SUBURBAN PROPANE — Warning Letter

220110002W_warning letter_03292011_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 29, 2011 Steven Boyd Vice President Field Operations Suburban Propane 3161 Cameron Park Drive, No 207 Cameron Park, CA 95682 CPF 2-2011-0002W Dear Mr. Boyd: On March 2-4, 2011, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) inspected the procedures, records, and facilities of one Suburban Propane (Suburban) liquefied petroleum gas (LPG) pipeline system in Bunnell, Florida, pursuant to Chapter 601 of 49 United States Code. The Suburban LPG system inspected served the Flagler County Housing Authority with 120 customers. As a result of the inspection, it appears that Suburban Propane has committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are as follows: 1. §191.11 Distribution system: Annual report. (a) Except as provided in paragraph (b) of this section, each operator of a distribution pipeline system shall submit an annual report for that system on Department of Transportation Form RSPA F 7100.1-1. This report must be submitted each year, not later than March 15, for the preceding calendar year. Suburban did not submit an annual report for the calendar years 2009 and 2010. 2. §192.465 External corrosion control: Monitoring. (a) Each pipeline that is under cathodic protection must be tested at least once each calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic protection meets the requirements of §192.463.#

220110002W_warning letter_03292011_text.pdf, page 2Suburban did not test each of its pipelines under cathodic protection in calendar years 2007, 2008, 2009, and 2010. A review of Suburban’s records revealed the last cathodic protection monitoring was accomplished on December 14, 2006. 3. §192.465 External corrosion control: Monitoring. … (d) Each operator shall take prompt remedial action to correct any deficiencies indicated by the monitoring. Suburban did not take prompt remedial action to correct deficiencies, i.e. unsatisfactory levels of cathodic protection indicated by low1 pipe-to-soil (p/s) readings, found during cathodic protection surveys performed on the Flagler County Housing Authority system in December 2006. Suburban had no records showing that action was taken to correct the low reading of -811 mV found at 400 S. Peach Street. 4. §192.481 Atmospheric corrosion control: Monitoring. (a) Each operator must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows: Onshore At least once every 3 calendar years, but with intervals not exceeding 39 months Offshore At least once each calendar year, but with intervals not exceeding 15 months (b) During inspections the operator must give particular attention to pipe at soil-to- air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. (c) If atmospheric corrosion is found during an inspection, the operator must provide protection against the corrosion as required by Sec. 192.479. Suburban did not inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion at required intervals. Suburban’s records showed that it performed atmospheric corrosion control monitoring in December 2006 and October 2010, exceeding the 39 month timeframe. 5. §192.491 Corrosion control records. (a) Each operator shall maintain records or maps to show the location of cathodically protected piping, cathodic protection facilities, galvanic anodes, and neighboring structures bonded to the cathodic protection system. Records or maps showing a stated number of anodes, installed in a stated manner or spacing, need not show specific distances to each buried anode. (b) Each record or map required by paragraph (a) of this section must be retained for as long as the pipeline remains in service. 1 The criteria for cathodic protection are contained in 49 CFR Part 192, Appendix D. The criteria being referenced in this letter is negative (cathodic) voltage of at least 850mV with reference to a saturated copper- copper sulfate half cell with protective current applied. Accordingly, a “low” p/s reading is a reading less negative than 850mV. 2#

220110002W_warning letter_03292011_text.pdf, page 3Suburban did not have revised and updated system map showing the location of galvanic anodes and cathodically protected piping. 6. §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. 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. Suburban did not properly prepare and follow a manual of written procedures for conducting operations and maintenance activities and for emergency response. While the operator had a manual dated January 3, 2011, the manual was generic and contained no site specific operations and maintenance procedures or site specific procedures for emergency response. 7. §192.625 Odorization of gas (a) A combustible gas in a distribution line must contain a natural odorant or be odorized so that at a concentration in air of one-fifth of the lower explosive limit, the gas is readily detectable by a person with a normal sense of smell. .... (f) To assure the proper concentration of odorant in accordance with this section, each operator must conduct periodic sampling of combustible gases using an instrument capable of determining the percentage of gas in air at which the odor becomes readily detectable. (See also NFPA 58,Section 4.2.3, LP-Gas Odorization) Suburban did not conduct periodic sampling (“sniff tests”) to assure the proper concentration of odorant using an instrument capable of determining the percentage of gas in air at which the odor becomes readily detectable. 8. §192.739 Pressure limiting and regulating stations: Inspection and testing. (a) Each pressure limiting station, relief device (except rupture discs), and Pressure regulating station and its equipment must be subjected at intervals not exceeding 15 months, but at least once each calendar year, to inspections and tests to determine that it is– (1) In good mechanical condition; (2) Adequate from the standpoint of capacity and reliability of operation for the service in which it is employed; (3) Except as provided in paragraph (b) of this section, set to control or relieve at the correct pressure consistent with the pressure limits of §192.201(a); and (4) Properly installed and protected from dirt, liquids, or other conditions that might prevent proper operation. 3#

220110002W_warning letter_03292011_text.pdf, page 4Suburban had Fisher 630 regulators installed on its 1000-gallon aboveground LPG tanks. These regulators are 2-inch in size with a ½-inch orifice and have pressure ratings of 250 psig at the inlet and 5-35 psig at the outlet. Suburban did not inspect and test these regulators in calendar years 2007, 2008, 2009 and 2010. Suburban’s records showed that inspection and testing of its three regulators was performed on December 14, 2006 and February 28, 2011. 9. §192.747 Valve maintenance: Distribution systems. (a) Each valve, the use of which may be necessary for the safe operation of a distribution system, must be checked and serviced at intervals not exceeding 15 months, but at least once each calendar year. Suburban did not check and service valves at intervals not exceeding 15 months, but at least once each calendar year. Suburban’s records showed that valve maintenance was performed on December 14, 2006, and on February 28, 2011. There were no valve maintenance records for calendar year 2007, 2008, 2009, and 2010. 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. 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 items identified in this letter. Failure to do so will result in Suburban Propane 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 2-2011-0002W. 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 treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerely, Wayne T. Lemoi Director, Office of Pipeline Safety PHMSA Southern Region 4#

220110002W_warning letter_03292011_text.pdf, page 5cc: Dave Cash Manager Suburban Propane 45 S. Dixie Hwy. St. Augustine, Florida 32084 Thomas Ross General Manager Suburban Propane 6991-15th Street East Sarasota, Florida 34243 5#