{"operation":"document","citation":"CPF 320131007W","title":"PINE PRAIRIE ENERGY CENTER LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-05-16","effective_on":null,"summary":"CLOSED warning letter citing 192.603(b), 192.739(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320131007W","body":"Warning Letter involving PINE PRAIRIE ENERGY CENTER LLC. PHMSA's enforcement data identifies the cited regulations as 192.603(b),  192.739(a). The case was opened on 2013-05-16 and is reported as closed as of 2013-05-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320131007W_Warning Letter_05162013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131007W/320131007W_Warning%20Letter_05162013.pdf\n\n320131007W_Warning Letter_05162013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131007W/320131007W_Warning%20Letter_05162013_text.pdf\n\n320131007W_Warning Letter_05162013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 16, 2013\nMr. Troy Valenzuela\nVice President – Environmental Health and Safety\nPlains Natural Gas Storage, LP\n333 Clay Street\nSuite 1600\nHouston, TX 77002\nCPF 3-2013-1007W\nDear Mr. Valenzuela:\nOn December 3-7, 2012, representatives of the Michigan Public Service Commission acting\nas interstate agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA)\npursuant to Chapter 601 of 49 United States Code inspected the records and facilities of the\nBluewater Gas Storage system in Columbus, MI.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation(s) are:\n1. §192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nPlains did not have records to verify that the annual review of the Operation and\nMaintenance manual was being performed as required by §192.605(a). Additionally, the\nrecords for the effectiveness review of the procedures were lacking in detail. Plains\npersonnel indicated that the annual reviews and the effectiveness reviews were performed\n\n\n\nthrough multiple processes and acknowledged that the reviews could be documented in a\nclearer format to more accurately reflect what was done.\n2. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests to determine\nthat it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at the\ncorrect pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nPlains personnel were not performing annual inspections on its fuel gas takeoff from the\nmainline for the compressors at Kimball Station and Columbus Station.\nPlains personnel did not realize that the pressure limiting equipment on the fuel gas for the\ncompressors at their stations were jurisdictional and required the annual inspection. Plains\npersonnel did indicate that they conducted maintenance on those devices annually, but did\nnot have any documents to substantiate those maintenance activities. Plains has already\nimplemented a new form to begin documentation of the inspections and will revise\nOperation & Maintenance procedures to reflect the new inspections.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item(s) identified in this letter. Failure to do so will result in Plains Natural Gas Storage,\nLP 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 3-2013-1007W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\n2\n\n\n\nthe portions 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,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5068}