# MACEDONIA GARDEN APARTMENTS — Warning Letter

- **operation:** document
- **citation:** CPF 220150001W
- **title:** MACEDONIA GARDEN APARTMENTS — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-02-18
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.1015(a), 192.455(a), 192.481, 192.625(f), 192.721(a), 192.723(a), 192.723(b)(1), 192.747(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220150001W
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Warning Letter involving MACEDONIA GARDEN APARTMENTS. PHMSA's enforcement data identifies the cited regulations as 192.1015(a),  192.455(a),  192.481,  192.625(f),  192.721(a),  192.723(a),  192.723(b)(1),  192.747(a). The case was opened on 2015-02-18 and is reported as closed as of 2015-02-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220150001W_warning letter_02182015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220150001W/220150001W_warning%20letter_02182015.pdf

220150001W_warning letter_02182015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220150001W/220150001W_warning%20letter_02182015_text.pdf

220150001W_warning letter_02182015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 18, 2015
Ms. Elizabeth Merrill
Macedonia Garden Apartments LLC
1722 W. 17th Street
Panama City, FL 32405
CPF 2-2015-0001W
Dear Ms. Merrill:
On August 13, 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 Macedonia Garden Apartments natural
gas master meter system records and pipeline system at the Macedonia Garden Apartments in
Panama City, Florida.
As a result of our investigation, it appears that Macedonia Garden 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. §192.455 External corrosion control: Buried or submerged pipelines installed after
July 31, 1971.
(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or
submerged pipeline installed after July 31, 1971, must be protected against external
corrosion, including the following:
(1) It must have an external protective coating meeting the requirements of
§192.461.
(2) It must have a cathodic protection system designed to protect the pipeline in
accordance with this subpart, installed and placed in operation within 1 year after
completion of construction.
The Macedonia Garden Apartments did not provide documentation demonstrating that it
had installed a cathodic protection system on its buried pipeline system.



2. §192.481 Atmospheric corrosion control: Monitoring.
Each operator must inspect each pipeline or portion of pipeline that is exposed to
atmosphere for evidence of atmospheric corrosion, as follows:
If the pipeline is located: Then the frequency of inspection is:
Onshore At least once every 3 calendar years, but with
intervals not exceeding 39 months
Offshore At least once each calendar year, but with
intervals not exceeding 15 months
The Macedonia Garden 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.
3. §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.
The Macedonia Garden 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.
4. §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.
The Macedonia Garden Apartments did not present records to demonstrate that it
conducted patrols of the pipeline system mains.
5. §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:
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(1) A leakage survey with leak detector equipment must be conducted in business
districts, including tests of the atmosphere in gas, electric, telephone, sewer, and
water system manholes, at cracks in pavement and sidewalks, and at other locations
providing an opportunity for finding gas leaks, at intervals not exceeding 15 months,
but at least once each calendar year.
The Macedonia Garden Apartments did not present records to demonstrate that it
conducted leakage surveys of the pipeline system 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.
The Macedonia Garden 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.
The Macedonia Garden Apartments did not present records to demonstrate that it had
developed and implemented an Integrity Management program.
Under 49 United States Code, §60122, Macedonia Garden 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
Macedonia Garden 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 2-2015-0001W. 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
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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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