# SUNRISE APTS — Warning Letter

- **operation:** document
- **citation:** CPF 220140018W
- **title:** SUNRISE APTS — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-10-16
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.1015(a), 192.481(a), 192.625(f), 192.721(a), 192.723(a), 192.723(b)(2), 192.739(a), 192.747(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220140018W
**body:**

Warning Letter involving SUNRISE APTS. PHMSA's enforcement data identifies the cited regulations as 192.1015(a),  192.481(a),  192.625(f),  192.721(a),  192.723(a),  192.723(b)(2),  192.739(a),  192.747(a). The case was opened on 2014-10-16 and is reported as closed as of 2014-10-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220140018W_warning letter_10162014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140018W/220140018W_warning%20letter_10162014.pdf

220140018W_warning letter_10162014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140018W/220140018W_warning%20letter_10162014_text.pdf

220140018W_warning letter_10162014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 16, 2014
Ms. Lori McGriff
President
Emmer Development Corporation
2801 SW Archer Rd.
Gainesville, FL 32608
CPF 2-2014-0018W
Dear Ms. McGriff:
On June 18, 2014, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Southern Region, Office of Pipeline Safety (OPS), pursuant to
Chapter 601 of 49 United States Code, inspected the Sunrise Apartments records and facilities
at the Sunrise Apartments in Pensacola, Florida.
As a result of our investigation, it appears that Sunrise 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
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 The Sunrise 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 meters 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” test at the extremities of the system to confirm that
the gas contains odorant.
Sunrise 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 and by conducting periodic
"sniff" tests at the extremities of the system to confirm that the gas contains odorant.
3. §192.721 Distribution systems: Patrolling.
(a) The frequency of patrolling mains must be determined by the severity of the
conditions which could cause failure or leakage, and the consequent hazards to
public safety.
Sunrise Apartments did not present records to demonstrate that it conducted patrols of the
pipeline system mains.
4. §192.723 Distribution systems: Leakage surveys.
(a) Each operator of a distribution system shall conduct periodic leakage surveys in
accordance with this section.
(b) The type and scope of the leakage control program must be determined by the
nature of the operations and the local conditions, but it must meet the following
minimum requirements:
…(2) A leakage survey with leak detector equipment must be conducted outside
business districts as frequently as necessary, but at least once every 5 calendar years
at intervals not exceeding 63 months…
Sunrise Apartments did not present records to demonstrate that it conducted leakage
surveys of the pipeline system outside a business district at least once every 5 calendar
years at intervals not exceeding 63 months.
5. §192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and Pressure
regulating station and its equipment must be subjected at intervals not exceeding 15
months, but at least once each calendar year, to inspections and tests to determine
that it is-
(1) In good mechanical condition;
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(2) Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or relieve at the
correct pressure consistent with the pressure limits of §192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other conditions that
might prevent proper operation.
Sunrise Apartments did not present records to demonstrate that it inspected and tested the
pressure regulating device at intervals not exceeding 15 months, but at least once each
calendar year.
6. §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.
Sunrise Apartments did not present records to demonstrate that it checked and serviced
each valve necessary for the safe operation of its distribution system at intervals not
exceeding 15 months, but at least once each calendar year.
7. §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.
Sunrise Apartments did not present records to demonstrate that it had developed and
implemented an Integrity Management program.
Under 49 United States Code, §60122, Sunrise 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 Sunrise
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 2-2014-0018W. 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
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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
cc: Ms. Kim Sawyer
Manager
Sunrise Apartments
4350 W. Fairfield Drive
Pensacola, FL 32505
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