{"operation":"document","citation":"CPF 220150002W","title":"ROYAL ARMS GARDEN APARTMENTS — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-02-19","effective_on":null,"summary":"CLOSED warning letter citing 192.1015(a), 192.455(a), 192.481, 192.625(f), 192.721(a), 192.747(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220150002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220150002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220150002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220150002W","body":"Warning Letter involving ROYAL ARMS 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),  192.747(a). The case was opened on 2015-02-19 and is reported as closed as of 2015-02-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220150002W_warning letter_02192015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220150002W/220150002W_warning%20letter_02192015.pdf\n\n220150002W_warning letter_02192015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220150002W/220150002W_warning%20letter_02192015_text.pdf\n\n220150002W_warning letter_02192015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 19, 2015\nMs. Brenda Zopp\nRoyal Arms Garden Apartments LLC\n1420 Balboa Ave.\nPanama City, FL 32401\nCPF 2-2015-0002W\nDear Ms. Zopp:\nOn August 13, 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 Royal Arms Garden Apartments natural\ngas master meter system records and master meter pipeline system at the Royal Arms Garden\nApartments in Panama City, Florida.\nAs a result of our investigation, it appears that Royal Arms Garden Apartments has committed\nprobable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations.\nThe items 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 Royal Arms Garden Apartments did not provide documentation demonstrating that it\nhad installed a cathodic protection system on its buried pipeline system.\n\n\n\n2. §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:\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\nintervals not exceeding 15 months\nThe Royal Arms Garden Apartments did not present records to demonstrate that it had\ninspected its onshore pipeline exposed to the atmosphere for evidence of atmospheric\ncorrosion at least once 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 Royal Arms Garden Apartments did not present records to demonstrate that it had\nassured the proper concentration of odorant in its pipeline system by receiving written\nverification from its gas source that the gas has the proper concentration of odorant or by\nconducting periodic \"sniff\" tests at the extremities of the system to confirm that the gas\ncontains odorant.\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 Royal Arms Garden Apartments did not present records to demonstrate that it\nconducted patrols of the pipeline system mains.\n5. §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.\n2\n\n\n\nThe Royal Arms Garden Apartments did not present records to demonstrate that it\nchecked and serviced each valve necessary for the safe operation of its distribution system\nat intervals not exceeding 15 months, but at least once each calendar year.\n6. §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 Royal Arms Garden Apartments did not present records to demonstrate that it had\ndeveloped and implemented an Integrity Management program.\nUnder 49 United States Code, §60122, Royal Arms Garden 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\nRoyal Arms Garden 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 2-2015-W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why\nyou 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":6949}