# MAGELLAN PIPELINE COMPANY, LP — Warning Letter

- **operation:** document
- **citation:** CPF 520145019W
- **title:** MAGELLAN PIPELINE COMPANY, LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-12-09
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.430, 195.571.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145019w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520145019W
**body:**

Warning Letter involving MAGELLAN PIPELINE COMPANY, LP. PHMSA's enforcement data identifies the cited regulations as 195.430,  195.571. The case was opened on 2014-12-09 and is reported as closed as of 2014-12-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520145019W_warning letter_12092014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145019W/520145019W_warning%20letter_12092014.pdf

520145019W_warning letter_12092014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145019W/520145019W_warning%20letter_12092014_text.pdf

520145019W_warning letter_12092014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 9, 2014
Mr. Larry Davied
Vice President Technical Services
Magellan Pipeline Company, LP
One Williams Center
P.O. Box 22186, Mail Drop 27
Tulsa, Oklahoma 74172
CPF 5-2014-5019W
Dear Mr. Davied:
Between September 9 through September 11, 2014 and September 22 through September 25,
2014, a representative of the Pipeline and Hazardous Materials Safety Administration
(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Magellan’s Refined
Products system in Colorado, South Dakota, and Wyoming.
As a result of the inspection, 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. §195.430 Firefighting equipment.
Each operator shall maintain adequate firefighting equipment at each pump
station and breakout tank area. The equipment must be-
(a) In proper operating condition at all times;
(b) Plainly marked so that its identity as firefighting equipment is clear; and,
(c) Located so that it is easily accessible during a fire



During the field inspection of your facilities, it was noted that the firefighting equipment was
not readily available in the breakout tank area at the DuPont Terminal. Interviews with
Magellan personnel revealed that each operation technician’s vehicle has a fire extinguisher.
Per §195.430, each operator shall maintain adequate firefighting equipment at each pump
station and breakout tank area. Since the time of inspection, Magellan has installed six (6)
new fire extinguishers in the breakout tank area at the DuPont Terminal.
2. §195.571 What criteria must I use to determine the adequacy of cathodic
protection?
Cathodic protection required by this Subpart must comply with one or more of
the applicable criteria and other considerations for cathodic protection contained
in paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference, see §
195.3).
During the review of Magellan’s cathodic protection corrosion control reports, it was noted
that the corrosion protection measurement of several test leads were less negative than the
required -850 mV needed to ensure adequate cathodic protection of the pipelines. Magellan’s
Corrosion Control procedure, 7.04-ADM-001, Revision 14, Section 2.3.2 from Corrosion
Control Criteria 195.571, states, “when practical, Magellan requires maintaining a polarized
potential of at least 0.850 volts as measured between the structure and a saturated copper-
copper sulfate reference electrode that is in contact with the electrolyte (earth, soil, water,
etc…)”, and Section 2.3.4 states, “when a -0.850 volt potential is not practical, the following
criteria is acceptable when approved by the Supervisor of Corrosion Control: a minimum
negative (cathodic) polarization shift of 100 mV”. Magellan acquired the assets from Plains
as of November 15, 2013, and remedial actions to bring cathodic protection levels to
minimum required levels are still not fully implemented.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a related series of violations. 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 correct
the item(s) identified in this letter. Failure to do so will result in Magellan Pipeline Company,
LP being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2014-5019W. 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
2



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).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 K. Nguyen
Item 1 Activity #146198
Item 2 Activity #146197 and Activity #146198
3
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