MAGELLAN PIPELINE COMPANY, LP — Notice of Probable Violation

party submissionOfficial PDF420205012_Operator Hearing Request Withdrawn_02182021.pdf#

party submissionOfficial PDF420205012_Operator Response to Notice and Request for Hearing_11202020.pdf#

420205012_PHC Hearing Scheduled_12182020_text.pdf, page 1Official PDFDecember 18, 2020 VIA ELECTRONIC MAIL TO: mark.materna@magellanlp.com and mary.mcdaniel@dot.gov Mr. Mark Materna Director, Pipeline Integrity Magellan Midstream Partners, LP One Williams Center P.O. Box 22186 Tulsa, Oklahoma 74172 Ms. Mary McDaniel Director, Southwest Region Pipeline and Hazardous Materials Safety Administration 8701 South Gessner, Suite 630 Houston, Texas 77074 Re: Notice of Hearing, Magellan Pipeline Company, LP CPF No. 4-2020-5012 Dear Mr. Materna and Ms. McDaniel: In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the Pipeline and Hazardous Materials Safety Administration in the above-referenced case. The hearing will take place on February 18, 2021, beginning at 8:30 a.m. Central Time. The hearing will be held via videoconference. I will provide the videoconference information prior to the hearing. At least 10 calendar days prior to the hearing (or by February 8, 2021), both parties must submit and exchange any additional written materials they intend to present at the hearing and the name and email address of each attendee. This information should be provided electronically. Materials not submitted by this date may be excluded. If you have any questions, please do not hesitate to contact me. Sincerely, Larry White Presiding Official cc: Mr. Michael Pearson, Senior Vice President, Technical Services, Magellan Pipeline Company, LP, michael.pearson@magellanlp.com Ms. Melanie Lampton, Counsel, Southwest Region, Office of Pipeline Safety, PHMSA, melanie.lampton@dot.gov#

420205012_Final Order_09172021_(18-163702S)_text.pdf, page 1Official PDFSeptember 17, 2021 VIA ELECTRONIC MAIL TO: jason.smith@magellanlp.com Mr. Jason Smith Vice President, Asset Integrity Magellan Pipeline Company, LP One Williams Center, MD 27 Tulsa, Oklahoma 74172 Re: CPF No. 4-2020-5012 Dear Mr. Smith: Enclosed please find the Final Order issued in the above-referenced case. It withdraws one of the allegations of violation, makes a finding of violation, includes two warning items, and finds that Magellan Pipeline Company, LP has completed the actions specified in the Notice to comply with the pipeline safety regulations. Therefore, this case is now 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. Service of the Final Order by e-mail is effective upon the date of transmission 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. Mark Materna, Director, Pipeline Integrity, Magellan Pipeline Company, LP, mark.materna@magellanlp.com Mr. R. Daniel Scroggins, Senior Attorney, Magellan Midstream Partners, LP, danny.scroggins@magellanlp.com CONFIRMATION OF RECEIPT REQUSTED#

420205012_Final Order_09172021_(18-163702S)_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Magellan Pipeline Company, LP, ) CPF No. 4-2020-5012 ) ) ) Respondent. ) ____________________________________) FINAL ORDER From September 20, 2019, through February 14, 2020, pursuant to 49 U.S.C. § 60117, a representative 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 Magellan Pipeline Company, LP’s (Magellan or Respondent) Orion West Pipeline Construction Project at various field locations in Texas and at Magellan headquarters in Tulsa, Oklahoma. The Orion West pipeline has about 430 miles of pipeline that moves refined petroleum products near Corsicana, Texas to Odessa, Texas. This construction project involved an increase in capacity (50,000 additional barrels per day) on the existing Orion West refined products system through replacement of about 140 miles of pipeline segments and upgrade or installation of pumping capacity. As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated September 18, 2020, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Magellan had committed two violations of 49 C.F.R. Part 195, proposed assessing a civil penalty of $50,100 for one of the alleged violations, and proposed ordering Respondent to take certain measures to correct the alleged violations. The Notice also included an additional two warning items pursuant to 49 C.F.R. § 190.205, which required no further action, but warned the operator to correct the probable violations or face possible future enforcement action. After requesting and receiving an extension of time to respond, Magellan responded to the Notice by letter dated November 20, 2020 (Response). Magellan contested all of the allegations and requested a hearing. By e-mail dated February 17, 2021, Respondent withdrew its request for a hearing and thereby authorized the entry of this Final Order without further notice.#

420205012_Final Order_09172021_(18-163702S)_text.pdf, page 3FINDING OF VIOLATION Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.202, which states: § 195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. The Notice alleged that Respondent violated 49 C.F.R. § 195.202 by failing to construct its Orion West pipeline in accordance with comprehensive written specifications or standards consistent with the requirements of Part 195, and also failing to follow its written construction specification when Magellan’s welding inspector was found to be using an incorrect version of the Magellan Specification 100. Specifically, the Notice alleged that Magellan failed to verify and document the welding parameters as required by its specification, and further, that Magellan’s welding inspector was using an incorrect version of the written construction specification. In its Response, Magellan initially contested this allegation of violation and requested a hearing on the issues. Subsequent to its Response, Magellan withdrew its hearing request on this Item and stated that it was no longer contesting the allegation of violation.1 Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R. § 195.202 by failing to verify and document the welding parameters as required by its specification, and failing to ensure that its welding inspector was using the correct version of the written construction specification. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.202, which states: § 195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. The Notice alleged that Respondent violated 49 C.F.R. § 195.202 by failing to construct its Orion West pipeline in accordance with comprehensive written specifications or standards consistent with the requirements of Part 195. Specifically, Magellan failed to install its newly constructed Orion West pipeline in the ditch consistent with the requirements of §§ 195.246 and 195.252. Moreover, Section 6.0 of Magellan’s Specification “Padding, Backfill, and Ditch Breakers, Revision 2, dated 05/20/2015,” requires the installation of a rock shield or use of padding to protect the pipeline from damage in rocky areas. The Notice alleged that on September 19, 2019, at County Road (CR) 209 in Callahan County, Texas, PHMSA observed 1 Magellan hearing request withdrawal e-mail, dated February 17, 2012 (on file with PHMSA).#

420205012_Final Order_09172021_(18-163702S)_text.pdf, page 4that the pipe had been lowered into the ditch in a rocky area with no rock shield or padding. In addition, the rocks in the spoil from trenching had not been segregated from the material to be used for backfilling. In its Response, Magellan asserted that it complied with §§ 195.202, 195.246, and 195.252, and requested that this item be withdrawn along with the associated Proposed Civil Penalty and Proposed Compliance Order. Magellan explained that during the field inspection on September 19, 2019, the PHMSA inspector visited an active pipeline construction site at CR 209. The construction site at CR 209 was observed to have an open construction ditch with new pipe as noted by the inspector and was not yet backfilled. According to Magellan, the pipeline construction was installed via road bore and tied into a section of lowered in pipe with proper ditch padding and rock shield installed. The pipe without rock shield was coated in Abrasion Resistant Overcoating, which was presented as evidence of the road bore installation method. Magellan explained that there is no practical method to effectively install a pipeline via road bore with rock shield installed, nor is it required by Magellan's procedure due to the installation method. The "Padding, Backfill, and Ditch Breaker'' specification also states, "Immediately before padding and backfilling, ditch and backfill material shall be inspected and rocks, large clods, stumps, skids, trash and other foreign material shall be removed." Magellan applied rock shield to the road bore piping and inspected the backfill material prior to backfilling the open excavation at CR 209. Based upon daily reports and photos from the construction project, Magellan claimed it had supporting evidence that the pipeline constructed in this area was installed per Magellan's Specification "Padding, Backfill, and Ditch Breaker." Therefore, Magellan argued that the location identified by the PHMSA inspector was properly protected with rock shield and spoils were inspected prior to backfilling the construction site at CR 209. Magellan provided supportive photographic evidence showing the pipeline segment at issue with rock shield installed prior to backfilling the open excavation in a PDF format in its Response, as well as JPEG format on February 9, 2021. In the Regional Director’s written evaluation of the response material submitted by Respondent, they recommended Item 3 be withdrawn. Accordingly, after considering all of the evidence, I find that Magellan did not violate the regulation as alleged in the Notice. Although photographic records were not available at the time of the inspection, Magellan did provide documentary evidence of compliance on February 9, 2021. Based upon the foregoing, I hereby order that Item 3 of the Notice be withdrawn. 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.2 2 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.#

420205012_Final Order_09172021_(18-163702S)_text.pdf, page 5In 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; the good faith of Respondent in attempting to comply with the pipeline safety regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA. 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 $50,100 for Item 3 cited above. Item 3: The Notice proposed a civil penalty of $50,100 for Respondent’s alleged violation of 49 C.F.R. § 195.202. Since this alleged violation has been withdrawn, the proposed penalty is not assessed. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 1 and 3 in the Notice for violations of 49 C.F.R. § 195.202. 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. The Director indicates that Respondent has taken the following actions specified in the proposed compliance order: 1. With respect to the violation of § 195.202 (Item 1), Respondent has completed the corrective actions proposed in the Notice. Specifically, Magellan provided records showing that welding parameters had been recorded for the welding activities at the De Leon pump station. 2. With respect to the violation of § 195.202 (Item 3), this Item is withdrawn along with the proposed compliance order actions. Accordingly, I find that compliance has been achieved. Therefore, the compliance terms proposed in the Notice are not included in this Order. WARNING ITEMS With respect to Items 2 and 4, the Notice alleged probable violations of Part 195, but identified them as warning items pursuant to § 190.205. The warnings were for: 49 C.F.R. § 195.202 (Item 2) ─ Respondent’s alleged failure to construct its Orion West pipeline in accordance with comprehensive written specifications or standards consistent with the requirements of Part 195. Specifically, the Notice alleged that Magellan failed to follow its written specification for hydrostatic testing to require the review and approval of hydrostatic test documentation by the#

420205012_Final Order_09172021_(18-163702S)_text.pdf, page 6Project Engineer, Test Supervisor, and Test Inspector. Section 3.9.4.5 of Magellan Specification 7.07-ADM-001 – Pressure Testing Specification, Revision 4 dated 11/02/2016, requires the Hydrostatic Test Form 07-FORM-0013 be completed and signed by the specified project personnel. After PHMSA communicated this inspection finding to Magellan, the Operator subsequently signed the forms and provided copies to PHMSA via e-mail; and 49 C.F.R. § 195.228 (Item 4) ─ Respondent’s alleged failure to perform visual inspections of production welds. On January 8, 2020, at the De Leon pump station, the PHMSA inspector observed that several welds were completed without the welding inspector performing visual inspections. Additionally, at the time of the inspection, the welding inspector was unable to provide records showing that visual inspections had been performed on previously completed welds. Magellan requested withdrawal of Item 2 because it stated that its procedure 7.03-ADM-001 - Pressure Testing requires the Project Manager, under section 3.10.4.5, to complete and sign the hydrostatic test section documentation, but intentionally does not require a time frame regarding the signing of Page 4 by the Project Manager. According to Magellan, at the time of the hydrostatic testing, the Project Manager provided written acceptance and approval of the test over e-mail but had yet to sign the Page 4 hydrostatic test form. A copy of the e-mail approval and signed Page 4 documentation were provided to the PHMSA inspector in accordance with the requirement in 7.03-ADM-001 during the inspection. Magellan requested withdrawal of Item 4 because it had previously submitted documentation to PHMSA that visual inspection as well as non-destructive testing were performed on each weld on the day in question. Under § 190.205, PHMSA does not adjudicate warning items to determine whether a probable violation occurred. If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. September 17, 2021 ___________________________________ _________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420205012_NOPV PCP PCO_09182020_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER ELECTRONIC MAIL - RETURN RECEIPT REQUESTED September 18, 2020 Michael Pearson Senior Vice President, Technical Services Magellan Pipeline Company, LP One William Center, OTC-9 P.O. Box 22186 Tulsa, Oklahoma 74172 CPF 4-2020-5012 Dear Mr. Pearson: From September 20, 2019 through February 14, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Magellan Pipeline Company, LP’s (Magellan) Orion West Pipeline Construction project at various field locations in Texas and records at your headquarters in Tulsa, Oklahoma. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are: 1. §195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. Magellan failed to construct its Orion West pipeline in accordance with comprehensive written specifications or standards consistent with the requirements of Part 195. First, Magellan failed to follow its written construction specification for welding on its pipeline. Section 8.7.1.7.1 of Magellan Specification 100 – Construction and Fabrication of Pipelines and Related Piping Systems, Revision 13 dated 03/08/2019, states “At a minimum, but no less than once per day volts, amps, heat input, travel speed, etc. shall be monitored on welders randomly and documented to ensure welding is performed within#

420205012_NOPV PCP PCO_09182020_text.pdf, page 22. 2 the parameters of the welding procedure.” The procedure further requires that the actual observed welding parameters be recorded on Magellan Welding Report 07-FORM-0722. Magellan did not record the actual parameters used to weld the Orion West pipeline in accordance with its written procedures. On January 8, 2020, while onsite, the PHMSA inspector requested Magellan’s record documenting the measured welding parameters as required by Specification 100. The welding inspector was unable to provide the record of this information for January 8, 2020, (or any of the previous days of the same week). The information provided by the welding inspector did not show that the welding parameters had been documented once per day nor had the information been recorded on 07-FORM-0722, as required by the Operators written specification. Second, Magellan also failed to follow its written construction specification when Magellan’s Welding inspector was found to be using an incorrect version of the Magellan Specification 100. The version of the procedure that was current at the time of the PHMSA inspection was WE-ADM-003, Revision 13, dated 03/08/2019. When asked for the version being used, the Magellan welding inspector provided the PHMSA inspector WE-ADM- 003, Revision 5, dated 03/09/2011. Not only did Magellan fail to verify and document the welding parameters as required by their specification, its welding inspector was not using the correct version of the written construction specification. §195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. Magellan failed to construct its Orion West pipeline in accordance with comprehensive written specifications or standards consistent with the requirements of Part 195. Specifically, Magellan failed to follow its written specification for hydrostatic testing to require the review and approval of hydrostatic test documentation by the Project Engineer, Test Supervisor, and Test Inspector. Section 3.9.4.5 of Magellan Specification 7.07 - ADM-001 – Pressure Testing Specification, Revision 4 dated 11/02/2016, requires the Hydrostatic Test Form 07-FORM-0013 be completed and signed by the specified project personnel. During the inspection week of February 10, 2020, PHMSA identified that page 4 of the Hydrostatic Test forms (07-FORM-0013) was not signed by the Magellan Project Manager for the pressure test records for all three construction spreads of the Orion West expansion project. After PHMSA communicated this inspection finding to Magellan, the Operator subsequently signed the forms and provided copies to PHMSA via email.#

420205012_NOPV PCP PCO_09182020_text.pdf, page 33. 4. 3 §195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. §195.246 Installation of pipe in a ditch. (a) All pipe installed in a ditch must be installed in a manner that minimized the introduction of secondary stresses and the possibility of damage to the pipe §195.252 Backfilling. When a ditch for a pipeline is backfilled, it must be backfilled in a manner that: (a) Provides firm support under the pipe; and (b) Prevents damage to the pipe and pipe coating from equipment or from the backfill material. Magellan failed to construct its Orion West pipeline in accordance with comprehensive written specifications or standards consistent with the requirements of Part 195. Specifically, Magellan failed to install its newly constructed Orion West pipeline in the ditch consistent with the requirements of §195.246 and §195.252. Moreover, Section 6.0 of Magellan’s Specification ‘Padding, Backfill, and Ditch Breakers, Revision 2, dated 05/20/2015,’ written specification requires the installation of rock shield or the use of padding to protect the pipeline from damage in rocky areas. On September 19, 2019, at the CR 209 in Callahan County, Texas, PHMSA observed that the pipe had been lowered into the ditch in a rocky area with no rock shield or padding. In addition, the rocks in the spoil from trenching had not been segregated from the material to be used for backfilling. Magellan failed to follow its written procedure to ensure construction of its pipeline in accordance with the specifications or standards related to installation of pipe in the ditch along with the proper backfilling. §195.228 Welds and welding inspection: Standards of acceptability. (a) Each weld and welding must be inspected to insure compliance with the requirements of this subpart. Visual inspection must be supplemented by nondestructive testing. Magellan’s welding inspector failed to perform visual inspections of production welds as required by §195.228(a). On January 8, 2020, at the De Leon pump station, PHMSA observed that several welds were completed without the welding inspector performing any visual inspections. Additionally, at the time of the inspection, the welding inspector was unable to provide records showing that visual inspections had been performed on previously completed welds.#

420205012_NOPV PCP PCO_09182020_text.pdf, page 44 Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. 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. We have reviewed the circumstances and supporting documentation involved for the above probable violations and recommend that you be preliminarily assessed a civil penalty of $50,100 as follows: Item number PENALTY 3 $50,100 Warning Items With respect to items 2 and 4, 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. Proposed Compliance Order With respect to items 1 and 3 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Magellan Pipeline Company, L.P. 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 Enforcement Proceedings. Please refer to this document and note the response options. All material you 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). Following the receipt of this Notice, you have 30 days to submit written comments, or request a hearing under 49 CFR § 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#

420205012_NOPV PCP PCO_09182020_text.pdf, page 55 Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. This period may be extended by written request for good cause. In your correspondence on this matter, please refer to CPF 4-2020-5012 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 Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings#

420205012_NOPV PCP PCO_09182020_text.pdf, page 66 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Magellan Pipeline Company, L.P. a Compliance Order incorporating the following remedial requirements to ensure the compliance of Magellan Pipeline Company, L.P. with the pipeline safety regulations: 1. In regard to Item Number 1 of the Notice pertaining to failure to follow its written specification to record the welding parameters, Magellan Pipeline Company, L.P. must show that the welding inspectors recorded the welding parameters for all welding activities at the De Leon pump station during the Orion West Expansion project. 2. In regard to Item Number 3 of the Notice pertaining to installation of pipe in a rocky ditch without padding or rock shield, Magellan Pipeline Company, L.P. must perform a coating survey (ACVG - Alternating Current Voltage Gradient Survey or DCVG - Direct Current Voltage Gradient Survey) to locate any holidays and evaluate the coating conditions of the buried pipeline. 3. For Item 1, Magellan must submit to the Director within thirty (30) days of receipt f the Final Order documentation that the review documents were completed and that the required information was recorded. If Magellan is unable to meet the above-mentioned requirement, then Magellan must submit a proposed alternative to the Director to verify the strength and mechanical properties of the welds. 4. For Item 2, the coating survey must be performed within ninety (90) days of receipt of the Final Order. Results of the survey must be provided to the Director within thirty (30) days of completion, and if any coating issues are detected, Magellan must submit a Repair Plan to the Director for review and approval within thirty (30) days of confirming coating damage. Coating repairs must be completed within 180 days of approval of the Repair Plan. 5. It is requested (not mandated) that Magellan Pipeline Company, L.P. maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Mary L. McDaniel, 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.#