{"operation":"document","citation":"CPF 220081007W","title":"CAROLINA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-14","effective_on":null,"summary":"CLOSED warning letter citing 192.13(c), 192.225(a), 192.603(b), 192.705(a), 192.706(a), 192.736(c), 192.745(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220081007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220081007W","body":"Warning Letter involving CAROLINA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.13(c),  192.225(a),  192.603(b),  192.705(a),  192.706(a),  192.736(c),  192.745(b). The case was opened on 2008-04-14 and is reported as closed as of 2008-04-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220081007W_warning letter_04142008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081007W/220081007W_warning%20letter_04142008.pdf\n\n220081007w_warning letter_04142008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220081007W/220081007w_warning%20letter_04142008_text.pdf\n\n220081007w_warning letter_04142008_text.pdf\n\nU. S. Department\nof Transportation\nPtpIBns and\nHazardous Matsrijalls Safety\nAdmiinlstretlon\n233 Peachtree Street Ste 600\nAtlanta, GA 30303\nWRING I KITER\nApril 14, 2008\nMr. Samuel L Dozier\nVP Commercial and Field Operations\nCarolina Gas Transmisston Corporation\n105 New Way Road\nColumbia, SC 29224-2407\nCPF No. 2-2008-1007W\nDear Mr. Dozier:\nOn September 24-28, 2007 and October 29 — November 7, 2007, representatives of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code inspected your pipeline procedures, records and facilities in Columbia,\nSouth Carolina.\nAs a result of the inspectton, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are.\n(c) Each operator shaB maintain, modify as appropriate, and follow the plans,\nprocedures, and programs that iit is required to estabhsh under Part I92.\nThe Operation A Maintenance Procedure 603 on pressure testing should reference the\nCarolina Gas Transmission Corporation (CGT) Operating Guidelines which contain\nhydrostatic testing procedures. CGT has been working to establish and standardkze the\ncompany procedures since the merger of two companies to form CGT.\n\n\n\nA review of the CGT Welding Manual found an incorrect reference to the 18'\" edition\nof API 1104. CGT must ensure that its Welding Manual has the correct reference of\nAPI 1104 19'\" edition.\n3. 192. 603 General provisions.\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under 192. 605.\nThe current CGT document management system referenced in the CGT O&M manual,\nMonitor-Pro 5 (MP5), for tracking and recording maintenance activities has a number\nof deficiencies The information recorded on the maintenance forms such as valve and\ncompressor station maintenance is not complete when recorded in the MP5 document\nmanagement system. CGT is in the process of evaluating and establishing a new\ndocument management system for maintenance activities.\n(a) Each operator shall have a patrol program to observe surface conditions on\nand adjacent to the transmission hne right-of-way for indications of leaks,\nconstruction activity, and other factors affecting safety and operation.\nA field inspection of the right-of-way location Station 27-5 near the Summerville area\nraised safety concerns about steel beams and a pile of gravel on the right-of-way. The\nconcern will be addressed with the sister company South Carolina Electric & Gas which\nshares the right-of-way with CGT.\nl. eakage surveys of a transmission Hne must be conducted at intervals not\nexceeding 15 months, but at least once each calendar year. However, in the case of\na transmission hne which transports gas in conformity with 192. 625 without an\nodor or' odorant, leakage surveys using leak detector equipment must be\nconducted —-\n(a) ln Class 3 locations, at intervals not exceeding '7 ~/z months, but at least twice\neach calendar year.\n\n\n\nCGT must ensure that it properly documents the leakage surveys of its Class 3\nun-odorized area with leak detector equipment on the 20 inch Port Wentworth segment.\nThe leakage survey records reviewed during the inspection did not demonstrate\ncomphance with the required interval of 7 /z months, However, CGT provided several\ndocuments from Heath Consultants to verify the dates, location and use of leak\ndetection equipment for compliance.\n6. 192. 736 Compressor stations: Cas detection.\n(c) Each gas detection and alarm system required by this section must be\nmaintained to function properly. The maintenance must include performance\ntests.\nCGT must ensure that the test performed on each means of activation for the ESD\nsystem, fire protection and gas detection is properly documented. The records provided\nfor review at the headquarter office from the MP5 system did not list the locations\ntested at each compressor station. The compressor station logbook was reviewed during\nthe field inspection and indicated that testing of each means for activating the systems\nwas performed.\nThe valve maintenance records were inconsistent with recorded information such as\nlocation and type of maintenance (lubricate, turn, paint, etc. ). CGT is in the process of\ndeveloping new forms for valve maintenance.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Failure to do so will result in Carolina Gas Transmission Corporation being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF Xo. 2-2008-I007%. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along\nwith the complete original document you must provide a second copy of the document with the\n\n\n\nportions you beheve qualify for confidential treatment redacted and an explanation of why you\nbeheve the redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\nSincerely,\n~\nMichael J. Khayata\nActing Director, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6455}