# SANTEE COOPER - RAINEY GENERATING STATION — Warning Letter

- **operation:** document
- **citation:** CPF 220111003W
- **title:** SANTEE COOPER - RAINEY GENERATING STATION — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2011-01-14
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.615(b)(2), 192.616(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220111003W
**body:**

Warning Letter involving SANTEE COOPER - RAINEY GENERATING STATION. PHMSA's enforcement data identifies the cited regulations as 192.615(b)(2),  192.616(a). The case was opened on 2011-01-14 and is reported as closed as of 2011-01-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220111003W_warning letter_01142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111003W/220111003W_warning%20letter_01142011.pdf

220111003W_warning letter_01142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220111003W/220111003W_warning%20letter_01142011_text.pdf

220111003W_warning letter_01142011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 14, 2011
Mr. Joseph Thorndyke
Station Manager
Santee Cooper - Rainey Generating Station
P.O. Box 70
2900 Opry House Road
Iva, SC 29655
CPF 2-2011-1003W
Dear Mr. Thorndyke:
On October 20-21, 2010, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) inspected the Santee Cooper - Rainey (SCR) Generating Station
records and pipeline facilities in Iva, SC, pursuant to Chapter 601 of 49 United States Code.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations in Title 49 of the Code of Federal Regulations. The items
inspected and the probable violations are:
1. §192.615 Emergency plans.
…. (b) Each operator shall:
…. (2) Train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training is effective.
While SCR's training records indicated SCR had completed some training related to
emergencies, SCR failed to meet the regulations because its records did not demonstrate
that it had adequately trained the appropriate operating personnel on the company’s
emergency procedures and did not show that SCR had verified the effectiveness of the
training.
2. §192.616 Public awareness.
(a) Except for an operator of a master meter or petroleum gas system covered under
paragraph (j) of this section, each pipeline operator must develop and implement a
written continuing public education program that follows the guidance provided in
the American Petroleum Institute’s (API) Recommended Practice (RP) 1162
(incorporated by reference, see §192.7).



SCR failed to meet the regulations because it did not complete a public awareness
program effectiveness evaluation no later than June 20, 2010.
API RP 1162 Section 8.5, Table 8-1 requires an operator to conduct an evaluation of the
effectiveness its public awareness program implementation at intervals of no more than
four years. The first effectiveness evaluation was due no later than June 20, 2010.
At the time of the inspection, SCR personnel provided documentation showing it had
communicated with a contractor to perform the effectiveness evaluation, but SCR could
not verify that the evaluation had actually been completed.
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 item(s) identified in this letter. Failure to do so will result in Santee Cooper Rainey 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 2-2011-1003W. 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
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