{"operation":"document","citation":"CPF 220140019W","title":"MOORINGS ASSOCIATES, LTD — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-11-06","effective_on":null,"summary":"CLOSED warning letter citing 192.1015(a), 192.455(a)(1), 192.455(a)(2), 192.481(a), 192.625(f)(1), 192.625(f)(2), 192.721(a), 192.723(a), 192.723(b)(1), 192.747(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140019w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140019w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220140019w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220140019W","body":"Warning Letter involving MOORINGS ASSOCIATES, LTD. PHMSA's enforcement data identifies the cited regulations as 192.1015(a),  192.455(a)(1),  192.455(a)(2),  192.481(a),  192.625(f)(1),  192.625(f)(2),  192.721(a),  192.723(a),  192.723(b)(1),  192.747(a). The case was opened on 2014-11-06 and is reported as closed as of 2014-11-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220140019W_warning letter_11062014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140019W/220140019W_warning%20letter_11062014.pdf\n\n220140019W_warning letter_11062014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220140019W/220140019W_warning%20letter_11062014_text.pdf\n\n220140019W_warning letter_11062014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 6, 2014\nMs. Lori McGriff\nEmmer Development Corporation\n2801 SW Archer Rd.\nGainesville, FL 32608\nCPF 2-2014-0019W\nDear Ms. McGriff:\nOn June 17, 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 Moorings Apartments natural gas master\nmeter system records and master meter pipeline system at the Moorings Apartments in\nPensacola, Florida.\nAs a result of our investigation, it appears that Moorings 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. §192.455 External corrosion control: Buried or submerged pipelines installed after\nJuly 31, 1971.\n(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or\nsubmerged pipeline installed after July 31, 1971, must be protected against external\ncorrosion, including the following:\n(1) It must have an external protective coating meeting the requirements of\n§192.461.\n(2) It must have a cathodic protection system designed to protect the pipeline in\naccordance with this subpart, installed and placed in operation within 1 year after\ncompletion of construction.\nThe Moorings Apartments 1) did not cathodically protect its pipeline system and 2) the\npipeline did not have an external protective coating. The Moorings Apartments did not\nprovide documentation demonstrating that it installed a cathodic protection system, during\nthe inspection pipe-to-soil readings were taken which did not show the pipeline was\n\n\n\n2. cathodically protected, and pipe was exposed and observed to not have an external\nprotective coating applied.\n§192.481 Atmospheric corrosion control: Monitoring.\nEach operator must inspect each pipeline or portion of pipeline that is exposed to\natmosphere for evidence of atmospheric corrosion, as follows:\nThen the frequency of inspection is:\nIf the pipeline is located: Onshore At least once every 3 calendar years, but with\nintervals not exceeding 39 months\nOffshore At least once each calendar year, but with\nintervals not exceeding 15 months\nThe Moorings Apartments did not present records to demonstrate that it had inspected its\nonshore pipeline exposed to the atmosphere for evidence of atmospheric corrosion at least\nonce every 3 calendar years, but with intervals not exceeding 39 months.\n3. §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.\nThe Moorings Apartments did not present records to demonstrate that it had assured the\nproper 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.\n4. §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.\nThe Moorings Apartments did not present records to demonstrate that it conducted patrols\nof the pipeline system mains.\n5. §192.723 Distribution systems: Leakage surveys.\n(a) Each operator of a distribution system shall conduct periodic leakage surveys in\naccordance with this section.\n2\n\n\n\n(b) The type and scope of the leakage control program must be determined by the\nnature of the operations and the local conditions, but it must meet the following\nminimum requirements:\n(1) A leakage survey with leak detector equipment must be conducted in business\ndistricts, including tests of the atmosphere in gas, electric, telephone, sewer, and\nwater system manholes, at cracks in pavement and sidewalks, and at other locations\nproviding an opportunity for finding gas leaks, at intervals not exceeding 15 months,\nbut at least once each calendar year.\nThe Moorings Apartments did not present records to demonstrate that it conducted\nleakage surveys of the pipeline system at intervals not exceeding 15 months, but at least\nonce each calendar year.\n6. §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.\nThe Moorings 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.\n7. §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.\nThe Moorings Apartments did not present records to demonstrate that it had developed\nand implemented an Integrity Management program.\nUnder 49 United States Code, §60122, Moorings Apartments is subject to a civil penalty not\nto 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\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\nMoorings 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 2-2014-0019W. 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\n3\n\n\n\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: The Moorings Associates, LTD\nMs. Mary Lou Derozier\n8491 Old Spanish Trail Road\nPensacola, FL 32514\n4","truncated":false,"body_characters":8253}