{"operation":"document","citation":"CPF 220140017W","title":"PENSACOLA VILLAGE APARTMENTS LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-10-14","effective_on":null,"summary":"CLOSED warning letter citing 192.1015(a), 192.481(a), 192.625(f), 192.739(a), 192.747(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220140017W","body":"Warning Letter involving PENSACOLA VILLAGE APARTMENTS LLC. PHMSA's enforcement data identifies the cited regulations as 192.1015(a),  192.481(a),  192.625(f),  192.739(a),  192.747(a). The case was opened on 2014-10-14 and is reported as closed as of 2014-10-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220140017W_warning letter_10142014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140017W/220140017W_warning%20letter_10142014.pdf\n\n220140017W_warning letter_10142014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140017W/220140017W_warning%20letter_10142014_text.pdf\n\n220140017W_warning letter_10142014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 14, 2014\nMr. John Dean\nPresident\nPensacola Village Apartments\n500 East Fairfield Drive\nPensacola, FL 32503\nCPF 2-2014-0017W\nDear Mr. Dean:\nOn June 3, 2014, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS), pursuant to\nChapter 601 of 49 United States Code, inspected the Pensacola Village Apartments’ natural\ngas master meter pipeline system and records at the Pensacola Village Apartments in\nPensacola, Florida.\nAs a result of our investigation, it appears that the Pensacola Village Apartments has\ncommitted probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal\nRegulations. The items inspected and the probable violations are as follows:\n1. §192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but with\nintervals not exceeding 39 months\nOffshore At least once each calendar year, but with intervals\nnot exceeding 15 months\nPensacola Village Apartments did not present records to demonstrate that it had inspected\nits onshore pipeline exposed to the atmosphere for evidence of atmospheric corrosion at\nleast once every 3 calendar years, but with intervals not exceeding 39 months.\n\n\n\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 meters 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” test at the extremities of the system to confirm that\nthe gas contains odorant.\nPensacola Village Apartments did not present records to demonstrate that it had assured\nthe proper concentration of odorant in its pipeline system by receiving written verification\nfrom its gas source that the gas has the proper concentration of odorant and by conducting\nperiodic \"sniff\" tests at the extremities of the system to confirm that the gas contains\nodorant.\n3. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests to determine\nthat it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at the\ncorrect pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nPensacola Village Apartments did not present records to demonstrate that it inspected and\ntested the pressure regulating device at intervals not exceeding 15 months, but at least\nonce 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.\nPensacola Village Apartments did not present records to demonstrate that it checked and\nserviced each valve necessary for the safe operation of its distribution system at intervals\nnot exceeding 15 months, but at least once 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\n2\n\n\n\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.\nPensacola Village Apartments did not present records to demonstrate that it had developed\nand implemented an IM program.\nUnder 49 United States Code, §60122, Pensacola Village Apartments 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\nPensacola Village 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 2-2014-0017W. 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\n3","truncated":false,"body_characters":6788}