{"operation":"document","citation":"CPF 420072004","title":"SEA ROBIN PIPELINE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-08-09","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.612(a), 192.727(g).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420072004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420072004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420072004","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420072004","body":"Notice of Probable Violation involving SEA ROBIN PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.612(a),  192.727(g). The case was opened on 2007-08-09 and is reported as closed as of 2009-12-03. Proposed civil penalty: $37,000. Assessed civil penalty: $0. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420072004_FinalOrder_12032009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420072004/420072004_FinalOrder_12032009.pdf\n\n420072004_FinalOrder_12032009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420072004/420072004_FinalOrder_12032009_text.pdf\n\n420072004_nopvpcppco_08092007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420072004/420072004_nopvpcppco_08092007.pdf\n\n420072004_nopvpcppco_08092007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420072004/420072004_nopvpcppco_08092007_text.pdf\n\n420072004_Operator response and request for hearing_09062007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420072004/420072004_Operator%20response%20and%20request%20for%20hearing_09062007.pdf\n\n420072004_FinalOrder_12032009_text.pdf\n\nDEC 03 2009\nMr. Jeryl Mohn\nVice President\nSea Robin Pipeline Company, LLC\n5444 Westheimer Road\nHouston, TX 77056-5306\nRe: CPF No. 4-2007-2004\nDear Mr. Mohn:\nEnclosed is the Final Order issued in the above-referenced case. It withdraws the allegations of\nviolation. This case is now closed. Your receipt of the Final Order constitutes service of that\ndocument under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. R.M. Seeley, Director, Southwest Region, PHMSA\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED [7005 0390 0005 6162 5180]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nSea Robin Pipeline Company, LLC, ) CPF No. 4-2007-2004\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom October 31 to November 3, 2006, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Sea Robin\nPipeline Company (Sea Robin or Respondent) in Erath, Louisiana. Respondent operates an\noffshore natural gas pipeline system in the Gulf of Mexico.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated August 9, 2007, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that Respondent had violated 49 C.F.R. §§ 192.612(a) and 192.727(g)\nand proposed assessing a civil penalty of $37,000 for the alleged violations. The Notice also\nproposed ordering Respondent to take certain measures to correct the alleged violations.\nSea Robin responded to the Notice by letter dated September 6, 2007 (Response). Respondent\ncontested all of the allegations and requested a hearing. A hearing was held on April 23, 2008,\nin Houston, Texas, with an attorney from the PHMSA Office of Chief Counsel presiding.\nRespondent was represented by counsel at the hearing. After the hearing, Respondent provided\nadditional information on May 29, 2008.\nWITHDRAWAL OF ALLEGATIONS\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.612(a), which states:\n§ 192.612 Underwater inspection and reburial of pipelines in the Gulf\nof Mexico and its inlets.\n(a) Each operator shall prepare and follow a procedure to identify its\npipelines in the Gulf of Mexico and its inlets in waters less than 15 feet\n\n\n\n2\n(4.6 meters) deep as measured from mean low water that are at risk of\nbeing an exposed underwater pipeline or a hazard to navigation. The\nprocedures must be in effect August 10, 2005.\nThe Notice alleged that Respondent failed to comply with 49 C.F.R. § 192.612(a) by failing to\nfollow its procedure to identify pipelines in the Gulf of Mexico that were at risk of being an\nexposed underwater pipeline or a hazard to navigation. Specifically, it alleged that Sea Robin\nfailed to justify a change in its schedule for inspection of its underwater pipelines. Respondent\nhad developed an inspection schedule pursuant to its written procedure under § 192.612(a) but\nhad allegedly delayed the inspection by one year without justification. In its Response and at the\nhearing, Sea Robin contested this allegation on the basis that it had not altered its schedule in the\nmanner alleged, and submitted credible information showing that it had actually moved up the\nscheduled inspection by one year. It appears that the allegation of a one-year delay was based\nupon the misreading of a date on a document of poor copy quality.\nBased on the foregoing, I order that this Item in the Notice be withdrawn.\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.727(g), which, at the time\nof the Notice, stated:1\n§ 192.727 Abandonment or deactivation of facilities.\n(a) …\n(g) For each abandoned offshore pipeline facility or each abandoned\nonshore pipeline facility that crosses over, under or through a\ncommercially navigable waterway, the last operator of that facility must\nfile a report upon abandonment of that facility.\n(1) The preferred method to submit data on pipeline facilities\nabandoned after October 10, 2000 is to the National Pipeline Mapping\nSystem (NPMS) in accordance with the NPMS “Standards for Pipeline\nand Liquefied Natural Gas Operator Submissions.” To obtain a copy of\nthe NPMS Standards, please refer to the NPMS homepage at\nwww.npms.rspa.dot.gov or contact the NPMS National Repository at 703–\n317–3073. A digital data format is preferred, but hard copy submissions\nare acceptable if they comply with the NPMS Standards. In addition to\nthe NPMS-required attributes, operators must submit the date of\nabandonment, diameter, method of abandonment, and certification that, to\nthe best of the operator’s knowledge, all of the reasonably available\ninformation requested was provided and, to the best of the operator’s\nknowledge, the abandonment was completed in accordance with\napplicable laws. Refer to the NPMS Standards for details in preparing\nyour data for submission. The NPMS Standards also include details of\nhow to submit data. Alternatively, operators may submit reports by mail,\nfax or e-mail to the Information Officer, Pipeline and Hazardous Materials\nSafety Administration, Department of Transportation, Room 7128, 400\nSeventh Street, SW, Washington DC 20590; fax (202) 366–4566; e-mail,\n1 After the inspection 49 C.F.R. § 192.727 was amended to update the contact information for PHMSA.\n\n\n\n3\nroger.little@dot.gov. The information in the report must contain all\nreasonably available information related to the facility, including\ninformation in the possession of a third party. The report must contain the\nlocation, size, date, method of abandonment, and a certification that the\nfacility has been abandoned in accordance with all applicable laws.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.727(g) by failing to submit\noffshore pipeline abandonment reports to PHMSA in accordance with the regulation.\nSpecifically, the Notice alleged that at the time of the inspection Respondent had failed to submit\nreports for its Line 709-6 10-inch Eugene Island 260 to 262 pipeline and Line 702-5 8-inch\nSouth Marsh Island 27 pipeline. In its Response and at the hearing, Sea Robin contested this\nallegation on the basis that it had submitted such reports to PHMSA, and the company submitted\ncredible information in support of its position, including dated documents showing that it had\nsubmitted the information before the inspection.\nBased on the foregoing, I order that this Item in the Notice be withdrawn.\nOn the basis of my withdrawal of both Items in the Notice, I order that the associated proposed\ncivil penalties and proposed compliance order also be withdrawn.\nThe terms and conditions of this Final Order shall be effective on receipt. This enforcement\nmatter is now closed.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":8447}