) total cost associated
with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated
with replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for
each day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
WARNING ITEM
With respect to Item 2, the Notice alleged probable violations of Part 192 but did not propose a
civil penalty or compliance order for this item. Therefore, this is considered to be a warning
item. The warning was for:
49 C.F.R. §§ 192.605(a) and 192.615(b)(3) (Item 2) ─ Respondent’s alleged
failure to perform a review of employee activities following an emergency
situation to determine whether emergency procedures were effectively followed
as required by Gulf South Procedure 3010 – Event Response Plan.



CPF No. 4-2018-1001
Page 6
If OPS finds a violation of these provisions in a subsequent inspection, Respondent may be
subject to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this
Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and
meet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective
action, remain in effect unless the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
August 8, 2019
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

420181001_NOPV PCP PCO_01312018_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 31, 2018
Mr. Richard Keyser
Sr. Vice President of Operations
Gulf South Pipeline, LP
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
CPF 4-2018-1001
Dear Mr. Keyser:
On multiple occasions between May 8, 2015 and September 15, 2016, representatives of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), pursuant to Chapter 601 of 49 United States Code were onsite and inspected Gulf South
Pipeline’s assets in Texas and Louisiana.
As a result of the investigation, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. §192.605 Procedural manual for operations, maintenance and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operating and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least



once each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
§ 192.615 Emergency plans.
(b) Each operator shall:
(2) Train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training is
effective.
Gulf South failed to perform training of personnel through mock drills to assure knowledge
of the emergency procedures and to verify effectiveness of the training as required by Gulf
South Procedure 3010.
During the inspection, records of annual training of personnel in emergency procedures
and mock drills were reviewed for the operating areas visited.
In 2014, exercises and mock drills were not conducted in Hall Summit Sarepta, Westlake,
and Goodrich Units and in 2015, exercises and mock drills were not conducted in Hall
Summit Sarepta and Goodrich Units.
Gulf South Procedure 3010 – Event Response Plan states:
“Supervisors who may be expected to implement a portion of this plan shall:
 Verify that training is effective through performance of exercises and mock drills
(document on Form 3000-40: Emergency Response Scenario and Training
Record); and
 Review employee activities after responses to events and emergency situations to
determine whether procedures were adequate and were effectively followed.
Documentation of training meetings, people attending, and the material covered
shall be put in writing and maintained in field office records (document on Form
0000-10: Meeting/Training Roster).
Exercises and mock drills shall be conducted periodically, typically once a year, as
operations permit. Exercise documentation shall be maintained at each facility
(document on Form 3000-40: Emergency Response Scenario and Training Record).”
2. §192.605 Procedural manual for operations, maintenance and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operating and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed
2



and updated by the operator at intervals not exceeding 15 months, but at least
once each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
§ 192.615 Emergency plans.
(b) Each operator shall:
(3) Review employee activities to determine whether the procedures were
effectively followed in each emergency.
Gulf South failed to perform a review of employee activities following an emergency situation
to determine whether emergency procedures were effectively followed as required by Gulf
South Procedure 3010.
Event Notification Reports 1062 and 1063 involved pipeline leaks that occurred within 220
yards of a building intended for human occupancy. The events did not result in reportable
Safety Related Condition Reports since they were promptly corrected. They were, however,
considered to be emergency situations due to their proximity to a building intended for human
occupancy.
Gulf South’s documentation of these emergency event situations on Form 3000-10 did not
include a review of employee activities to determine whether procedures were effectively
followed in response to the emergency.
Gulf South Procedure 3010 – Event Response Plan states:
“Supervisors who may be expected to implement a portion of this plan shall:
 Review employee activities after responses to events and emergency situations to
determine whether procedures were adequate and were effectively followed.”
Gulf South Procedure 2130 – General Operation of the Pipeline states:
Safety-Related Condition
“Potential safety-related conditions include, but are not limited to the following:
 A leak in a pipeline or LNG facility that contains or processes gas or LNG that
constitutes and emergency. A leak discovered, especially one that exists within 220
yards (220 m) from any building intended for human occupancy or outside place of
assembly by default is an emergency.”
3. §192.743 Pressure limiting and regulating stations: Capacity of relief devices.
(a) Pressure relief devices at pressure limiting stations and pressure regulating stations
must have sufficient capacity to protect the facilities to which they are connected. Except
as provided in §192.739(b), the capacity must be consistent with the pressure limits of
§192.201(a). This capacity must be determined at intervals not exceeding 15 months, but
3



at least once each calendar year, by testing the devices in place or by review and
calculations.
(b) If review and calculations are used to determine if a device has sufficient capacity,
the calculated capacity must be compared with the rated or experimentally
determined relieving capacity of the device for the conditions under which it operates.
After the initial calculations, subsequent calculations need not be made if the annual
review documents that parameters have not changed to cause the rated or
experimentally determined relieving capacity to be insufficient.
Gulf South failed to properly determine the capacity of pressure relief devices to protect the
facilities to which they are connected as required by §192.743.
The Control Equipment Inspection Reports presented as a record of annual inspection of
overpressure protection did not represent actual or up to date information related to regulator and
relief valve capacities. Outlined below are locations where overpressure protection device
capacities were presented incorrectly on the Control Equipment Inspection Report form.
The required annual testing or reviews of capacities of regulators and overpressure protection relief
devices should have revealed to the reviewers that, in some cases, capacities of regulators appeared
to exceed the capacities of overpressure protective relief devices.
Control Equipment Inspection Reports for Relief Valve SLN 571, Alto City Gate Equipment No.
255600 and Regulator SLN 571, Alto City Gate Reg-Primary Equipment No. 255501 indicate
improper capacities of 71.5 MSCF/HR and 85 MSCF/HR respectively for 2013 and 2015.
Control Equipment Inspection Report for Relief Valve SLN 508 Entex-Carthage TB Equipment
No. 255695 indicated an inadequate capacity of 266 MSCF/HR with the Regulator Capacity @ set
point of MAOP to the relief valve in MSCF/HR of 500 in the 2013 inspection cycle.
Control Equipment Inspection Reports reviewed from 2011 – 2015 indicated the capacity of Relief
Valve 727470-1 SLN 4695 Equipment No. 257753 to be 2835 MSCF/HR and Regulator Capacity
(Equipment No. 259011) @ set point of MAOP to the relief valve in MSCF/HR to also be 2835.
Further investigation revealed the correct capacities of the Relief Valve and Regulator to be 2218.4
and 1926.3 MSCF/HR respectively.
Gulf South Procedure 2050 – Regulator and Overpressure Protection states:
“Requirements and Frequencies for Testing and Inspection
Operations Personnel shall inspect and test all DOT regulated pressure regulating
and overpressure protection equipment at facilities to determine that it meets the
following:
 In good mechanical condition;
 Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
4



 Properly installed and protected from dirt, liquids, or other conditions that might
prevent proper operation; and
 It is set to function at the correct pressure.
Annually the Regional Measurement Leader (RML) shall perform capacity verification on all
regulator, relief valve and/or overpressure protection equipment.”
4. §192.465 External corrosion control: Monitoring.
(d) Each operator shall take prompt remedial action to correct any deficiencies indicated by
the monitoring.
Gulf South failed to take prompt remedial action to remediate cathodic protection deficiencies
discovered during annual monitoring of cathodically protected facilities.
On Line 64, Magasco C.S. to Call Junction, pipe-to-soil measurements taken at mile pole 62.9600
failed to meet the established criteria for adequate cathodic protection for 2014 and 2015 and pipe-
to-soil measurements taken at mile pole 63.9010 failed to meet adequate cathodic protection levels
for 2014, 2015, and 2016.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related
series of violations. For violations occurring prior to November 2, 2015, 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. The Compliance Officer has reviewed the circumstances and
supporting documentation involved in the above probable violation(s) and has recommended that
you be preliminarily assessed a civil penalty of $62,000as follows:
Item number PENALTY
1 $ 29,600
4 $ 32,400
Warning Items
With respect to Item 2, 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 promptly correct these items. Failure to do so may
result in additional enforcement action.
5



Proposed Compliance Order
With respect to Item 3 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Gulf South Pipeline, LP.
Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. All
material submit in response to this enforcement action may be 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). If you do not respond within 30 days of receipt of this Notice, this constitutes a
waiver of your right to contest the allegations in this Notice and authorizes the Associate
Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to
you and to issue a Final Order.
In your correspondence on this matter, please refer to CPF 4-2018-1001 and for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Terri J. Binns
Acting Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
6



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Gulf South Pipeline, LP a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Gulf South
Pipeline, LP with the pipeline safety regulations:
1. 2. 3. In regard to Item Number 3 of the Notice pertaining to the failure to properly
determine the capacity of pressure reduction and relief devices to protect facilities
to which they are connected as required by §192.743:
a. Gulf South must conduct a review of pressure reduction and relief device
capacities to ensure adequate overpressure protection capacities are in place to
maintain downstream operating pressures within the MAOP limits and provide
training to individuals responsible for the annual reviews required by §192.743.
b. Provide documentation of the reviews of pressure reduction and overpressure
protection capacities performed. Also provide the names and dates of when the
training was completed for individuals who would be performing the annual
reviews required by §192.743.
Gulf South shall complete Item 1 within 60 days after receipt of the Final Order.
It is requested (not mandated) that Gulf South Pipeline, LP maintain documentation
of the safety improvement costs associated with fulfilling this Compliance Order
and submit the total to Terri J. Binns, Acting Director, Southwest Region, Pipeline
and Hazardous Materials Safety Administration. It is requested that these costs be
reported in two categories: 1) total cost associated with preparation/revision of
plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
7
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