FLORIDA GAS TRANSMISSION CO — Warning Letter

party submissionOfficial PDF220071002W_Operator Response_01302007.pdf#

party submissionOfficial PDF220071002W_Operator Response_03302007.pdf#

220071002W_Warning Letter_01112007.pdf, page 1Official PDF@ U.5. Deportmenf of Trqnsportqlion Pipellne ond Hozordous Moferlots Sotety Admlnl3lrqlion 233 Peachtr€e Slreet Ste. 600 Atlanta, GA 30303 WARNING LETTER CERTIFIED MAIL. RETURN RECEIPT REOUESTED January 11,2007 Eric J. Amundsen Vice President Technical Services Florida Gas Transmission Company 5444 Westheimer Road Houston. T){77056-5306 cPF 2-2007-1002w Dear Mr. Amundsen: On April 3-6,2006., a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspectSd maintenance records in your office in Tallahassee, Florida. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations Title 49, Code of Federal Regulations. The item inspected and the probable violation is: $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. tr'or 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.#

220071002W_Warning Letter_01112007.pdf, page 2Florida Gas Transmission Company uses a computerized database called MP2 to record compliance inspection data. The MP2 system contains the following specific instructions for completing pressure regulator inspections: "ENTER THE FOLLOWING INFORMATION IN COMMENTS WHEN CLOSING WORK ORDERS" SET POINT: , AS FOUND: , AS LEFT: LOCK UP: YES/NO. It was found that in some areas of your company these procedures are not being used and appear to be viewed by operating personnel as optional. Pressure regulator inspection records were reviewed for the years 2004 and 2005. In the Munson Team Area, records for 20 pressure regulators did not contain the required comments. 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 violations persists up to a maximum of $1,000,000 for any 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 identified in this letter. Be advised that failure to do so will result in Florida Gas Transmission Company 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 2-2007-1002W. Sincerely, slinda Daughty Linda Daugherty Director, Southern Region Pipeline and Hazardous Materials Safety Administration 2#