{"operation":"document","citation":"CPF 220140005W","title":"GAINESVILLE REGIONAL UTIL GAS DEPT — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-07-30","effective_on":null,"summary":"CLOSED warning letter citing 192.1003, 192.605(a), 192.721(b)(2), 192.805(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220140005W","body":"Warning Letter involving GAINESVILLE REGIONAL UTIL GAS DEPT. PHMSA's enforcement data identifies the cited regulations as 192.1003,  192.605(a),  192.721(b)(2),  192.805(a). The case was opened on 2014-07-30 and is reported as closed as of 2014-07-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220140005W_warning letter_07302014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140005W/220140005W_warning%20letter_07302014.pdf\n\n220140005W_warning letter_07302014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140005W/220140005W_warning%20letter_07302014_text.pdf\n\n220140005W_warning letter_0730201_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140005W/220140005W_warning%20letter_0730201_text.pdf\n\n220140005W_warning letter_0730201_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 30, 2014\nMs. Kathy Viehe\nInterim General Manager\nGainesville Regional Utilities\n301 SE 4th Avenue\nGainesville, FL 32601\nCPF 2-2014-0005W\nDear Ms.Viehe:\nOn May 19-23, 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 facilities, records, and procedures of Gainesville\nRegional Utilities (GRU) liquefied petroleum gas (LPG) pipeline systems in Gainesville,\nFlorida. As a result of the inspection, it appears that GRU has committed probable violations\nof the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nGRU operates both natural gas and LPG distribution pipeline systems using the same\nprocedural manual for operations, maintenance, and emergencies. The manual was\nmissing procedures specific to LPG operations, maintenance, and/or emergencies.\n\n\n\n2. §192.721 Distribution systems: Patrolling.\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 ½ months, but at least\ntwice each calendar year.\nGRU did not provide records to demonstrate that it had patrolled the mains on its LPG\npipeline system outside business districts in calendar years 2012 and 2013 at intervals not\nexceeding 7½ months, but at least twice each calendar year.\n3. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) Identify covered tasks;\nGRU operates both natural gas and LPG distribution pipeline systems using the same\nOperation Qualification (OQ) program. The OQ program was missing covered tasks\nspecific to LPG.\n4. § 192.1003 What do the regulations in this subpart cover?\nGeneral. This subpart prescribes minimum requirements for an IM program for any\ngas distribution pipeline covered under this part, including liquefied petroleum gas\nsystems. A gas distribution operator, other than a master meter operator or a small\nLPG operator, must follow the requirements in §§ 192.1005-192.1013 of this subpart.\nA master meter operator or small LPG operator of a gas distribution pipeline must\nfollow the requirements in § 192.1015 of this subpart.\nGRU operates both natural gas and LPG distribution pipeline systems using the same\nDistribution Integrity Management Program (DIMP) but there were no references to\nspecific LPG requirements in the DIMP.\nUnder 49 United States Code, § 60122, GRU is subject to a civil penalty not to exceed\n$ 200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in the GRU being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2014-0005W. 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\n2\n\n\n\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: Anthony Hewitt\nGas T & D Manager\n3805 N.W. 97th Blvd.\nGainesville, FL 32606\n3\n\n220140005W_warning letter_07302014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 30, 2014\nMs. Kathy Viehe\nInterim General Manager\nGainesville Regional Utilities\n301 SE 4th Avenue\nGainesville, FL 32601\nCPF 2-2014-0005W\nDear Ms.Viehe:\nOn May 19-23, 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 facilities, records, and procedures of Gainesville\nRegional Utilities (GRU) liquefied petroleum gas (LPG) pipeline systems in Gainesville,\nFlorida. As a result of the inspection, it appears that GRU has committed probable violations\nof the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nGRU operates both natural gas and LPG distribution pipeline systems using the same\nprocedural manual for operations, maintenance, and emergencies. The manual was\nmissing procedures specific to LPG operations, maintenance, and/or emergencies.\n\n\n\n2. §192.721 Distribution systems: Patrolling.\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 ½ months, but at least\ntwice each calendar year.\nGRU did not provide records to demonstrate that it had patrolled the mains on its LPG\npipeline system outside business districts in calendar years 2012 and 2013 at intervals not\nexceeding 7½ months, but at least twice each calendar year.\n3. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) Identify covered tasks;\nGRU operates both natural gas and LPG distribution pipeline systems using the same\nOperation Qualification (OQ) program. The OQ program was missing covered tasks\nspecific to LPG.\n4. § 192.1003 What do the regulations in this subpart cover?\nGeneral. This subpart prescribes minimum requirements for an IM program for any\ngas distribution pipeline covered under this part, including liquefied petroleum gas\nsystems. A gas distribution operator, other than a master meter operator or a small\nLPG operator, must follow the requirements in §§ 192.1005-192.1013 of this subpart.\nA master meter operator or small LPG operator of a gas distribution pipeline must\nfollow the requirements in § 192.1015 of this subpart.\nGRU operates both natural gas and LPG distribution pipeline systems using the same\nDistribution Integrity Management Program (DIMP) but there were no references to\nspecific LPG requirements in the DIMP.\nUnder 49 United States Code, § 60122, GRU is subject to a civil penalty not to exceed\n$ 200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in the GRU being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2014-0005W. 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\n2\n\n\n\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: Anthony Hewitt\nGas T & D Manager\n3805 N.W. 97th Blvd.\nGainesville, FL 32606\n3","truncated":false,"body_characters":10759}