{"operation":"document","citation":"CPF 220140003W","title":"PK MANAGEMENT, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-07-02","effective_on":null,"summary":"CLOSED warning letter citing 192.1015(a), 192.465(d), 192.625(f)(1), 192.625(f)(2), 192.721(a), 192.721(b)(2), 192.747.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220140003W","body":"Warning Letter involving PK MANAGEMENT, LLC. PHMSA's enforcement data identifies the cited regulations as 192.1015(a),  192.465(d),  192.625(f)(1),  192.625(f)(2),  192.721(a),  192.721(b)(2),  192.747. The case was opened on 2014-07-02 and is reported as closed as of 2014-07-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220140003W_Warning letter_07022014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140003W/220140003W_Warning%20letter_07022014.pdf\n\n220140003W_Warning letter_07022014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140003W/220140003W_Warning%20letter_07022014_text.pdf\n\n220140003W_Warning letter_07022014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 2, 2014\nMs. Jenne McLain-Bankhead\nProperty Manager\nPK Management, LLC\n26301 Curtis Wright Parkway, Suite 110\nRichmond Heights, OH 44143\nCPF 2-2014-0003W\nDear Ms. McLain-Bankhead:\nOn May 22, 2014, 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 Forest Green Apartments master meter and\ndownstream piping and facilities at 3501 N.E. 15th Street, Gainesville, Florida.\nAs a result of the inspection, it appears that Forest Green Apartments has committed probable\nviolations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The\nitems inspected and the probable violations are as follows:\n1. §192.465 External corrosion control: Monitoring\n... (d) Each operator shall take prompt remedial action to correct any deficiencies\nindicated by the monitoring.\nForest Green Apartments did not take prompt remedial action to correct deficiencies\nindicated by the external corrosion control monitoring of its pipeline system.\nA review of Forest Green Apartments’ corrosion control monitoring records for three\nyears (2012 - 2014) revealed low1 pipe-to-soil (p/s) readings. Table 1 includes the p/s\nreadings taken on the dates shown at various locations along the Forest Green Apartments\npipeline system. Every reading shown in the table fails to meet the criteria for cathodic\nprotection contained in the federal pipeline safety regulations. Yet, at the time of the\nPHMSA inspection, Forest Green Apartments had not taken remedial actions to correct\nthese deficiencies.\n1 The criteria for cathodic protection are contained in 49 CFR Part 192, Appendix D. The criteria being\nreferenced in this letter is negative (cathodic) voltage of at least 850mV with reference to a saturated copper-\ncopper sulfate half-cell. Accordingly, a “low” p/s reading is a reading less negative than 850mV.\n\n\n\nJan 24, 2012 Feb 7, 2013 Jan 15, 2014\nBuilding N Building P - 530 mV - 730 mV - 550 mV\n- 600 mV - 670 mV\nBuilding T - 700 mV Building S - 630 mV - 630 mV - 630 mV\n- 730 mV - 700 mV - 640 mV\nBuilding R - 670 mV - 600 mV - 700 mV\nBuilding W - 590 mV - 630 mV - 650 mV\nBuilding V - 520 mV - 530 mV - 630 mV\nTable 1\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.\nForest Green Apartments did not present to the PHMSA inspector records to demonstrate\nthat it had assured the proper concentration of odorant in its pipeline system by receiving\nwritten verification from its gas source that the gas has the proper concentration of\nodorant or by conducting periodic \"sniff\" tests at the extremities of the system to confirm\nthat the gas contains odorant.\n3. §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… (2) Outside business districts, at intervals not exceeding 7 1/2 months, but at least\ntwice each calendar year.\nForest Green Apartments did not present to the PHMSA inspector any records to show it\npatrolled its distribution system in the residential area at intervals not exceeding 7½\nmonths, but at least twice each calendar year.\n4. §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\n2\n\n\n\ninoperable, unless the operator designates an alternative valve.\nForest Green Apartments did not present to the PHMSA inspector records to demonstrate\nthat it had checked and serviced its shut off (or key valve) which may be necessary for the\nsafe operation of its distribution system at intervals not exceeding 15 months, but at least\nonce each calendar year.\n5. §192.1015 What must a master meter or small liquefied petroleum gas (LPG)\noperator do to implement this subpart?\n(a) General. No later than August 2, 2011 the operator of a master meter system or a\nsmall LPG operator must develop and implement an IM program that includes a\nwritten IM plan as specified in paragraph (b) of this section. The IM program for\nthese pipelines should reflect the relative simplicity of these types of pipelines.\nForrest Green Apartments did not present to the PHMSA inspector records to demonstrate\nthat it had developed and implemented an Integrity Management program.\nUnder 49 United States Code, § 60122, Forest Green Apartments is subject to a civil penalty\nnot to exceed $ 200,000 per violation per day the violation persists up to a maximum of\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012,\nthe maximum penalty may not exceed $100,000 per violation per day, with a maximum\npenalty not to exceed $1,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in the\nForest Green Apartments 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 2-2014-0003W. 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\ncc: Shelandarae Adam-Hudson\nProperty Manager\n3501 N.E. 15th Street\nGainesville, Florida 32609\n3","truncated":false,"body_characters":7664}