# SEA ROBIN PIPELINE CO — Notice of Probable Violation

**Citation:** CPF 420112001  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2011-03-21

CLOSED notice of probable violation citing 192.605(a), 192.807(b).

## Document text

Notice of Probable Violation involving SEA ROBIN PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.807(b). The case was opened on 2011-03-21 and is reported as closed as of 2012-02-15. Proposed civil penalty: $19,000. Assessed civil penalty: $10,300. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420112001_Closure Letter_02152012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420112001/420112001_Closure%20Letter_02152012.pdf

420112001_Closure Letter_02152012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420112001/420112001_Closure%20Letter_02152012_text.pdf

420112001_Final Order_12292011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420112001/420112001_Final%20Order_12292011.pdf

420112001_Final Order_1229201_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420112001/420112001_Final%20Order_1229201_text.pdf

420112001_NOPV PCP PCO_03212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420112001/420112001_NOPV%20PCP%20PCO_03212011.pdf

420112001_NOPV PCP PCO_03212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420112001/420112001_NOPV%20PCP%20PCO_03212011_text.pdf

420112001_NOPV PCP PCO_03212011_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 21, 2011
Mr. Eric Amundsen
Vice President of Technical Services
Sea Robin Pipeline Company
5444 Westheimer Road
Houston, TX 77056-5306
CPF 4-2011-2001
Dear Mr. Amundsen:
During September and December 2010, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
offshore natural gas transmission pipeline system, Unit ID 1874 – Sea Robin Transmission in Erath,
LA.
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
violation(s) 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 operations 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 one 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.



Sea Robin personnel failed to follow the established procedures when performing covered
task PLOQ713A ‘Commission and Maintain Stationary Gas Detection Systems’. During the
inspection, PHMSA asked Sea Robin to perform this covered task as part of the inspection
process.
Sea Robin uses Panhandle Energy’s Standard Operating Procedures (SOP) and specifically
in this instance Sea Robin utilized SOP H.18 ‘Stationary Gas and Fire Detection Systems’.
Section 7.4 ‘Testing and Inspection of Gas Sensors’, step 3 states:
“CALIBRATE every sensor and TEST each controller using a 50% Lower Explosive
Limit (LEL) methane calibration gas source. VERIFY the following action:
• Low alarm trip point - not more that 25% LEL
• High alarm trip point - not more than 50% LEL
• 0% (zero) with the LEL meter in free air
At the Erath Compressor Station they use an additional site specific procedure, ‘Calibrate
Gas Detectors’. In the procedure, steps 7.2 through 7.9 detail the process used to calibrate
a gas detection sensor. These steps are repeated to calibrate each gas detection sensor.
Step 7.12 is for testing each gas detection sensor. Step 7.12 states:
“Verify an LEL gas warning (GAS.WARN) at 20% LEL and LEL gas alarm
(GAS.ALARM) at 40% LEL by noting the following in the control room.”
7.12.1 The Horn sounds
7.12.2 An indication is seen on the Network Monitor
7.12.3 An alarm printout occurs on the Network Printer
7.12.4 The red alarm light is illuminated on the Sensor Controller Card.
During the performance of covered task PLOQ713A, Sea Robin personnel performed the
calibration steps, 7.2 through 7.9 for the gas detection sensor located over Compressor 1-
Unit #2. The personnel failed to perform step 7.12 to verify that the gas detector low alarm
trip and high alarm trip were functioning properly. In response to PHMSA inquiry as to why
not all parts of the task were completed PHMSA inspectors were told that the complete
testing could not be performed because it would cause a station shut down. PHMSA
identified in the site specific procedure, ‘Calibrate Gas Detectors’ a note which states
“Placing the Station safety systems in bypass mode will prevent a unit shutdown for the Gas
Detection Warning Alarm signal (GAS.ALARM) caused by the testing procedure”.
Sea Robin Personnel did not follow the actions required in their SOP and site specific
procedures.
2



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 operations 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 one 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.
Sea Robin personnel failed to follow their procedures for Conducting Atmospheric Corrosion
Inspection. Sea Robin failed to provide protection against atmospheric corrosion as required
by this procedure.
Sea Robin uses Panhandle Energy’s Standard Operating Procedures (SOP) specifically Sea
Robin utilized SOP D.44 “Atmospheric Corrosion Inspection.” Section 7.4 Reporting states
results of the inspection are to be documented:
1. Document metal loss evaluations in the Pipe inspection Database
2. Document coating evaluations and recommended actions in the Corrosion Database
3. Document remedial action plan using Form 7T-60 Remedial Action report.
PHMSA reviewed paperwork and noted the following:
South Marsh 33 platform. Panhandle Energy “CD_Atm_V_SMI_06 Atmospheric Report” [J-
SMI 33] blow down notes:
5/28/08 moderate corrosion in flange area
7/17/09 a case 6 having blisters at supports and 1in blowdown has several defects at
tank.
6/15/10 case 6 one inch cmv piping
East Cameron 195 platform. Panhandle Energy “CD_Atm_EC-WC_06 Atmospheric Report”
[J-EC195] Riser 707 notes:
8/15/09 Riser is a Case 6 with corrosion at supports and scale along riser
8/9/10 Case 6, recoat riser
East Cameron 195 platform. Panhandle Energy “CD_Atm_EC-WC_06 Atmospheric Report”
[J-EC195] Riser 701 notes:
8/15/09 Riser is a Case 6 with corrosion at supports
8/9/10 Case 6, recoat riser
Appendix B of this SOP identifies the various classification of coating Inspection. Case 6
coating classification is described as:
“Degradation of topcoat, but majority of primer and/or intermediate coat intact.
Indications of pitting. Economic analysis indicates maintenance coating is cost
effective.
”
The action required for a Case 6 classification is: “Coating rehabilitation required. Remove
and replace existing coating system in areas where coating degradation is severe. Apply
maintenance coating over intact portions of existing coating.”
3



During the inspection, observations were made of the piping and components at the
locations above. Each location displayed areas of deteriorated coating and extensive
corrosion. Sea Robin personnel did not follow the actions required in their SOP.
3. 192.807 Recordkeeping.
(b) Records supporting an individual’s current qualification shall be maintained while
the individual is performing the covered task. Records of prior qualification and
records of individuals no longer performing covered tasks shall be retained for a
period of five years.
Sea Robin failed to maintain current qualification records supporting the qualification of
‘Contractor, OQ’ for the maintenance of mainline valves 700-44, 700-46, and 700-48.
PHMSA reviewed the valve maintenance records. Task 7T0032E – Annual Valve
Maintenance and Trouble Report (Emergency Valves) is designated as an OQ task. Work
Order No: 169209, Assembly No: 94039, Amarada Hess Plant, indicates that the annual
maintenance task for valves 700-44, 700-46, and 700-48 was partially done by “Contractor,
OQ” on May 22, 2010. Sea Robin personnel stated they did not have the individual’s name
or OQ records.
Sea Robin must maintain qualification records for individuals that perform or have performed
covered tasks on the pipeline system.
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for
each violation for each day the violation persists up to a maximum of $1,000,000 for any 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 $19,000 as follows:
Item number PENALTY
2 $10,300
3 $ 8,700
Proposed Compliance Order
With respect to items 1 and 2 pursuant to 49 United States Code § 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Sea Robin
Pipeline Company. 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. 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 treatment4



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 4-2011-2001 and for each document you
submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
5



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Sea Robin Pipeline Company a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Sea Robin Pipeline
Company with the pipeline safety regulations:
1. In regard to Item Number 1 of the Notice pertaining to the failure to follow the
established procedures when performing covered task PLOQ713A ‘Commission and
Maintain Stationary Gas Detection Systems,
’ Sea Robin should review their
procedures and retrain and qualify those individuals responsible for the testing and
maintenance of the Stationary Gas Detection Systems to ensure the procedures will
be followed.
2. In regard to Item Number 2 of the Notice pertaining to the failure to follow SOP D.44
“Atmospheric Corrosion Inspection,” Sea Robin must remediate the areas noted.
3. Aforementioned to be accomplished within 30 days following receipt of the Final
Order.
4. It is requested (not mandated) that Sea Robin Pipeline Company maintain
documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to R. M. Seeley, 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.
6

420112001_Closure Letter_02152012_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 15, 2012
Mr. Eric Amundsen
Vice President and Chief Asset Integrity Officer
Sea Robin Pipeline Company
5444 Westheimer Road
Houston, TX 77056-5306
CPF 4-2011-2001
Dear Mr. Amundsen:
On December 29, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Sea Robin Pipeline Company 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,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials
Safety Administration

420112001_Final Order_12292011.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
DEC 2 9 2011
Mr. Eric Amundsen
Vice President of Technical Services
Sea Robin Pipeline Company
5444 Westheimer Road
Houston, TX 77056-5306
Re: CPF No. 4-2011-2001
Dear Mr. Amundsen:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $10,300, and specifies actions that need to be taken by Sea
Robin Pipeline Company to comply with the pipeline safety regulations. The penalty payment
terms are set forth in the Final Order. When the civil penalty has been paid and the terms of
the compliance order completed, as determined by the Director, Southwest Region, this
enforcement action will be closed. Service of the Final Order by certified mail is deemed
effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
~~~
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. R.M. Seeley, Director, Southwest Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Stephen M. Moore, Counsel, Sea Robin Pipeline Company, LLC.
CERTIFIED MAIL~ RETURN RECEIPT REQUESTED [717910001642030577991



U.S. DEPARTl\1ENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of
Sea Robin Pipeline Company,
)
)
)
)
)
Respondent.
) ___________________________)
CPF No. 4-2011-2001
FINAL ORDER
In September and December 2010, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted on-site pipeline safety inspections of the facilities and records of Sea Robin
Pipeline Company (Sea Robin or Respondent) in Erath, Louisiana. Sea Robin operates 377.2
miles of pipeline, 2 compressor stations, and 5 offshore platforms.
As a result of these inspections, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated March 21,2011, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.P.R.§ 190.207, the
Notice proposed finding that Sea Robin committed violations of 49 C.P.R. Part 192 and
assessing a civil penalty of $19,000 for the alleged violations. The Notice also proposed
ordering Respondent to take certain measures to correct the alleged violations.
Sea Robin responded to the Notice by letter dated April 22, 2011 (Response), contesting two of
the allegations and requesting a hearing. An informal hearing was held on August 23, 2011, in
Houston, Texas with an attorney from the Office of Chief Counsel, PHMSA, presiding. At the
hearing, Sea Robin was represented by counsel. After the hearing, Respondent provided a
transcript of the proceeding, a Post-Hearing Statement (Brief), and additional exhibits for the
record, by letter dated September 23, 2011. 1
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.605, which states in
relevant part:
1 Some documents were forwarded electronically.



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 operations 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.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its
manual of written procedures for conducting operations and maintenance activities and for
emergency response. Specifically, the Notice alleged that a PHMSA inspector requested that
Sea Robin personnel perform a covered task, "Commission and Maintain Stationary Gas
Detection Systems," as part of the inspection process. Sea Robin personnel failed to verify that
the gas detector low and high alarm trips were properly functioning. When questioned, company
personnel mistakenly stated that performance of Step 3 of this covered task would result in a
station shut down. 2 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. § 192.605(a) by failing to follow its manual of written procedures when performing
maintenance of the gas detection system.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.605, which states in
relevant part:
§ 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 operations 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.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its
Standard Operating Procedures (SOP) for addressing atmospheric corrosion on certain offshore
platforms. SOP D.44 "Atmospheric Corrosion Inspection," Section 7.4 Reporting requires
documentation of corrosion and its Appendix B classifies and provides the action item for each
2 A subsequent review of the maintenance records showed this is not the case ... " Pipeline Safety Violation Report
(Violation Report), (March 22, 20 II) (on file with PHMSA) at 3-4.



3
instance of noted corrosion. From 2008 through 2010, OPS asserted that Sea Robin personnel
repeatedly noted "Case 6 classifications" of corrosion on the South Marsh 33 and East Cameron
195 platforms. According to Appendix B, coating rehabilitation is required for Case 6
classifications. OPS argued in the Notice that Sea Robin failed to follow its SOP, which requires
remediation of Case 6 classifications prior to the next inspection cycle.
At the hearing, the Respondent presented evidence that it followed its SOP for addressing
atmospheric corrosion on the offshore platforms cited in the Notice. Sea Robin argued that
neither its operating procedures nor any regulation require remediation of corrosion on offshore
platforms prior to the next scheduled inspection. According to the Respondent, while Sea Robin
assigned a level63 to the instances of corrosion cited in the Notice, such corrosion is not
indicative of an integrity threat to the pipeline and therefore remediation was properly scheduled,
per its SOP. The Respondent also argued that corrosion is a constant concern, given the
geographic location and attendant weather conditions of offshore platforms in this area. Sea
Robin reasoned that, given these circumstances, some corrosion is expected and not necessarily
indicative of an integrity threat requiring repair according to a specific timetable. Since it
adhered to the required yearly inspection intervals and determined that no immediate repair
condition was presented, the Respondent argued that it acted in accordance with its SOP and
therefore did not violate either its procedures or § 192.605( a).
Sea Robin uses Panhandle Energy's SOP Volume D - Corrosion (SOP), which provides the
procedure for an "Atmospheric Corrosion Inspection." Several parts of this procedure are
instructive and reproduced below.
Section 7.3 "Evaluation of Inspection Results" states, in relevant part:
Step Activity
1 RANK coating condition as follows.
• Good (0-5% ): Coating intact with no visible deterioration or damage
• Fair (6-20%): Coating essentially intact, but with some visible deterioration
• Poor (21-99% ): Extensive visible deterioration of coating
• Bare (100%): No coating present.
2 DETERMINE whether the service life of the existing coating system can be extended through
spot repair or maintenance painting.
3 DEVELOP recommendations for coating rehabilitation using the guidelines listed in Appendix B
Classification of Coating Inspections.
4 DETERMINE whether the existing coating system will provide adequate protection to limit
corrosion activity to a uniform light surface oxide before the next Compliance Inspection.
NOTE:
1. 2. With the exception of soil/air interfaces and offshore risers, the presence of uniform light surface
oxides should not affect the safe operation of the pipeline system.
Any corrosion found on an offshore riser or at a soil/air interface requires remedial action.
3 Panhandle Standard Operating Procedure (SOP), Appendix B, "Classification of Coating Inspection" rates
corrosion from Case l (least) to Case 7 (most).



4
A d' B Cl 'f t' fC I oatmg nspectmn
lppen IX aSSl lCa lOll 0
CASE DESCRIPTION ACTION
Case 1 Coating system intact ... No action required.
Case4 Degradation of topcoat, but majority of primer and/or No action required. Existing coating
intermediate coat intact. No indications of pitting. system must be removed prior to
Economic analysis indicates maintenance coating is not recoating.
cost effective. Experience in Area indicates that
remaining coating and/or surface oxide will prevent
pitting until next inspection period.
Case 6 Degradation of topcoat, but majority of primer and/or Coating rehabilitation required.
immediate coat intact. Indication of pitting. Economic Remove and replace existing coating
analysis indicates maintenance coating is cost effective. system in areas where coating
degradation is severe. Apply
maintenance coating over intact
portions of existing coating.
Sea Robin argues that its atmospheric corrosion procedures provide the company with the
flexibility to defer a Case 6 classification until an integrity threat to the pipeline is identified or
the corrosion is such that the company is not adequately maintaining the pipeline.4
However, the plain language of this SOP, read in its entirety, indicates otherwise. Section 7.3,
Step 4, specifically directs the inspector to determine whether the coating system will provide
sufficient protection until the next inspection cycle. Furthermore, Appendix B provides a
straightforward classification system that progresses from Case 1 to Case 7. For Case 1 through
Case 4 scenarios, "No action [is] required." In the description of Case 4, where no action is
required, the inspector is required to find that the "remaining coating and/or surface oxide will
prevent pitting until [the] next inspection period." In other words, for situations that are
classified as Case 1 - 4, the inspector must find the coating either "will perform adequately until
[the] next inspection period [or] will prevent pitting until [the] next inspection period. "5
Notably, Case 6 is absent of any such contemplation of the next inspection period. I find that
this is because "Appendix B: Classification of Coating Inspection," read in conjunction with
SOP "VolumeD- Corrosion- Atmospheric Corrosion Inspection" requires that rehabilitation be
addressed prior to the next inspection period.
Given Sea Robin's position that its SOP does not require remediation prior to the next inspection
cycle, the Respondent also questioned in its post-hearing submission if any "authority [exists] for
the position ... that the remediation at issue in Item 2 was required to be completed within an
inspection interval." In a prior case, Panhandle, whose SOP is used by Sea Robin and is at issue
in this case, acknowledged that remediation of noted action items should occur before the next
4 "HEARING OFFICER: So is it your position that you could- Say we have the same situation. You say that it's a
Case 6. As long- in your view, as long as you monitor the situation to the extent that you're sure that the integrity
of the system has not been called into question, you could delay [these] remedial action as far into the future as you
deem appropriate? MR. RAU: And I hear where you're going and I would say that ... there's another requirement
in the code that says we must maintain the coating system ... So I think the issue is: Is more than a year appropriate
or not? ... We disagree with that. We think that a year or less is not appropriate."
5 SOP, Appendix B.



5
inspection cycle. In an August 6, 20086 letter, Panhandle Energy readily admitted that "PHMSA
has issued guidance on maximum intervals for corrosion control system remediation. That
guidance states that remediation should be initiated prior to the next inspection period." 7 The
next inspection period is, and has always been, the target for the remediation of issues noted
during a previous inspection.
Accordingly, after considering all of the evidence, I find that Respondent violated
49 C.F.R. § 192.605(a) by failing to remediate corrosion, according to its SOP.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.807, which states in
relevant part:
§ 192.807 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with
this subpart.
(a) ...
(b) Records supporting an individual's current qualification shall be
maintained while the individual is performing the covered task.
Records of prior qualification and records of individuals no longer
performing covered tasks shall be retained for a period of five
years.
The Notice alleged that Respondent violated 49 C.F.R. § 192.807(b) by failing to maintain
current qualification records for covered task 7T0032E- Annual Valve Maintenance and
Trouble Report (Emergency Valves). During the inspection, Sea Robin could not produce the
OQ records for "Contractor OQ," who partially performed the annual maintenance task for three
valves on May 22, 2010.
At the hearing, the Respondent stated that a Sea Robin employee, Ronald Eversberg, performed
maintenance of the mainline valves cited in the Notice for failure to maintain OQ records for an
individual performing a covered task. PHMSA asserted that Sea Robin's maintenance records
indicated that the annual maintenance task for certain valves was partially completed by
"Contractor OQ."
6 In the Matter of Panhandle Eastern Pipeline Co. (Panhandle Pipeline), CPF 3-2008-1002, (Jun. 17, 20 11)
(available at www.phmsa.dot.gov/pipeline/enforcement).
7 While not dispositive of the issue presented in this case, a number of final orders reaffirm that remediation should
occur prior to the beginning of the next inspection cycle. "Adverse conditions should be corrected as soon as
possible, and no later than the next inspection cycle." In the Matter of Cenex, Inc. ( Cenex), C.P.F. No. 5-1998-4514
(Oct. 20, 1998) (available at www.phmsa.dot.gov/pipeline/enforcement). "The failure to take appropriate action to
correct the low readings in time for the next inspection cycle reflects a serious lapse in Respondent's ability to react
appropriately to matters affecting the safe operation of its pipeline system." In the Matter of Natural Gas Pipeline
Company of America (Natural Gas Pipeline), C.P.F. 2-1997-3103 (Aug. 18, 1997) (available at
www. phmsa.dot. go v /pipeline/enforcement).



6
Sea Robin stated that, due to administrative error, "Contractor OQ" was inserted in the place of
Ronald Eversberg, who witnessed the maintenance of the valves in question.8 At the hearing,
Respondent provided an updated form showing that Ronald Eversberg witnessed the
maintenance of these valves.9 Accordingly, based upon a review of all of the evidence, I order
that Item 3 be withdrawn. .
ASSESS:MENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. 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; the Respondent's
ability to pay the penalty and 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 civil penalty of $10,300 for the violation of§ 192.605(a). I withdrew the
allegation of violation for Item 3; therefore, no civil penalty is appropriate.
Item 2: The Notice proposed a civil penalty of $10,300 for Respondent's violation of
49 C.F.R. § 192.605(a), for failing to prepare and follow its SOP for atmospheric corrosion
inspections. The Respondent argued that the penalty should be withdrawn due to the fact that it
did not violate its SOP by failing to remediate atmospheric corrosion prior to the next inspection
cycle. Given that I rejected this argument, there do not appear to be any factors that favor
mitigation of the proposed penalty for this item.
The Respondent did not make a good-faith effort to comply with the regulation. Furthermore,
although Respondent's omission did not result in any damage to the pipeline system or the
environment, Respondent's failure to promptly remediate could have undermined pipeline safety.
Respondent's ability to pay is not in question.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $10,300 for violation of 49 C.F.R. § 192.605.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
8 "But as far as the maintenance of the valve itself, outside of operation, we can say that Ron [Eversberg] performed
all of those activities. Transcript, 54.
9 Compliance Work Order, l-3.



7
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The
Financial Operations Division telephone number is (405) 954-8893.
Failure to pay the $10,300 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. § 192.605. Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas 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 operations:
1. With respect to the violation of§ 192.605 (Item 1), Respondent must review its
procedures and re-train and re-qualify those individuals responsible for the testing
and maintenance of the Stationary Gas Detection Systems to ensure the
procedures will be followed within 30 days following receipt of this Final Order.
2. With respect to the violation of§ 192.605 (Item 2), Respondent must remediate
the areas noted on the South Marsh 33 and East Cameron 195 platforms, as
indicated on the relevant Atmospheric Reports, within 30 days following receipt
of this Final Order.
3. Proof of compliance must be provided to the Regional Director, Southwest
Region, within 15 days of the completion of Items 1 and 2.
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.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 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.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2"d Floor, Washington, DC



8
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
~~ DEC2920D
Jeffrey D:-wiese Date Issued
Associate Administrator
for Pipeline Safety

420112001_Final Order_1229201_text.pdf

DEC 29 2011
Mr. Eric Amundsen
Vice President of Technical Services
Sea Robin Pipeline Company
5444 Westheimer Road
Houston, TX 77056-5306
Re: CPF No. 4-2011-2001
Dear Mr. Amundsen:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $10,300, and specifies actions that need to be taken by Sea
Robin Pipeline Company to comply with the pipeline safety regulations. The penalty payment
terms are set forth in the Final Order. When the civil penalty has been paid and the terms of
the compliance order completed, as determined by the Director, Southwest Region, this
enforcement action will be closed. Service of the Final Order by certified mail is deemed
effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. R.M. Seeley, Director, Southwest Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Stephen M. Moore, Counsel, Sea Robin Pipeline Company, LLC.
CERTIFIED MAIL - RETURN RECEIPT REQUESTED [71791000164203057799]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Sea Robin Pipeline Company, ) CPF No. 4-2011-2001
)
Respondent. )
____________________________________)
FINAL ORDER
In September and December 2010, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted on-site pipeline safety inspections of the facilities and records of Sea Robin
Pipeline Company (Sea Robin or Respondent) in Erath, Louisiana. Sea Robin operates 377.2
miles of pipeline, 2 compressor stations, and 5 offshore platforms.
As a result of these inspections, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated March 21, 2011, 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 Sea Robin committed violations of 49 C.F.R. Part 192 and
assessing a civil penalty of $19,000 for the alleged violations. The Notice also proposed
ordering Respondent to take certain measures to correct the alleged violations.
Sea Robin responded to the Notice by letter dated April 22, 2011 (Response), contesting two of
the allegations and requesting a hearing. An informal hearing was held on August 23, 2011, in
Houston, Texas with an attorney from the Office of Chief Counsel, PHMSA, presiding. At the
hearing, Sea Robin was represented by counsel. After the hearing, Respondent provided a
transcript of the proceeding, a Post-Hearing Statement (Brief), and additional exhibits for the
record, by letter dated September 23, 2011.
1
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.605, which states in
relevant part:
1 Some documents were forwarded electronically.



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 operations 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.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its
manual of written procedures for conducting operations and maintenance activities and for
emergency response. Specifically, the Notice alleged that a PHMSA inspector requested that
Sea Robin personnel perform a covered task, “Commission and Maintain Stationary Gas
Detection Systems,
” as part of the inspection process. Sea Robin personnel failed to verify that
the gas detector low and high alarm trips were properly functioning. When questioned, company
personnel mistakenly stated that performance of Step 3 of this covered task would result in a
station shut down.2 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. § 192.605(a) by failing to follow its manual of written procedures when performing
maintenance of the gas detection system.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.605, which states in
relevant part:
§ 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 operations 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.
The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow its
Standard Operating Procedures (SOP) for addressing atmospheric corrosion on certain offshore
platforms. SOP D.44 “Atmospheric Corrosion Inspection,” Section 7.4 Reporting requires
documentation of corrosion and its Appendix B classifies and provides the action item for each
2 A subsequent review of the maintenance records showed this is not the case …” Pipeline Safety Violation Report
(Violation Report), (March 22, 2011) (on file with PHMSA) at 3-4.



3
instance of noted corrosion. From 2008 through 2010, OPS asserted that Sea Robin personnel
repeatedly noted “Case 6 classifications” of corrosion on the South Marsh 33 and East Cameron
195 platforms. According to Appendix B, coating rehabilitation is required for Case 6
classifications. OPS argued in the Notice that Sea Robin failed to follow its SOP, which requires
remediation of Case 6 classifications prior to the next inspection cycle.
At the hearing, the Respondent presented evidence that it followed its SOP for addressing
atmospheric corrosion on the offshore platforms cited in the Notice. Sea Robin argued that
neither its operating procedures nor any regulation require remediation of corrosion on offshore
platforms prior to the next scheduled inspection. According to the Respondent, while Sea Robin
indicative of an integrity threat to the pipeline and therefore remediation was properly scheduled,
per its SOP. The Respondent also argued that corrosion is a constant concern, given the
geographic location and attendant weather conditions of offshore platforms in this area. Sea
Robin reasoned that, given these circumstances, some corrosion is expected and not necessarily
indicative of an integrity threat requiring repair according to a specific timetable. Since it
assigned a level 63 to the instances of corrosion cited in the Notice, such corrosion is not
adhered to the required yearly inspection intervals and determined that no immediate repair
condition was presented, the Respondent argued that it acted in accordance with its SOP and
therefore did not violate either its procedures or §192.605(a).
Sea Robin uses Panhandle Energy’s SOP Volume D – Corrosion (SOP), which provides the
procedure for an “Atmospheric Corrosion Inspection.” Several parts of this procedure are
instructive and reproduced below.
Section 7.3 “Evaluation of Inspection Results” states, in relevant part:
Step Activity
1 RANK coating condition as follows.
• Good (0-5%): Coating intact with no visible deterioration or damage
• Fair (6-20%): Coating essentially intact, but with some visible deterioration
• Poor (21-99%): Extensive visible deterioration of coating
• Bare (100%): No coating present.
2 DETERMINE whether the service life of the existing coating system can be extended through
spot repair or maintenance painting.
3 DEVELOP recommendations for coating rehabilitation using the guidelines listed in Appendix B
Classification of Coating Inspections.
4 DETERMINE whether the existing coating system will provide adequate protection to limit
corrosion activity to a uniform light surface oxide before the next Compliance Inspection.
NOTE:
1. With the exception of soil/air interfaces and offshore risers, the presence of uniform light surface
oxides should not affect the safe operation of the pipeline system.
2. Any corrosion found on an offshore riser or at a soil/air interface requires remedial action.
3 Panhandle Standard Operating Procedure (SOP), Appendix B, “Classification of Coating Inspection” rates
corrosion from Case 1 (least) to Case 7 (most).



4
Appendix B: Classification of Coating Inspection
CASE DESCRIPTION ACTION
Case 1 Coating system intact . . . No action required.
Case 4 Degradation of topcoat, but majority of primer and/or
intermediate coat intact. No indications of pitting.
Economic analysis indicates maintenance coating is not
cost effective. Experience in Area indicates that
remaining coating and/or surface oxide will prevent
pitting until next inspection period.
No action required. Existing coating
system must be removed prior to
recoating.
Case 6 Degradation of topcoat, but majority of primer and/or
immediate coat intact. Indication of pitting. Economic
analysis indicates maintenance coating is cost effective.
Coating rehabilitation required.
Remove and replace existing coating
system in areas where coating
degradation is severe. Apply
maintenance coating over intact
portions of existing coating.
Sea Robin argues that its atmospheric corrosion procedures provide the company with the
flexibility to defer a Case 6 classification until an integrity threat to the pipeline is identified or
the corrosion is such that the company is not adequately maintaining the pipeline.
4
However, the plain language of this SOP, read in its entirety, indicates otherwise. Section 7.3,
Step 4, specifically directs the inspector to determine whether the coating system will provide
sufficient protection until the next inspection cycle. Furthermore, Appendix B provides a
straightforward classification system that progresses from Case 1 to Case 7. For Case 1 through
Case 4 scenarios, “No action [is] required.” In the description of Case 4, where no action is
required, the inspector is required to find that the “remaining coating and/or surface oxide will
prevent pitting until [the] next inspection period.” In other words, for situations that are
classified as Case 1 - 4, the inspector must find the coating either “will perform adequately until
[the] next inspection period [or] will prevent pitting until [the] next inspection period.”5
Notably, Case 6 is absent of any such contemplation of the next inspection period. I find that
this is because “Appendix B: Classification of Coating Inspection,” read in conjunction with
SOP “Volume D – Corrosion – Atmospheric Corrosion Inspection” requires that rehabilitation be
addressed prior to the next inspection period.
Given Sea Robin’s position that its SOP does not require remediation prior to the next inspection
cycle, the Respondent also questioned in its post-hearing submission if any “authority [exists] for
the position . . . that the remediation at issue in Item 2 was required to be completed within an
inspection interval.” In a prior case, Panhandle, whose SOP is used by Sea Robin and is at issue
in this case, acknowledged that remediation of noted action items should occur before the next
4 “HEARING OFFICER: So is it your position that you could – Say we have the same situation. You say that it’s a
Case 6. As long – in your view, as long as you monitor the situation to the extent that you’re sure that the integrity
of the system has not been called into question, you could delay [these] remedial action as far into the future as you
deem appropriate? MR. RAU: And I hear where you’re going and I would say that . . . there’s another requirement
in the code that says we must maintain the coating system . . . So I think the issue is: Is more than a year appropriate
or not? . . . We disagree with that. We think that a year or less is not appropriate.”
5 SOP, Appendix B.



5
inspection cycle. In an August 6, 20086 letter, Panhandle Energy readily admitted that “PHMSA
has issued guidance on maximum intervals for corrosion control system remediation. That
next inspection period is, and has always been, the target for the remediation of issues noted
guidance states that remediation should be initiated prior to the next inspection period.”7 The
during a previous inspection.
Accordingly, after considering all of the evidence, I find that Respondent violated
49 C.F.R. § 192.605(a) by failing to remediate corrosion, according to its SOP.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.807, which states in
relevant part:
§ 192.807 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with
this subpart.
(a) . . .
(b) Records supporting an individual’s current qualification shall be
maintained while the individual is performing the covered task.
Records of prior qualification and records of individuals no longer
performing covered tasks shall be retained for a period of five
years.
The Notice alleged that Respondent violated 49 C.F.R. § 192.807(b) by failing to maintain
current qualification records for covered task 7T0032E – Annual Valve Maintenance and
Trouble Report (Emergency Valves). During the inspection, Sea Robin could not produce the
OQ records for “Contractor OQ,” who partially performed the annual maintenance task for three
valves on May 22, 2010.
At the hearing, the Respondent stated that a Sea Robin employee, Ronald Eversberg, performed
maintenance of the mainline valves cited in the Notice for failure to maintain OQ records for an
individual performing a covered task. PHMSA asserted that Sea Robin’s maintenance records
indicated that the annual maintenance task for certain valves was partially completed by
“Contractor OQ.”
6 In the Matter of Panhandle Eastern Pipeline Co. (Panhandle Pipeline), CPF 3-2008-1002, (Jun. 17, 2011)
(available at www.phmsa.dot.gov/pipeline/enforcement).
7 While not dispositive of the issue presented in this case, a number of final orders reaffirm that remediation should
occur prior to the beginning of the next inspection cycle. “Adverse conditions should be corrected as soon as
possible, and no later than the next inspection cycle.” In the Matter of Cenex, Inc. (Cenex), C.P.F. No. 5-1998-4514
(Oct. 20, 1998) (available at www.phmsa.dot.gov/pipeline/enforcement). “The failure to take appropriate action to
correct the low readings in time for the next inspection cycle reflects a serious lapse in Respondent’s ability to react
appropriately to matters affecting the safe operation of its pipeline system.” In the Matter of Natural Gas Pipeline
Company of America (Natural Gas Pipeline), C.P.F. 2-1997-3103 (Aug. 18, 1997) (available at
www.phmsa.dot.gov/pipeline/enforcement).



6
Sea Robin stated that, due to administrative error, “Contractor OQ” was inserted in the place of
Ronald Eversberg, who witnessed the maintenance of the valves in question.8 At the hearing,
Respondent provided an updated form showing that Ronald Eversberg witnessed the
maintenance of these valves.
that Item 3 be withdrawn.
9 Accordingly, based upon a review of all of the evidence, I order
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. 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; the Respondent’s
ability to pay the penalty and 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 civil penalty of $10,300 for the violation of § 192.605(a). I withdrew the
allegation of violation for Item 3; therefore, no civil penalty is appropriate.
Item 2: The Notice proposed a civil penalty of $10,300 for Respondent’s violation of
49 C.F.R. § 192.605(a), for failing to prepare and follow its SOP for atmospheric corrosion
inspections. The Respondent argued that the penalty should be withdrawn due to the fact that it
did not violate its SOP by failing to remediate atmospheric corrosion prior to the next inspection
cycle. Given that I rejected this argument, there do not appear to be any factors that favor
mitigation of the proposed penalty for this item.
The Respondent did not make a good-faith effort to comply with the regulation. Furthermore,
although Respondent’s omission did not result in any damage to the pipeline system or the
environment, Respondent’s failure to promptly remediate could have undermined pipeline safety.
Respondent’s ability to pay is not in question.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $10,300 for violation of 49 C.F.R. § 192.605.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
8 “But as far as the maintenance of the valve itself, outside of operation, we can say that Ron [Eversberg] performed
all of those activities. Transcript, 54.
9 Compliance Work Order, 1-3.



7
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The
Financial Operations Division telephone number is (405) 954-8893.
Failure to pay the $10,300 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. § 192.605. Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas 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 operations:
1. With respect to the violation of § 192.605 (Item 1), Respondent must review its
procedures and re-train and re-qualify those individuals responsible for the testing
and maintenance of the Stationary Gas Detection Systems to ensure the
procedures will be followed within 30 days following receipt of this Final Order.
2. With respect to the violation of § 192.605 (Item 2), Respondent must remediate
the areas noted on the South Marsh 33 and East Cameron 195 platforms, as
indicated on the relevant Atmospheric Reports, within 30 days following receipt
of this Final Order.
3. Proof of compliance must be provided to the Regional Director, Southwest
Region, within 15 days of the completion of Items 1 and 2.
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.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 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.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC



8
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420112001>
- Source ID: `phmsa-enforcement`
- SHA-256: `7358275f3336a490203f71eb6b169562cbaa7057ad8705ecc5eb4d0c7a00244c`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T15:35:46.752Z
- Document slug: `phmsa-enforcement-420112001`

### Source metadata

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