{"operation":"document","citation":"CPF 220091004W","title":"FLORIDA GAS TRANSMISSION CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-09-23","effective_on":null,"summary":"CLOSED warning letter citing 192.201(b), 192.465(a), 192.731, 192.739(a), 192.745(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220091004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220091004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220091004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220091004W","body":"Warning Letter involving FLORIDA GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192,  192.201(b),  192.465(a),  192.731,  192.739(a),  192.745(a). The case was opened on 2009-09-23 and is reported as closed as of 2009-09-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220091004W_operator response_11102009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220091004W/220091004W_operator%20response_11102009.pdf\n\n220091004W_warning letter_09232009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220091004W/220091004W_warning%20letter_09232009.pdf\n\n220091004W_warning letter_09232009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220091004W/220091004W_warning%20letter_09232009_text.pdf\n\n220091004W_warning letter_09232009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nSeptember 23, 2009\nMr. Jeryl Mohn\nSenior Vice President, Operations and Engineering\nFlorida Gas Transmission Company, LLC\n5444 Westheimer Road\nHouston, TX 77056 CPF 2-2009- 1004W\nDear Mr. Mohn:\nOn June 22 through August 14, 2009, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, conducted\nan onsite pipeline safety inspection of your Florida Gas Transmission (FGT) pipeline facilities\nfor the Gulf Coast, Central and South Florida Areas. The pipeline records were reviewed at the\nMaitland and Tallahassee, Florida offices.\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, Part 192. The items\ninspected and the probable violations are:\n1. §192.201(b) Required capacity of pressure relieving and limiting stations.\n(b) When more than one pressure regulating or compressor station feeds into a pipeline,\nrelief valves or other protective devices must be installed at each station to ensure that the\ncomplete failure of the largest capacity regulator or compressor, or any single run of\nlesser capacity regulators or compressors in that station, will not impose pressures on any\npart of the pipeline or distribution system in excess of those for which it was designed, or\nagainst which it was protected, whichever is lower.\nAs a result of an abnormal condition that Safety Harbor Team recently experienced, FGT\ninstalled program logic to close the by pass valve 30-0 at the Plant City compressor station 30\nwhen the compressor station is not running and the by pass valve is open to prevent the 14 inch\nSaint Pete discharge lateral from over pressuring the suction side of the compressor station. The\nSaint Pete discharge pipeline is bi-directional and sometimes FGT needs natural gas to flow in\n\n\n\nthe reverse direction (East to West) to feed back into the suction side of the compressor station\nto provide natural gas to the West side of the pipeline system due to varying system demands.\nAt this time, FGT only has one level of over pressure protection and needs to ensure another\nlayer of over pressure protection in case program logic fails to close the by pass valve and not\nprotect the suction side of the compressor station 30. The compressor station suction pipeline\nhas a lower maximum allowable operating pressure (MAOP) than the discharge pipeline.\n2. §192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency must be\ninspected and partially operated at intervals not exceeding 15 months, but at least once\neach calendar year.\nFGT Mt. Vernon team did not have a 2008 record of service for valve 44-0. FGT upgraded the\ndata base and this valve was not included into the new data base.\n3. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests.\nFGT Quincy team did not have a 2007 maintenance record for the Hopkins New regulators and\nmissed the 15 month requirement for the Hopkins West regulators. The Hopkins West\nregulators were serviced in February 2007 and September 2008. (This was caused by a data\nbase upgrade error and the information was not loaded.)\n4. §192.731 Compressor stations: Inspection and testing of relief devices.\n(a) Except for rupture discs, each pressure relieving device in a compressor station must\nbe inspected and tested in accordance with §§192.739 and 192.743, and must be operated\nperiodically to determine that it opens at the correct set pressure.\n(b) Any defective or inadequate equipment found must be promptly repaired or replaced.\n(c) Each remote control shutdown device must be inspected and tested at intervals not\nexceeding 15 months, but at least once each calendar year, to determine that it functions\nproperly.\nFGT Quincy team missed the 15 month requirement for inspecting and testing pressure controls\nfor the Quincy Compressor station. FGT records show the test was conducted on January 2007\nand June 2008. (This was caused by a data base upgrade error.)\n5. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once each\ncalendar year, but with intervals not exceeding 15 months, to determine whether the\ncathodic protection meets the requirements of §192.463.\n\n\n\nFGT Caryville team missed the 2008 pipe to soil reading on the 100 line at mile post 374.768\n“Hwy 69” (test point 273215).\nThe Caryville team missed the 15 month interval requirement on the 100 line at mile post\n27.678 (test point 146139) “Valve at the Smith Power plant”\n. Pipe to Soil Readings were taken\non 3/6/08 and 8/5/09.\nIn addition to the items above, we also noted the following item of concern:\nIn reviewing FGT cathodic protection records on Alternating Current (AC) interference, some\nof the induced AC voltages were over 15 volts. FGT is planning to take remedial action to\nminimize the AC interference. The current AC voltage readings on the Anclote pipeline are:\nAnclote Pipeline\nStation Mile Post Location Old AC Reading\n268+45 5.08 CLT 224 26.14 Volts (V)\n309+71 5.87 CLT227 22.71\n354+79 6.72 CLT230 25.58\n421+40 7.98 CLT235 36.67\nUnder 49 United States Code, §60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violations persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in FGT being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2009-1004W. 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).\nSincerely,\nLinda Daugherty\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7704}