{"operation":"document","citation":"CPF 220130017W","title":"CLYDEBANK ROYAL STEWART ARMS — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-05-02","effective_on":null,"summary":"CLOSED warning letter citing 192.455(a)(2), 192.457(b)(3), 192.481(a), 192.625(f), 192.721, 192.747.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220130017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220130017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220130017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220130017W","body":"Warning Letter involving CLYDEBANK ROYAL STEWART ARMS. PHMSA's enforcement data identifies the cited regulations as 192.455(a)(2),  192.457(b)(3),  192.481(a),  192.625(f),  192.721,  192.747. The case was opened on 2013-05-02 and is reported as closed as of 2013-05-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220130017W_warning letter_05022013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220130017W/220130017W_warning%20letter_05022013.pdf\n\n220130017W_warning letter_05022013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220130017W/220130017W_warning%20letter_05022013_text.pdf\n\n220130017W_warning letter_05022013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 2, 2013\nMs. Sharon Wilson\nProperty Manager\nClydebank Royal Stewart Arms\n1 Royal Stewart Parkway\nDunedin, FL 34698\nCPF 2-2013-0017W\nDear Ms. Wilson:\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 Clydebank Royal Stewart Arms master meter and\ndownstream piping and facilities at 1 Royal Stewart Parkway, Dunedin, Florida.\nAs a result of the inspection, it appears that Clydebank Royal Stewart Arms 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. §192.455 External corrosion control: Buried or submerged pipelines installed after\nJuly 31, 1971.\n(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or\nsubmerged pipeline installed after July 31, 1971, must be protected against external\ncorrosion, including the following:\n... (2) It must have a cathodic protection system designed to protect the pipeline in\naccordance with this subpart, installed and placed in operation within 1 year after\ncompletion of construction.\nClydebank Royal Stewart Arms did not install, and place in operation within one year\nafter completion of construction, a cathodic protection system designed to protect a buried\npipeline against external corrosion.\nClydebank Royal Stewart Arms has 1480 feet of 2-6-inch BIW coated buried pipe. Some\nof this pipe was installed after July 3, 1971, but Clydebank Royal Stewart Arms has not\ninstalled a cathodic protection system designed to protect the pipeline against external\ncorrosion.\n\n\n\nIf the pipeline is located: Onshore Offshore 2. §192.457 External corrosion control: Buried or submerged pipelines installed\nbefore August 1, 1971.\n…. (b) Except for cast iron or ductile iron, each of the following buried or\nsubmerged pipelines installed before August 1, 1971, must be cathodically protected\nin accordance with this subpart in areas in which active corrosion is found:\n…. (3) Bare or coated distribution line.\nClydebank Royal Stewart Arms has 1480 feet of 2-6-inch BIW coated buried pipe. Some\nof this pipe was installed before August 1, 1971, but Clydebank Royal Stewart Arms has\nnot installed a cathodic protection system designed to protect the pipeline against external\ncorrosion. Moreover, Clydebank Royal Stewart Arms did not present to the PHMSA\ninspector any records to demonstrate that there are no areas of active corrosion on these\nlines. The methods and required time intervals an operator must use to determine if areas\nof active corrosion exist on its pipelines are described in §192.465(e).\n3. §192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to\nthe atmosphere for evidence of atmospheric corrosion, as follows:\nThen the frequency of inspection is:\nAt least once every 3 calendar years, but with\nintervals not exceeding 39 months\nAt least once each calendar year, but with intervals\nnot exceeding 15 months\n... (c) If atmospheric corrosion is found during an inspection, the operator must\nprovide protection against the corrosion as required by Sec. 192.479.\nClydebank Royal Stewart Arms did not inspect its onshore pipeline exposed to the\natmosphere for evidence of atmospheric corrosion at least once every 3 calendar years, but\nwith intervals not exceeding 39 months. Moreover, Clydebank Royal Stewart Arms did\nnot provide protection against atmospheric corrosion in accordance with §192.479, which\nrequires pipelines to be properly cleaned and coated to prevent atmospheric corrosion.\nThe PHMSA inspector observed and photographed master meter with associated piping\nthat showed signs of atmospheric corrosion. This portion of pipeline had not been\nproperly cleaned and coated to prevent atmospheric corrosion.\n4. §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\n2\n\n\n\nconcentration of odorant; and\n(2) Conducting periodic \"sniff\" tests at the extremities of the system to confirm that\nthe gas contains odorant.\nClydebank Royal Stewart Arms 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.\n5. §192.721 Distribution systems: Patrolling.\n(a) The frequency of patrolling mains must be determined by the severity of the\nconditions which could cause failure or leakage, and the consequent hazards to\npublic safety.\n(b) Mains in places or on structures where anticipated physical movement or\nexternal loading could cause failure or leakage must be patrolled -\n(1) In business districts, at intervals not exceeding 4 1/2 months, but at least four\ntimes each calendar year; and\n(2) Outside business districts, at intervals not exceeding 7 1/2 months, but at least\ntwice each calendar year.\nClydebank Royal Stewart Arms did not present to the PHMSA inspector any records to\nshow it patrolled its distribution system in the residential area at intervals not exceeding\n7½ months, but at least twice each calendar year.\n6. §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.\nClydebank Royal Stewart Arms 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, Clydebank Royal Stewart Arms 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\nClydebank Royal Stewart Arms being subject to additional enforcement action.\n3\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2013-0017W. 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\n4","truncated":false,"body_characters":8816}