{"operation":"document","citation":"CPF 220130009W","title":"CLEARWATER CHRISTIAN COLLEGE — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-04-30","effective_on":null,"summary":"CLOSED warning letter citing 192.161(a), 192.625(f), 192.747.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220130009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220130009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220130009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220130009W","body":"Warning Letter involving CLEARWATER CHRISTIAN COLLEGE. PHMSA's enforcement data identifies the cited regulations as 192.161(a),  192.625(f),  192.747. The case was opened on 2013-04-30 and is reported as closed as of 2013-04-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220130009W_warning letter_04302013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220130009W/220130009W_warning%20letter_04302013.pdf\n\n220130009W_warning letter_04302013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220130009W/220130009W_warning%20letter_04302013_text.pdf\n\n220130009W_warning letter_04302013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 30, 2013\nMr. Roy Squires\nDirector of Physical Plant\nClearwater Christian College\n3400 Gulf-to-Bay Blvd.\nClearwater, FL 33759 CPF 2-2013-0009W\nDear Mr. Squires:\nOn March 19, 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety, pursuant to Chapter\n601 of 49 United States Code, inspected the Clearwater Christian College master meter and\ndownstream piping and facilities at 3400 Gulf-to-Bay Blvd., Clearwater, Florida.\nAs a result of the inspection, it appears that Clearwater Christian College has committed\nprobable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations.\nThe items inspected and the probable violations are as follows:\n1. §192.161 Supports and anchors.\n(a) Each pipeline and its associated equipment must have enough anchors or\nsupports to:\n(1) Prevent undue strain on connected equipment;\n(2) Resist longitudinal forces caused by a bend or offset in the pipe; and,\n(3) Prevent or damp out excessive vibration.\nAt the time of inspection, PHMSA inspectors found that the Clearwater Christian College\nmaster meter and its associated aboveground piping, regulator, and relief devices did not\nhave enough support to prevent undue strain on connected equipment. The master meter\nassembly could be moved from side to side and was not resistant to longitudinal forces.\n2. §192.625 Odorization of gas.\n... (f) To assure the proper concentration of odorant in accordance with this section,\neach operator must conduct periodic sampling of combustible gases using an\ninstrument capable of determining the percentage of gas in air at which the odor\nbecomes readily detectable. Operators of master meter systems may comply with\nthis requirement by-\n(1) Receiving written verification from their gas source that the gas has the proper\nconcentration of odorant; and\n(2) Conducting periodic \"sniff\" tests at the extremities of the system to confirm that\nthe gas contains odorant.\n\n\n\nClearwater Christian College did not present to the PHMSA inspector any records to\ndemonstrate that it had assured the proper concentration of odorant in its pipeline system\nby receiving written verification from its gas source that the gas has the proper\nconcentration of odorant or by conducting periodic \"sniff\" tests at the extremities of the\nsystem to confirm that the gas contains odorant.\n3. §192.747 Valve maintenance: Distribution systems.\n(a) Each valve, the use of which may be necessary for the safe operation of a\ndistribution system, must be checked and serviced at intervals not exceeding 15\nmonths, but at least once each calendar year.\n(b) Each operator must take prompt remedial action to correct any valve found\ninoperable, unless the operator designates an alternative valve.\nClearwater Christian College did not present to the PHMSA inspector any records to\ndemonstrate that it had checked and serviced its shut off (or key valve) which may be\nnecessary for the safe operation of its distribution system at intervals not exceeding 15\nmonths, but at least once each calendar year.\nUnder 49 United States Code, § 60122, Clearwater Christian College is subject to a civil\npenalty not to exceed $ 200,000 per violation per day the violation persists up to a maximum\nof $2,000,000 for a related series of violations. For violations occurring prior to\nJanuary 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a\nmaximum penalty not to exceed $1,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in the\nClearwater Christian College being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2013-0009W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n2","truncated":false,"body_characters":5380}