# GOLDEN TRIANGLE STORAGE, INC. — Notice of Amendment

- **operation:** document
- **citation:** CPF 420191011M
- **title:** GOLDEN TRIANGLE STORAGE, INC. — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-11-21
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.465(d).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420191011m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420191011m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420191011m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420191011M
**body:**

Notice of Amendment involving GOLDEN TRIANGLE STORAGE, INC.. PHMSA's enforcement data identifies the cited regulation as 192.465(d). The case was opened on 2019-11-21 and is reported as closed as of 2020-01-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420191011M_Closure Letter_01152020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191011M/420191011M_Closure%20Letter_01152020.pdf

420191011M_Closure Letter_01152020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191011M/420191011M_Closure%20Letter_01152020_text.pdf

420191011M_Notice of Amendment_11212019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191011M/420191011M_Notice%20of%20Amendment_11212019.pdf

420191011M_Notice of Amendment_11212019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191011M/420191011M_Notice%20of%20Amendment_11212019_text.pdf

420191011M_Operator Response to Notice_12162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191011M/420191011M_Operator%20Response%20to%20Notice_12162019.pdf

420191011M_Closure Letter_01152020_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 15, 2020
Kimberly S. Greene
Chairman and CEO
Southern Gas Company
10 Peachtree Place
Atlanta, Georgia 30309
CPF 4-2019-1011M
Dear Ms. Greene:
On January 7, 2019 through June 22, 2019, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.) inspected the facilities of your subsidiary, Golden Triangle
Storage Inc., in Orange, Texas. As a result of the inspection, Golden Triangle Storage Inc. (GTS)
was issued a Notice of Amendment on November 22, 2019.
GTS submitted its amended procedures on December 16, 2019. My staff reviewed the amended
procedures and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Mary. L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

420191011M_Notice of Amendment_11212019_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 21, 2019
Kimberly S. Greene
Chairman and CEO
Southern Company Gas
10 Peachtree Place
Atlanta, Georgia 30309
CPF 4-2019-1011M
Dear Ms. Greene:
On January 7, 2019 through June 22, 2019, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.) inspected the facilities of your subsidiary, Golden Triangle
Storage Inc., in Orange, Texas.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within
Golden Triangle Storage’s plans or procedures, as described below:
1. §192.465 External corrosion control: Monitoring.
(d) Each operator shall take prompt remedial action to correct any deficiencies
indicated by the monitoring.



Golden Triangle Storage, Inc.’s procedure for corrosion control monitoring are inadequate and
require revision. Section 8.24 of the written Corrosion Control Monitoring procedures (within the
Operations and Maintenance Manual and Sections 8.2.1 (a) and 8.2.1 (f) of the Division 11
Manual) do not stipulate a timeline or timeframe for completing remediation after it has been
identified in order to maintain the pipeline integrity. §192.465(d) requires “prompt” remedial
action inorder to ensure that the integrity of the pipeline is not compromised in anyway and that
Corrosion Control Monitoring can be completed at the required frequencies. Golden Triangle
should revise its procedures to define prompt as it relates to all corrosion control remediation
activities required within its procedures.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. 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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
2



It is requested (not mandated) that Golden Triangle Storage, Inc. maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, P.E.,
Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In
correspondence concerning this matter, please refer to CPF 4-2019-1011M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Mary L. McDaniel P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
3
- **truncated:** false
- **body characters:** 6443
