{"operation":"document","citation":"CPF 22025001WL","title":"AMERIGAS PROPANE LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-12-04","effective_on":null,"summary":"CLOSED warning letter citing 192.465(d), 192.605(a), 192.615(c), 192.625(f), 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025001wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025001wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22025001wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22025001WL","body":"Warning Letter involving AMERIGAS PROPANE LP. PHMSA's enforcement data identifies the cited regulations as 192.465(d),  192.605(a),  192.615(c),  192.625(f),  192.739(a). The case was opened on 2025-12-04 and is reported as closed as of 2025-12-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22025001WL_Warning Letter_12042025_(23-293748).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22025001WL/22025001WL_Warning%20Letter_12042025_(23-293748).pdf\n\n22025001WL_Warning Letter_12042025_(23-293748)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22025001WL/22025001WL_Warning%20Letter_12042025_(23-293748)_text.pdf\n\n22025001WL_Warning Letter_12042025_(23-293748)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n230 Peachtree Street N.W.\nSuite 2100\nAtlanta, GA 30303\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: Michael.Sharp@amerigas.com;\npamela.cannon@amerigas.com; chad.krouse@amerigas.com\nDecember 4, 2025\nMichael Sharp\nChief Executive Officer\nAmeriGas Propane, L.P.\n500 North Gulph Road\nKing of Prussia, PA 19406\nCPF 2-2025-001-WL\nDear Mr. Sharp:\nOn February 5 to 9, February 26 to March 1, and April 2 to 5, 2024, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of\n49 United States Code (U.S.C.), conducted inspections of AmeriGas’s liquefied petroleum gas\n(LPG) distribution systems in the Palmetto District (Palmetto, Florida) and Tampa District\n(Tampa, Florida). The inspections included a review of procedures, examination of records, and\nfield verification of compliance with the applicable pipeline safety regulations. Additional\nrecords were submitted in response to PHMSA’s requests, and follow-up videoconferences were\nheld on January 14 and June 23, 2025, to review documentation and discuss the status of open\nitems.\nAs a result of the inspections, it is alleged that AmeriGas has committed probable violations of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violations are:\n1. § 192.465 External corrosion control: Monitoring and remediation.\n(a) . . . .\n\n\n\n(d) Each operator must promptly correct any deficiencies indicated by the\ninspection and testing required by paragraphs (a) through (c) of this section. …\n1\nAmeriGas failed to comply with 49 CFR § 192.465(d) because it did not promptly correct\ncathodic protection (CP) deficiencies identified during periodic monitoring. AmeriGas\nrecords showed sustained low2 CP readings across multiple monitoring periods in Tampa\nDistrict systems, but the company failed to promptly correct the deficiencies.\nAvery Oaks — CP surveys in May 2020 and August 2021 showed that Tanks 1 and 2\nrecorded low pipe-to-soil potentials less negative than the -0.85 V criterion, with survey\nremarks in both years recommending additional anodes. The low pipe-to-soil potentials in\ntwo consecutive years demonstrate that AmeriGas failed to promptly correct the\ndeficiencies. Later surveys showed that CP levels at the tanks were restored.\nCreekside — CP surveys in July 2021, June 2022, and June 2023 showed that all nine\ntanks in the system recorded low pipe-to-soil potentials less negative than the -0.85 V\ncriterion in each of those years. The low pipe-to-soil potentials in three consecutive years\ndemonstrate that AmeriGas failed to promptly correct the deficiencies. In January 2024,\nAmeriGas removed five of the nine underground containers and installed two new ones,\nleaving six tanks in service. A PHMSA field inspection in February 2024 confirmed that\nthe six tanks had adequate CP.\nKeystone Shores — CP survey in March 2022 and March 2023 showed that all three\ntanks in the system recorded low pipe-to-soil potentials less negative than the -0.85 V\ncriterion in both years. The low pipe-to-soil potentials in two consecutive years\ndemonstrate that AmeriGas failed to promptly correct the deficiencies. A survey dated\nJanuary 22, 2024, showed improved CP levels on all three tanks; however, some low\nreadings were still recorded. A subsequent survey dated February 1, 2024, showed that all\nthree tanks had adequate CP.\nFor these systems, CP levels remained below the required threshold across multiple\nyears. Although later surveys showed that AmeriGas failed to promptly correct the\ndeficiencies, as required by 49 CFR § 192.465(d).\n1 The full text of § 192.465(d) includes additional requirements specific to onshore transmission pipelines which\nare not relevant to this enforcement matter.\n2 Appendix D to 49 CFR Part 192 provides several criteria for demonstrating adequate CP. AmeriGas used\nthe -0.85 volt (V) (–850 millivolts (mV)) criterion. A ‘low’ reading is any value less negative than -0.85 V\n(e.g., -0.60 V, or -600 mV), which indicates inadequate protection. Even a single reading less negative\nthan -0.85 V (-850 mV) on a buried container indicates the protection is inadequate.\n2\n\n\n\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a\nmanual of written procedures for conducting operations and maintenance activities\nand for emergency response…3\nAmeriGas failed to comply with 49 CFR § 192.605(a) because it did not follow its\nwritten procedures for managing inactive service lines. On January 4, 2022, during a leak\nrepair, AmeriGas reinstated a polyethylene (PE) service line on Palomino Circle in the\nMote Ranch system (Tampa District) that had been inactive since at least August 2019\n(about 29 months). AmeriGas did not perform the required annual reviews, evaluate the\nline for future use, track it in a manner sufficient to ensure it was identified for review, or\nobtain the higher-level approvals required to retain jurisdictional equipment in place\nduring inactivity, as required by its written procedures.\nAt the time the service line became inactive in August 2019, AmeriGas’s Operating and\nMaintenance Manual included an Abandonment or Deactivation of Facilities section last\nrevised on June 20, 2012. That procedure required annual reviews of inactive service\nlines at intervals not exceeding 15 months and abandonment at the main if no reasonable\nprospect of reuse remained.\nOn July 31, 2021, AmeriGas revised and retitled the section Abandonment of Facilities,\nDeactivation of Facilities, Discontinuance of Service or Equipment Left in Place. The\nrevision retained the annual review and abandonment requirements and added a provision\nallowing jurisdictional equipment to remain in place, but only with written approvals\nfrom both the Region Director and the Division Pipeline Manager.\nBoth the 2012 and 2021 versions required AmeriGas to perform annual reviews of\ninactive service lines and determine whether abandonment was warranted. To carry out\nthese requirements, AmeriGas needed to identify which lines were inactive and track\nthem in a manner sufficient to ensure they were reviewed.\nFailure to Identify or Track the Inactive Line\nAmeriGas’s procedures required inactive service lines to be identified and reviewed\nannually, with abandonment at the main if no reasonable prospect of reuse remained.\nBeginning July 31, 2021, the revised procedure also allowed inactive equipment to\nremain in place with higher-level approvals. To comply, AmeriGas needed to track which\nlines were inactive. PHMSA requested a list of inactive service lines and supporting\ndocumentation, but AmeriGas provided neither. The Palomino Circle service line—\nknown to have been inactive since at least August 8, 2019—was never tracked in a\nmanner that would have allowed the required reviews or decisions under either version of\nthe procedure.\n3 The full text of § 192.605(a) includes additional requirements specific to transmission lines which are not\nrelevant to this enforcement matter.\n3\n\n\n\nFailure to Conduct Annual Reviews of Inactive Line Status\nBoth the 2012 and 2021 procedures required AmeriGas to review the status of inactive\nservice lines annually, at intervals not exceeding 15 months. PHMSA requested\ndocumentation of such reviews. AmeriGas provided none, and no records showed that the\nPalomino Circle service line was reviewed at any point from August 2019 through the\nApril 2024 inspection.\nFailure to Obtain Required Approvals\nBoth the June 20, 2012 and July 31, 2021 procedures required AmeriGas to abandon\ninactive service lines at the main if no reasonable prospect of reuse remained. The July\n31, 2021 revision also allowed jurisdictional equipment to remain in place, but only with\nwritten approvals from both the Region Director and the Division Pipeline Manager.\nThe Palomino Circle service line had been inactive for more than two years when it was\nreinstated on January 4, 2022, after the July 31, 2021 procedure took effect. AmeriGas\nprovided no documentation showing that it obtained the required approvals before\nreconnecting the line.\nFollowing reinstatement, the line remained inactive. In November 2024 AmeriGas\nreported plans to abandon it, but in June 2025 the company stated a resident expressed\ninterest in retaining it. Such a decision could have been acceptable under the 2021\nprocedure only if the required approvals had been obtained, but no such documentation\nwas provided.\nIn sum, AmeriGas reinstated a service line that had been inactive for more than two years\nwithout identifying it as inactive, conducting the required annual reviews, or obtaining\nrequired approvals prior to reinstating the service line. This sequence of events\ndemonstrates multiple failures to follow the written procedures AmeriGas established for\nmanaging inactive service lines.\n3. § 192.615 Emergency plans.\n(a) . . . .\n(c) Each operator must establish and maintain liaison with the appropriate\npublic safety answering point(i.e., 9-1-1 emergency call center) where direct access\nto a 9-1-1 emergency call center is available from the location of the pipeline, as well\nas fire, police, and other public officials, to:\n(1) Learn the responsibility and resources of each government organization\nthat may respond to a gas pipeline emergency;\n(2) Acquaint the officials with the operator's ability in responding to a gas\npipeline emergency;\n(3) Identify the types of gas pipeline emergencies of which the operator\nnotifies the officials; and\n(4) Plan how the operator and officials can engage in mutual assistance to\nminimize hazards to life or property.\n4\n\n\n\nAmeriGas failed to comply with 49 CFR § 192.615(c) because it did not establish and\nmaintain liaison with local emergency response officials in the Palmetto District. For\ncalendar years 2021, 2022, and 2023, AmeriGas had no documented contact with\nManatee County fire or emergency response agencies. Company personnel indicated that\nmeetings “may have occurred,” but no evidence was provided of outreach, coordination,\nor planning with the agencies responsible for pipeline emergency response.\nWithout conducting liaison, AmeriGas could not ensure that public officials were familiar\nwith its capabilities, aware of the types of pipeline emergencies, or prepared to coordinate\nmutual assistance. By failing to perform these required liaison activities, AmeriGas did\nnot comply with § 192.615(c).\n4. § 192.625 Odorization of gas.\n(a) . . . .\n(f) To assure the proper concentration of odorant in accordance with this\nsection, each operator must conduct periodic sampling of combustible gases using\nan instrument capable of determining the percentage of gas in air at which the odor\nbecomes readily detectable.…4\nAmeriGas failed to comply with 49 CFR § 192.625(f) because it did not conduct periodic\nsampling of combustible gases using an instrument capable of determining the percentage\nof gas in air at which the odor becomes readily detectable.\nMote Ranch system (Palmetto District) — PHMSA requested odorization sampling\nrecords, but AmeriGas provided none for the period November 15, 2021, through August\n17, 2023, a gap of about 21 months. The absence of records demonstrates that periodic\nsampling was not performed or documented during this time, as required by § 192.625(f).\nStone Lake Ranch system (Tampa District), On June 13, 2023, AmeriGas documented\nodorization verification on a “Sniff Test Report” instead of the “Gas Odorization Test\nReport” required by its procedures. The Sniff Test Report lacked fields necessary to\ndemonstrate that (1) an instrument was used, and (2) the test measured the percentage of\ngas in air at which odor becomes readily detectable. Without those elements, AmeriGas\ndid not demonstrate that the required sampling occurred.\nBy failing to perform odorization sampling as required, AmeriGas did not comply with\n§ 192.625(f).\n5. § 192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and\npressure regulating station and its equipment must be inspected and tested at\nintervals not exceeding 15 months, but at least once each calendar year, to\ndetermine that it is:\n4 The full text of § 192.625(f) includes additional requirements specific to master meters, which are not relevant\nto this enforcement matter.\n5\n\n\n\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for\nthe service in which it is employed;\n(3) Set to control or relieve at the correct pressure consistent with the\npressure limits of § 192.201; and\n(4) Properly installed and protected from dirt, liquids, or other conditions\nthat might prevent proper operation.\nAmeriGas failed to comply with 49 CFR § 192.739(a) because it did not inspect and test\neach required regulator and pressure-limiting device at the prescribed intervals. In several\nsystems, entire runs5 or individual pieces of equipment were omitted from the\ninspections, leaving portions of the stations unverified for proper operation and\noverpressure protection.\nDarby Lake system — Records for March 2021, March 2022, and May 2023 documented\nonly one run of regulators and did not include the secondary (maintenance) leg. By\nomitting the inspection and testing of the maintenance leg, AmeriGas did not demonstrate\nthat all required equipment was inspected at the intervals required by § 192.739(a).\nEagle Watch system — The May 2021 record documented only the downstream regulator\nand omitted the upstream regulator in series. Without inspection of both regulators,\nAmeriGas did not demonstrate that the station as a whole was in good mechanical\ncondition and providing adequate overpressure protection.\nKeystone Shores system — Records for March 2021, March 2022, and March 2023\ndocumented only one run of regulators and omitted the secondary (maintenance) leg. The\nincomplete inspections did not confirm that all installed runs were functional and ready\nfor use, as required.\nOrange Blossom Creek Phase 1 system — AmeriGas did not provide any regulator\nstation inspection record for calendar year 2022. The last record was June 2021 and the\nnext was March 2023, exceeding the 15-month maximum interval.\nStone Lake Ranch system — AmeriGas did not provide regulator station inspection\nrecords for calendar years 2020 or 2021. The last available record was July 2019, with\nthe next dated May 2022, resulting in no documented inspections for two consecutive\nyears.\nBecause AmeriGas failed to inspect and test all required regulators and pressure-limiting\ndevices—including entire runs of equipment—and did not perform inspections at the\nprescribed intervals, it did not demonstrate that its regulator stations were in good\n5 A “run” is two or more pressure control devices arranged in series. Regulator stations may also include parallel\nruns, which may operate concurrently to share load or remain out of service as a backup. Under § 192.739(a),\neach regulator and pressure-limiting device must be inspected and tested at the required intervals, and this\nrequirement applies to all runs of equipment, whether operated in parallel or maintained as a backup, to ensure\nthey remain functional and ready for service.\n6\n\n\n\nmechanical condition, set to relieve at the correct pressure, and adequately protected from\nfailure. By omitting these required inspections and intervals, AmeriGas did not comply\nwith § 192.739(a).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maxımum penalty may not exceed $239, 42 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documentation involved in this case and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the items identified in this letter to the extent practicable and\nto take appropriate measures to prevent recurrence. Failure to do so will result in AmeriGas\nPropane, L.P., being subject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 2-2025-001-WL. 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 portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n8","truncated":false,"body_characters":19214}