{"operation":"document","citation":"CPF 220083001W","title":"CHATTANOOGA GAS CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-07-10","effective_on":null,"summary":"CLOSED warning letter citing 193.2613, 193.2619(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220083001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220083001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220083001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220083001W","body":"Warning Letter involving CHATTANOOGA GAS CO. PHMSA's enforcement data identifies the cited regulations as 193.2613,  193.2619(e). The case was opened on 2008-07-10 and is reported as closed as of 2008-07-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220083001W_warning letter_07102008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220083001W/220083001W_warning%20letter_07102008.pdf\n\n220083001w_warning letter_07102008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220083001W/220083001w_warning%20letter_07102008_text.pdf\n\n220083001w_warning letter_07102008_text.pdf\n\nU. s. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n233 peachtree Street Ste. 600\nAtlanta, GA 30303\nWARNING LETTER\nCERTIPIED MAIL - RETURN RECEIPT~RE UEETED\nJuly 10, 2008\nMr. Charles Rawson\nVice President Gas Operations\nAGL Resources\nTen Peachtree Place\nAtlanta, Georgia 30309\nCPF 2-2008-3001W\nDear Mr. Rawson:\nOn June 9-12, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected your\nChattanooga Gas Company liquefied natural gas (LNG) facility in Chattanooga, Tennessee.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n193. 2613 Auxiliary power sources.\nEach auxiliary power source must be tested monthly to check its operational\ncapability and tested annually for capacity. The capacity test must take into\naccount the power needed to start up and simultaneously operate equipment that\nwould have to be served by that power source in an emergency.\nChattanooga Gas uses a software document management system to schedule and track\nmaintenance and operational activities. The system produces a work order form which\nhas a target date for completing the monthly inspection. Work order records for 2007\ndid not have a completion date for the months of May, June and October, Completion\nof the monthly test was verified by other field records. Chattanooga Gas needs to\nproperly record the completion date for monthly testing on the work order.\n\n\n\n193. 2619 Control systems.\n(e) Relief valves must be inspected and tested for verification of the valve seat\nlifting pressure and reseating.\nThe 2006 relief valve inspection records indicated that valves for the LNG transfer to\ntruck loading system were tested in December of 2007. Records for 2007 indicated that\nall relief valves were inspected and tested as required in November 2007. The records\nwere not clear about the date when the valves for this system were tested and replaced.\nThe operational logs verified that the LNG transfer system to uuck loading was taken\nout of service in November 2006 due to bad hose lines. The lines were replaced in\nApril of 2007 returning the system back to service. Chattanooga Gas needs to properly\nrecord the date when a relief valve is tested or replaced to ensure that proper inspection\nintervals are maintained.\nUnder 49 United States Code, II 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. Also, for LNG facilities, an additional penalty of not more\nthan $50, 000 for each violation may be imposed. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in Chattanooga Gas Company\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-200S-3001W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4610}