# EASTSIDE GARDEN & TERRACE APARTMENTS — Warning Letter

- **operation:** document
- **citation:** CPF 220140008W
- **title:** EASTSIDE GARDEN & TERRACE APARTMENTS — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-08-11
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.1015(a), 192.481(a), 192.481(c), 192.625(f)(1), 192.625(f)(2), 192.721(b)(2), 192.747(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220140008W
**body:**

Warning Letter involving EASTSIDE GARDEN & TERRACE APARTMENTS. PHMSA's enforcement data identifies the cited regulations as 192.1015(a),  192.481(a),  192.481(c),  192.625(f)(1),  192.625(f)(2),  192.721(b)(2),  192.747(a). The case was opened on 2014-08-11 and is reported as closed as of 2014-08-11. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220140008W_warning letter_08112014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140008W/220140008W_warning%20letter_08112014.pdf

220140008W_warning letter_08112014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140008W/220140008W_warning%20letter_08112014_text.pdf

220140008W_warning letter_08112014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 11, 2014
Ms. Kimberley Mundle
Property Manager
Eastside Gardens & Terrace Apartments
1212 East 1st Street
Jacksonville, FL 32206
CPF 2-2014-0008W
Dear Ms. Mundle:
On June 17, 2014, 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 Eastside Gardens & Terrace Apartments master
meters and downstream piping and facilities. The Eastside Gardens Apartment’s master
meter was located at 1212 East 1st Street, Jacksonville, FL, and the Eastside Terrace
Apartment’s master meter was located at 1230 East 7th Street, Jacksonville, FL.
As a result of the inspection, it appears that Eastside Gardens & Terrace Apartments has
committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal
Regulations. The items inspected and the probable violations are as follows:
1. §192.481 Atmospheric corrosion control: Monitoring.
(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to
the atmosphere for evidence of atmospheric corrosion, as follows:
Then the frequency of inspection is:
At least once every 3 calendar years, but with intervals
not exceeding 39 months
At least once each calendar year, but with intervals not
exceeding 15 months
If the pipeline is located: Onshore Offshore ... (c) If atmospheric corrosion is found during an inspection, the operator must
provide protection against the corrosion as required by Sec. 192.479.



Eastside Gardens and Terrace Apartments did not present records to demonstrate that it
had inspected its onshore pipeline exposed to the atmosphere for evidence of atmospheric
corrosion at least once every 3 calendar years, but with intervals not exceeding 39 months.
2. §192.625 Odorization of gas.
... (f) To assure the proper concentration of odorant in accordance with this section,
each operator must conduct periodic sampling of combustible gases using an
instrument capable of determining the percentage of gas in air at which the odor
becomes readily detectable. Operators of master meter systems may comply with
this requirement by-
(1) Receiving written verification from their gas source that the gas has the proper
concentration of odorant; and
(2) Conducting periodic "sniff" tests at the extremities of the system to confirm that
the gas contains odorant.
Eastside Gardens and Terrace Apartments did not present records to demonstrate that it
had assured the proper concentration of odorant in its pipeline system by receiving written
verification from its gas source that the gas has the proper concentration of odorant or by
conducting periodic "sniff" tests at the extremities of the system to confirm that the gas
contains odorant.
3. §192.721 Distribution systems: Patrolling.
… (b) Mains in places or on structures where anticipated physical movement or
external loading could cause failure or leakage must be patrolled -
… (2) Outside business districts, at intervals not exceeding 7 1/2 months, but at least
twice each calendar year.
Eastside Gardens and Terrace Apartments did not present records to show it had patrolled
its distribution system in the residential area at intervals not exceeding 7½ months, but at
least twice each calendar year.
4. §192.747 Valve maintenance: Distribution systems.
(a) Each valve, the use of which may be necessary for the safe operation of a
distribution system, must be checked and serviced at intervals not exceeding 15
months, but at least once each calendar year.
Eastside Gardens and Terrace Apartments did not present records to demonstrate that it
had checked and serviced its shut off (or key valve) which may be necessary for the safe
operation of its distribution system at intervals not exceeding 15 months, but at least once
each calendar year.
5. §192.1015 What must a master meter or small liquefied petroleum gas (LPG)
operator do to implement this subpart?
(a) General. No later than August 2, 2011 the operator of a master meter system or
a small LPG operator must develop and implement an IM program that includes a
written IM plan as specified in paragraph (b) of this section. The IM program for
these pipelines should reflect the relative simplicity of these types of pipelines.
2



Eastside Gardens and Terrace Apartments did not present records to demonstrate that it
had developed and implemented an IM program.
Under 49 United States Code, § 60122, Eastside Gardens and Terrace Apartments 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 items identified in this letter. Failure to do so will result in the
Eastside Gardens and Terrace Apartments 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 2-2014-0008W. 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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