{"operation":"document","citation":"CPF 420187001W","title":"GEL OFFSHORE PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-12-17","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420187001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420187001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420187001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420187001W","body":"Warning Letter involving GEL OFFSHORE PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2018-12-17 and is reported as closed as of 2018-12-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420187001W_Warning Letter_12172018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420187001W/420187001W_Warning%20Letter_12172018.pdf\n\n420187001W_Warning Letter_12172018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420187001W/420187001W_Warning%20Letter_12172018_text.pdf\n\n420187001W_Warning Letter_12172018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 17, 2018\nJeff Gifford\nVice President, HSSE\nGEL Offshore Pipeline, LLC\n919 Milam Street, Suite 2100\nHouston, Texas 77002\nCPF 4-2018-7001W\nDear Mr. Gifford:\nDuring the month of February 2015, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code inspected your GEL Offshore Pipeline, LLC (GEL) in the Gulf of Mexico. At\nthe time of the inspection, GEL indicated that the offshore services, routine and non-routine\nmaintenance activities, had been contracted to Enterprise Products Operating LLC (Enterprise)\nusing Enterprise procedures under PHMSA OPID # 31618.\nAs a result of the inspection, it appears that GEL has committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolations are:\n1. §195.402 Procedural Manual for Operations, Maintenance, and Emergencies\n(a) General. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies. This manual shall be reviewed\nat intervals not exceeding 15 months, but at least once each calendar year, and\n\n\n\nappropriate changes made as necessary to ensure that the manual is effective. This\nmanual shall be prepared before initial operations of a pipeline system commence,\nand appropriate parts shall be kept at locations where operations and maintenance\nactivities are conducted.\nGEL failed to follow the written Enterprise O&M procedure Section 702 Investigation of Failure\nand Procedure 2.4 of the Enterprise Safety Policies Manual to conduct a post-accident\ninvestigation following an accident occurring May 12, 2014, as required by §195.402(c)(5).\nOn May 12, 2014, GEL reported an accident to the National Response Center (NRC #1082483).\nThe accident took place on the Outer Continental Shelf (OCS), Platform VR-331A, at the splash\nzone on an 8” riser.\nDuring the inspection, PHMSA requested GEL to provide the post-accident review for the May\n12, 2014 accident. GEL was unable to provide the post-accident review.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(a) Which pipelines are covered by this section? This section applies to each hazardous\nliquid pipeline and carbon dioxide pipeline that cold affect a high consequence area,\nincluding any pipeline located in a high consequence area unless the operator\neffectively demonstrates by risk assessment that the pipeline could not affect the area.\n(Appendix C of this part provides guidance on determining if a pipeline could affect a\nhigh consequence area.)\nGEL failed to identify and document the applicability of Pipeline Integrity Management in high\nconsequence areas (HCA) for their offshore pipeline system as defined by §195.452(a) and\nAppendix C.\nAt the time of the inspection, GEL had not completed the identification of all pipeline segments\nsubject to the IMP for the GEL Offshore pipeline (segment 8178, Segment 5854, Segment 4037\nand Segment 4038). Following the inspection, GEL provided documentation to support the\nevaluation of all of their operating segments.\n3. § 195.579 What must I do to mitigate internal corrosion?\n(a) General. If you transport any hazardous liquid or carbon dioxide that would corrode\nthe pipeline, you must investigate the corrosive effect of the hazardous liquid or\ncarbon dioxide on the pipeline and take adequate steps to mitigate internal corrosion.\n2\n\n\n\nGEL failed to investigate the corrosive effect of the hazardous liquid on the pipeline and take\nadequate steps to mitigate internal corrosion. GEL did not provide records to validate an\ninvestigation as required by § 195.589 (c).\nDuring the inspection, PHMSA requested GEL to provide the corrosion control monitoring records\n(2012, 2013, and 2014) to ensure that the offshore pipelines are being monitored for internal\ncorrosion. GEL responded that their pipelines have not had a monitoring system for internal\ncorrosion since 2012 when it was acquired from Marathon Pipeline. GEL stated they do not use\ncorrosion inhibitor or perform periodic product analysis. PHMSA discovered GEL installed two\ncorrosion coupons on February 6, 2015. The coupon installation was on the last day of the PHMSA\ninspection and has provided records to demonstrate the coupons have been inspected since their\ninstallation.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related\nseries of violations. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to\nexceed $2,000,000 for a related series of violations. 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 GEL Offshore Pipeline, LLC being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2018-7001W. 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,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6942}