# CLEARWATER GAS SYSTEM — Warning Letter

- **operation:** document
- **citation:** CPF 220130004W
- **title:** CLEARWATER GAS SYSTEM — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-04-02
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.743(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220130004w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220130004w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220130004w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220130004W
**body:**

Warning Letter involving CLEARWATER GAS SYSTEM. PHMSA's enforcement data identifies the cited regulation as 192.743(a). The case was opened on 2013-04-02 and is reported as closed as of 2013-04-02. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220130004W_warning letter_04022013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220130004W/220130004W_warning%20letter_04022013.pdf

220130004W_warning letter_04022013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220130004W/220130004W_warning%20letter_04022013_text.pdf

220130004W_warning letter_04022013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 2, 2013
Mr. Charles Warrington
Managing Director
City of Clearwater Gas System
400 N. Myrtle Avenue
Clearwater, FL 33755
CPF 2-2013-0004W
Dear Mr. Warrington:
From March 18-19, 2013, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Southern Region, Office of Pipeline Safety, pursuant to Chapter
601 of 49 United States Code, inspected the City of Clearwater (Clearwater) liquefied
petroleum gas (LPG) pipeline system records in Clearwater and facilities in Tarpon Springs
and Port Richey, Florida.
As a result of the inspection, it appears that Clearwater has committed a probable violation of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected
and the probable violation is as follows:
1. §192.743 Pressure limiting and regulating stations: Testing 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.
Clearwater did not provide any records to demonstrate that the capacities of its
pressure regulators with internal relief valves were confirmed, either by testing the
devices in place or by review and calculations, in calendar years 2011 and 2012.
Under 49 United States Code, §60122, City of Clearwater is subject to a civil penalty not to
exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000
for a related series of violations. For violations occurring prior to January 4, 2012, the
maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty



not to exceed $1,000,000 for a 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 identified in this letter. Failure to do so will result in City of
Clearwater 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 2-2013-0004W. 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
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