# SUBURBAN PROPANE — Warning Letter

- **operation:** document
- **citation:** CPF 220120004W
- **title:** SUBURBAN PROPANE — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-08-01
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.1005, 192.11(b), 192.16, 192.195, 192.353(a), 192.463(a), 192.465(a), 192.465(d), 192.481, 192.491(a), 192.605(a), 192.615(b), 192.615(c), 192.616(h), 192.616(i), 192.625(f), 192.707, 192.721, 192.723, 192.739(a), 192.741(a), 192.743, 192.747(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220120004W
**body:**

Warning Letter involving SUBURBAN PROPANE. PHMSA's enforcement data identifies the cited regulations as 192.1005,  192.11(b),  192.16,  192.195,  192.353(a),  192.463(a),  192.465(a),  192.465(d),  192.481,  192.491(a),  192.605(a),  192.615(b),  192.615(c),  192.616(h),  192.616(i),  192.625(f),  192.707,  192.721,  192.723,  192.739(a),  192.741(a),  192.743,  192.747(a). The case was opened on 2012-08-01 and is reported as closed as of 2012-08-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220120004W_warning letter_08012012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120004W/220120004W_warning%20letter_08012012.pdf

220120004W_warning letter_08012012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220120004W/220120004W_warning%20letter_08012012_text.pdf

220120004W_warning letter_08012012_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 1, 2012
Mr. Steven Boyd
Vice President of Field Operations
Suburban Propane
3161 Cameron Park Drive, Suite 207
Cameron Park, CA 95682-7978
CPF 2-2012-0004W
Dear Mr. Boyd:
From December 5-9, 2011, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) inspected the Suburban Propane (Suburban) records and procedures
in its North Miami, Florida, office and its liquefied petroleum gas (LPG) pipeline systems in
Dade County, Florida, pursuant to Chapter 601 of 49 United States Code.
As a result of the inspection, it appears that Suburban 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. §192.11 Petroleum gas systems.
... (b) Each pipeline system subject to this part that transports only petroleum gas or
petroleum gas/air mixtures must meet the requirements of this part and of
ANSI/NFPA 58 and 59.
Suburban did not meet the requirements of NFPA 58 (2004), Section 6.7.4.6, which states
that “The point of discharge shall also be located not less than 5 ft (1.5 m) in any
direction away from any source of ignition, openings into direct-vent (sealed combustion
system) appliances, or mechanical ventilation air intakes.”



Suburban installed the point of discharge from pressure relief devices on regulating
equipment less than 5 feet from sources of ignition at the following locations:
– 1500 SW 131st Avenue at University Lakes
– 2787 E Marina Drive at Estates of Fort Lauderdale
– 501 135th Way at Sunshine City
2. §192.16 Customer notification.
(a) This section applies to each operator of a service line who does not maintain the
customer's buried piping up to entry of the first building downstream, or, if the
customer's buried piping does not enter a building, up to the principal gas utilization
equipment or the first fence (or wall) that surrounds that equipment. For the
purpose of this section, “customer's buried piping” does not include branch lines
that serve yard lanterns, pool heaters, or other types of secondary equipment. Also,
“maintain” means monitor for corrosion according to §192.465 if the customer's
buried piping is metallic, survey for leaks according to §192.723, and if an unsafe
condition is found, shut off the flow of gas, advise the customer of the need to repair
the unsafe condition, or repair the unsafe condition.
(b) Each operator shall notify each customer once in writing of the following
information:
(1) The operator does not maintain the customer's buried piping.
(2) If the customer's buried piping is not maintained, it may be subject to the
potential hazards of corrosion and leakage.
(3) Buried gas piping should be—
(i) Periodically inspected for leaks;
(ii) Periodically inspected for corrosion if the piping is metallic; and
(iii) Repaired if any unsafe condition is discovered.
(4) When excavating near buried gas piping, the piping should be located in advance,
and the excavation done by hand.
(5) The operator (if applicable), plumbing contractors, and heating contractors can
assist in locating, inspecting, and repairing the customer's buried piping.
(c) Each operator shall notify each customer not later than August 14, 1996, or 90
days after the customer first receives gas at a particular location, whichever is later.
However, operators of master meter systems may continuously post a general notice
in a prominent location frequented by customers.
(d) Each operator must make the following records available for inspection by the
Administrator or a State agency participating under 49 U.S.C. 60105 or 60106:
(1) A copy of the notice currently in use; and
(2) Evidence that notices have been sent to customers within the previous 3 years.
Suburban did not notify each customer once in writing of the information required by the
regulation within 90 days after its customers first received gas. Suburban did not have
documentation to demonstrate that it had provided the notice required by §192.16(b) in
the time allowed by §192.16(c). Moreover, Suburban did not have a copy of the notice
currently in use as required by §192.16(d)(1). Photographic evidence of buried customer
piping downstream of the meter was taken at 348 Big Cypress Drive in Seminole Estates.
2



3. §192.195 Protection against accidental overpressuring.
(a) General requirements. Except as provided in §192.197, each pipeline that is
connected to a gas source so that the maximum allowable operating pressure could
be exceeded as the result of pressure control failure or of some other type of failure,
must have pressure relieving or pressure limiting devices that meet the requirements
of §§192.199 and 192.201.
(b) Additional requirements for distribution systems. Each distribution system that
is supplied from a source of gas that is at a higher pressure than the maximum
allowable operating pressure for the system must—
(1) Have pressure regulation devices capable of meeting the pressure, load, and other
service conditions that will be experienced in normal operation of the system, and
that could be activated in the event of failure of some portion of the system; and
(2) Be designed so as to prevent accidental overpressuring.
Suburban failed to ensure that each pipeline that was connected to a gas source, for which
the maximum allowable operating pressure could be exceeded as the result of pressure
control failure or some other type of failure, had a pressure relieving or pressure limiting
device that met the requirements §192.199 and §192.201.
Suburban supplies gas to its pipeline systems from LPG storage tanks capable of operating
at well over 100 psig while its downstream pipeline systems have a maximum allowable
operating pressure of 30 psig. There were not any additional over pressure relieving or
pressure limiting devices installed on the pipelines downstream of its storage tanks that
would have prevented accidental overpressuring of the pipeline systems had the primary
regulator failed. The lack of overpressure protection was identified, during the field
inspection, on the pipelines downstream of:
– the tank at 2523 Opa Locka
– the tank at 2525 Opa Locka
– tanks 5, 8, 10, and 13 at Boulevard Heights
– tanks 25 and 26 at Oakland Acres
– the tank at Randall Square
– tanks 1, 2, 4, and 5 at Stardust
– the tank at Sunshine Village (Note: though the operator had installed overpressure
protection at this location, the PHMSA inspectors found the overpressure protection
by-passed during the inspection leaving the downstream pipeline without protection
from accidental overpressuring)
– tanks 9, 14, and 15 at University Lakes
4. § 192.353 Customer meters and regulators: Location.
(a) Each meter and service regulator, whether inside or outside a building, must be
installed in a readily accessible location and be protected from corrosion and other
damage, including, if installed outside a building, vehicular damage that may be
anticipated. However, the upstream regulator in a series may be buried.
Suburban did not protect each meter and service regulator installed outside a building
from vehicular damage. During the field inspection, a meter not protected from vehicular
damage was found in the vacant lot adjacent to 1112 SW 127th Court in University Lakes.3



Evidence of the probable violation is based on field observations of the inspectors and
photographs that show the meter was not protected from vehicular damage and had
probably been struck by a vehicle.
5. §192.463 External corrosion control: Cathodic protection.
(a) Each cathodic protection system required by this subpart must provide a level of
cathodic protection that complies with one or more of the applicable criteria
contained in appendix D of this part. If none of these criteria is applicable, the
cathodic protection system must provide a level of cathodic protection at least equal
to that provided by compliance with one or more of these criteria.
Suburban did not ensure that its installed cathodic protection systems provided a level of
cathodic protection that complied with one or more of the applicable criteria contained in
Appendix D of Part 192.
Cathodic protection testing performed during the inspection found locations with low1
pipe-to-soil (p/s) readings indicating inadequate levels of cathodic protection. An
abbreviated list of locations with associated low p/s readings follows:
– 2523 Opa Locka 12/07/2011
– Tank -426 mV
– Pipeline -333 mV
– 2525 Opa Locka 12/07/2011
– Tank -488 mV
– Pipeline -488 mV
– Boulevard Heights 12/08/2011 02/22-23/2011
– Tank 8 -651 mV -762 mV
– Tank 13 -505 mV -383 mV
– Pipeline downstream Tank 5 -359 mV -394 mV
– Pipeline downstream Tank 8 -348 mV -429 mV
– Pipeline downstream Tank 10 -510 mV -507 mV
– Fairway Heights #2 12/07/2011
– Tank 3 -416 mV
– Pipeline -294 mV
– Fairway Heights #4 12/07/2011
– 15720 SW 104th Avenue -416 mV
– Oakland Acres 12/07/2011
– Tank 25 -185 mV
– Tank 26 -320 mV
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. Accordingly, a “low” pipe-to-soil (p/s) reading is a reading less negative than -850mV.4



– Stardust 12/07/2011
– Tank 1 -327 mV
– Tank 2 -612 mV
– Tank 4 -430 mV
– Tank 7 -480 mV
– Tank 11 -730 mV
– University Lakes 12/07/2011 01/25-26/2011
– 12920 SW 14th Street -828 mV -531 mV
– 1447 SW 131st Avenue -299 mV -264 mV
– Pool Meter -552 mV -656 mV
6. §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. However, if tests at those
intervals are impractical for separately protected short sections of mains or
transmission line, not in excess of 100 feet (30 meters), or separately protected
service line, these pipelines may be surveyed on a sampling basis. At least 10 percent
of these protected structures, distributed over the entire system must be surveyed
each calendar year, with a different 10 percent checked each subsequent year, so
that the entire system is tested in each 10-year period.
Suburban did not test each pipeline that is under cathodic protection, 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.
Suburban provided records for the annual cathodic protection monitoring that it had
performed. However, Suburban was unable to provide records demonstrating that it
performed external corrosion control monitoring on the following systems for the years
indicated:
– 2523 Opa Locka 2009 - 2011
– 2525 Opa Locka 2009 - 2011
– Boulevard Heights 2010
– Estates of Ft. Lauderdale 2010
– Fairway Heights #2: 2009 - 2011
– Fairway Heights #4: 2009 - 2011
– Oakland Acres: 2009 - 2011
– Randall Square: 2009 - 2011
– Seminole Estates: 2010
– Stardust: 2009 - 2011
– Sunshine City: 2009 - 2011
– Sunshine Village: 2009 - 2011
– University Lakes: 2009
5



7. §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 indicated by its
external corrosion control monitoring.
Suburban provided documentation showing that it had low cathodic protection potentials
in its 2009 monitoring at several locations in Boulevard Heights. Documentation of its
2011 monitoring continued to show low cathodic protection potentials. Suburban was
unable to produce documentation that it had corrected the deficiencies. The locations
identified were:
Boulevard Heights June 2009 February 2011
– Tank 1 -401 mV -524 mV
– Tank 2 -394 mV -254 mV
– Tank 4 -846 mV -747 mV
– Tank 13 -714 mV -383 mV
Additionally, Suburban documentation showed the Sunshine Village Test Station 61 test
lead produced no readings during its external corrosion control monitoring on
June 30, 2009. When checked in the field on December 8, 2011, the test lead still
produced no reading. Suburban was unable to produce documentation that it had
corrected the deficiency.
8. §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:
If the pipeline is located: Then the frequency of inspection is:
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 §192.479.
Suburban did not inspect each onshore pipeline or portion of pipeline exposed to the
atmosphere for evidence of atmospheric corrosion at least once every 3 calendar years, but
with intervals not exceeding 39 months. Suburban has onshore pipelines exposed to the
atmosphere for which it provided no records demonstrating that it performed atmospheric
corrosion control monitoring for 2523 Opa Locka, 2525 Opa Locka, Fairway Heights #2,
Fairway Heights #4, Oakland Acres, Randall Square, Stardust, Sunshine City, and
Sunshine Village in calendar years 2009, 2010, or 2011.
6



9. §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.
Suburban did not maintain records and maps showing the location of cathodically
protected piping, cathodic protection facilities, galvanic anodes, and neighboring
structures bonded to the cathodic protection system for its pipeline facilities. Suburban’s
pipeline system maps did not identify the location of all cathodically protected piping and
galvanic anodes.
10. §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. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once 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.
The Suburban written procedural manual for operations, maintenance, and emergencies
did not have procedures for the following:
– defining an incident in accordance with the definition found in §191.3
– requiring reports (except SRCR and offshore pipeline condition reports) be submitted
in accordance with the requirements of §191.7
– reporting mechanical fitting failures on its distribution systems as required by §191.12
– notifying PHMSA electronically through the National Registry of Pipeline and LNG
Operators at http://opsweb.phmsa.dot.gov of certain events, as required by §191.22
– filing written safety-related conditions reports in accordance with the requirements of
§191.23
– notifying new customers, within 90 days, of their responsibility for service lines not
maintained by the operator as required by §192.16
– joining plastic pipe in accordance with §192.281
– qualifying joining procedures for plastic pipe in accordance with §192.283
– qualifying persons to make plastic pipe joints in accordance with §192.285
– inspecting joints in plastic pipes in accordance with §192.287
– installing excess flow valves (EFV) which meet the performance requirements of
§192.381 on new or replaced service lines on single-family residences as required
by §192.383
– having design, installation, and maintenance of cathodic protection systems carried out
by, or under the direction of, a person qualified in pipeline corrosion control methods
as specified in §192.453
– examining buried pipe when exposed as required by §192.459
7



– applying a protective coating, for the purpose of external corrosion control in
accordance with §192.461
– providing a level of cathodic protection that complies with one or more of the
applicable criteria contained in appendix D of Part 192, as required by §192.463
– taking prompt remedial action to correct any deficiencies indicated by cathodic
protection monitoring as required by §192.465(d)
– electrically isolating buried or submerged pipelines from other underground metallic
structures and performing inspection and electrical tests to assure that electrical
isolation is adequate as required by §192.467
– having sufficient test stations or other contact points for electrical measurements as
required by §192.469
– installing and maintaining test leads in accordance with §192.471
– inspecting the internal surface for evidence of corrosion whenever any pipe is
removed from a pipeline for any reason as required by §192.475(b)
– inspecting pipelines exposed to the atmosphere in accordance with §192.481
– maintaining corrosion control records and maps in accordance with §192.491
– making construction records, maps, and operating history available to appropriate
operating personnel as required by §192.605(b)(3)
– periodically reviewing work done by operator personnel to determine the effectiveness
of procedures used in normal operation as required by §192.605(b)(8)
– taking adequate precautions in excavated trenches as required by §192.605(b)(9)
– having a damage prevention program as required by §192.614
– responding to emergencies in accordance with §192.615(a)
– furnishing supervisors the latest edition of emergency procedures, training appropriate
operating personnel, and reviewing employee activities to determine whether the
procedures were effectively followed in each emergency as required by §192.615(b)
– establishing and maintaining liaison appropriate fire, police, and other public officials
as required by §192.615(c)
– investigating failures in accordance with §192.617
– odorizing the gas 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, as
required by §192.625(a); and conducting periodic sampling of combustible gases
using an instrument capable of determining the percentage of gas in air at which the
odor becomes readily detectable as required by §192.625(f).
– placing and maintaining line markers as required by §192.707
– inspecting and testing pressure limiting and regulating stations at intervals not
exceeding 15 months, but at least once each calendar year as required by §192.739(a)
– taking prompt remedial action to correct any valve found inoperable as required by
§192.747(b)
– a qualification program meeting the requirements of Subpart N (i.e. §192.801-809)
11. §192.615 Emergency plans.
... (b) Each operator shall:
(1) Furnish its supervisors who are responsible for emergency action a copy of that
portion of the latest edition of the emergency procedures established under
8



paragraph (a) of this section as necessary for compliance with those procedures.
(2) Train the appropriate operating personnel to assure that they are knowledgeable
of the emergency procedures and verify that the training is effective.
(3) Review employee activities to determine whether the procedures were effectively
followed in each emergency.
Suburban did not train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training was effective.
Suburban did not have documentation demonstrating that it had trained the appropriate
operating personnel to assure that they are knowledgeable of the emergency procedures
and verified that the training was effective.
12. §192.615 Emergency plans.
... (c) Each operator shall establish and maintain liaison with appropriate fire, police,
and other public officials to:
(1) Learn the responsibility and resources of each government organization that may
respond to a gas pipeline emergency;
(2) Acquaint the officials with the operator's ability in responding to a gas pipeline
emergency;
(3) Identify the types of gas pipeline emergencies of which the operator notifies the
officials; and
(4) Plan how the operator and officials can engage in mutual assistance to minimize
hazards to life or property.
Suburban did not establish and maintain liaison with appropriate fire, police, and other
public officials. When requested, Suburban was unable to provide documentation
showing that it established and maintained liaison with fire, police, and other public
officials.
13. §192.616 Public Awareness.
... (h) Operators in existence on June 20, 2005, must have completed their written
programs no later than June 20, 2006. The operator of a master meter or petroleum
gas system covered under paragraph (j) of this section must complete development of
its written procedure by June 13, 2008. Upon request, operators must submit their
completed programs to PHMSA or, in the case of an intrastate pipeline facility
operator, the appropriate State agency.
Suburban did not complete its public awareness program by the regulatory deadline. At
the time of the inspection, Suburban did not have a written program or procedures in place
that met the requirements of §192.616.
14. §192.616 Public Awareness.
... (i) The operator's program documentation and evaluation results must be
available for periodic review by appropriate regulatory agencies.
Suburban did not document its public awareness program. When requested, Suburban
provided no documentation of public awareness activities.
9



15. §192.625 Odorization of gas.
... (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. Operators of master meter systems may comply with
this requirement by-
(1) Receiving written verification from their gas source that the gas has the proper
concentration of odorant; and
(2) Conducting periodic "sniff" tests at the extremities of the system to confirm that
the gas contains odorant.
Suburban did not assure the proper concentration of odorant by conducting periodic
sampling of combustible gases using an instrument capable of determining the percentage
of gas in air at which the odor becomes readily detectable. Suburban provided
documentation from its propane supplier showing the propane was odorized prior to
delivery and records showing that the operator conducted periodic “sniff” tests to confirm
the gas contained odorant. However, since Suburban was not operating master meter
systems, it cannot solely rely on this method to comply with the regulation. The only
acceptable method of complying was to use an instrument capable of determining the
percentage of gas in air at which the odor becomes readily detectable.
16. §192.707 Line markers for mains and transmission lines.
(a) Buried pipelines. Except as provided in paragraph (b) of this section, a line
marker must be placed and maintained as close as practical over each buried main
and transmission line:
(1) At each crossing of a public road and railroad; and
(2) Wherever necessary to identify the location of the transmission line or main to
reduce the possibility of damage or interference.
(b) Exceptions for buried pipelines. Line markers are not required for the following
pipelines:
(1) Mains and transmission lines located offshore, or at crossings of or under
waterways and other bodies of water.
(2) Mains in Class 3 or Class 4 locations where a damage prevention program is in
effect under §192.614.
(3) Transmission lines in Class 3 or 4 locations until March 20, 1996.
(4) Transmission lines in Class 3 or 4 locations where placement of a line marker is
impractical.
(c) Pipelines aboveground. Line markers must be placed and maintained along each
section of a main and transmission line that is located aboveground in an area
accessible to the public.
(d) Marker warning. The following must be written legibly on a background of
sharply contrasting color on each line marker:
(1) The word “Warning,” “Caution,” or “Danger” followed by the words “Gas (or
name of gas transported) Pipeline” all of which, except for markers in heavily
developed urban areas, must be in letters at least 1 inch (25 millimeters) high
with1/4inch (6.4 millimeters) stroke.
10



(2) The name of the operator and the telephone number (including area code) where
the operator can be reached at all times.
Suburban did not place pipeline markers as close as practical over each buried main at
each crossing of a public road and along each section of mains that were located
aboveground in an area accessible to the public. During the field inspection, the
inspectors identified multiple locations where buried mains crossed public streets and
where mains came aboveground that did not have pipeline markers.
17. §192.721 Distribution systems: Patrolling.
(a) The frequency of patrolling mains must be determined by the severity of the
conditions which could cause failure or leakage, and the consequent hazards to
public safety.
(b) Mains in places or on structures where anticipated physical movement or
external loading could cause failure or leakage must be patrolled—
(1) In business districts, at intervals not exceeding 4½ months, but at least four times
each calendar year; and
(2) Outside business districts, at intervals not exceeding 7½ months, but at least twice
each calendar year.
Suburban did not patrol its mains in business districts at intervals not exceeding 4½
months, but at least four times each calendar year and its mains outside business districts
at intervals not exceeding 7½ months, but at least twice each calendar year. Suburban had
no records documenting that it patrolled Randall Square (in a business district),
2523 Opa Locka, 2525 Opa Locka, Boulevard Heights, Estates of Ft. Lauderdale, Fairway
Heights #2, Fairway Heights #4, Oakland Acres, Seminole Estates, Stardust, Sunshine
City, Sunshine Village, and University Lakes for 2009-2011.
18. §192.723 Distribution systems: Leakage surveys.
(a) Each operator of a distribution system shall conduct periodic leakage surveys in
accordance with this section.
(b) The type and scope of the leakage control program must be determined by the
nature of the operations and the local conditions, but it must meet the following
minimum requirements:
(1) A leakage survey with leak detector equipment must be conducted in business
districts, including tests of the atmosphere in gas, electric, telephone, sewer, and
water system manholes, at cracks in pavement and sidewalks, and at other locations
providing an opportunity for finding gas leaks, at intervals not exceeding 15 months,
but at least once each calendar year.
(2) A leakage survey with leak detector equipment must be conducted outside
business districts as frequently as necessary, but at least once every 5 calendar years
at intervals not exceeding 63 months. However, for cathodically unprotected
distribution lines subject to §192.465(e) on which electrical surveys for corrosion are
impractical, a leakage survey must be conducted at least once every 3 calendar years
at intervals not exceeding 39 months.
11



Suburban did not conduct periodic leakage surveys in accordance with §192.723.
Suburban had no records documenting that it conducted leak surveys at intervals not
exceeding 15 months, but at least once each calendar year at Randall Square. Furthermore,
Suburban had no records documenting that it conducted leak surveys at least once every
5 calendar years at intervals not exceeding 63 months at 2523 Opa Locka,
2525 Opa Locka, Fairway Heights #2, Fairway Heights #4, Oakland Acres, Seminole
Estates, Stardust, Sunshine City, Sunshine Village, and University Lakes.
19. §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.
§ 192.743 Pressure limiting and regulating stations: Capacity of relief devices.
(a) Pressure relief devices at pressure limiting stations and pressure regulating
stations must have sufficient capacity to protect the facilities to which they are
connected. Except as provided in §192.739(b), the capacity must be consistent with
the pressure limits of §192.201(a). This capacity must be determined at intervals not
exceeding 15 months, but at least once each calendar year, by testing the devices in
place or by review and calculations.
(b) If review and calculations are used to determine if a device has sufficient
capacity, the calculated capacity must be compared with the rated or experimentally
determined relieving capacity of the device for the conditions under which it
operates. After the initial calculations, subsequent calculations need not be made if
the annual review documents that parameters have not changed to cause the rated or
experimentally determined relieving capacity to be insufficient.
(c) If a relief device is of insufficient capacity, a new or additional device must be
installed to provide the capacity required by paragraph (a) of this section.
Suburban did not inspect and test its pressure limiting and regulating stations at intervals
not exceeding 15 months, but at least once each calendar year. Moreover, Suburban did
not determine the capacity at intervals not exceeding 15 months, but at least once each
calendar year, by testing the devices in place or by review and calculations.
Suburban did not have records demonstrating that it inspected, tested, or determined the
capacity of each pressure limiting and regulating station and its equipment at intervals not
exceeding 15 months, but at least once each calendar year at the following locations:
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– No records for calendar years 2009 – 2011 for 2523 Opa Locka, 2525 Opa Locka,
Fairway Heights #2, Fairway Heights #4, Oakland Acres, Randall Square, Stardust,
Sunshine City, and Sunshine Village.
– No records for calendar years 2009 – 2010 for Boulevard Heights, Estates of
Ft. Lauderdale, and Seminole Estates.
– No records for calendar years 2009 and 2011 for University Lakes.
20. §192.741 Pressure limiting and regulating stations: Telemetering or recording
gauges.
(a) Each distribution system supplied by more than one district pressure regulating
station must be equipped with telemetering or recording pressure gauges to indicate
the gas pressure in the district.
Suburban did not equip each distribution system supplied by more than one district
regulating station with telemetering or recording pressure gauges to indicate the gas
pressure in the district. Suburban had systems which were fed from more than one district
regulating station (i.e. regulator at each tank) which did not have telemetering or recording
pressure gauges. During the field inspection, the inspector identified this item at
Boulevard Heights, Fairway Heights #2, Oakland Acres, Stardust, and University Lakes.
21. §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 each valve which may be necessary for the safe
operation of its pipeline distribution system at intervals not exceeding 15 months, but at
least once each calendar year. Records reviewed during the inspection identified the
following:
– No records for calendar years 2009 – 2011: for 2523 Opa Locka, 2525 Opa Locka,
Fairway Heights #2, Fairway Heights #4, Oakland Acres, Randall Square, Stardust,
Sunshine City, and Sunshine Village.
– No records for 2010: Boulevard Heights, Estates of Ft. Lauderdale, and Seminole Estates.
22. §192.1005 What must a gas distribution operator (other than a master meter or
small LPG operator) do to implement this subpart?
No later than August 2, 2011 a gas distribution operator must develop and
implement an integrity management program that includes a written integrity
management plan as specified in §192.1007.
Suburban did not develop and implement an integrity management program that includes
a written integrity management plan as specified in §192.1007 by August 2, 2011. As of
the dates of the inspection, the operator’s plan was still being developed and had not yet
been implemented.
Under 49 United States Code, § 60122, Suburban is 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 and13



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 2-2012-0004W. 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
CC: Thomas Ross, Managing Director
Suburban Propane
6991 15th Street E
Sarasota, FL 34243-3277
Steve Watson, Customer Service Center Manager
Suburban Propane
1491 NE 130th ST
North Miami, FL 33161-4410
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