{"operation":"document","citation":"CPF 420122001W","title":"SEA ROBIN PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-07-16","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420122001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420122001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420122001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420122001W","body":"Warning Letter involving SEA ROBIN PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2012-07-16 and is reported as closed as of 2012-07-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420122001W_Warning_07162012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420122001W/420122001W_Warning_07162012.pdf\n\n420122001W_Warning_07162012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420122001W/420122001W_Warning_07162012_text.pdf\n\n420122001W_Warning_07162012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 16, 2012\nMr. Eric Amundsen\nVice President of Technical Services\nSea Robin Pipeline Company\n5444 Westheimer Road\nHouston, TX 77056-5306\nCPF 4-2012-2001W\nDear Mr. Amundsen:\nBetween October 2011 and February 2012, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the\ndocumentation of the re-route of Sea Robin Transmission pipeline #709. This pipeline is located in the\nGulf of Mexico off the coast of Louisiana.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation\nis:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures for\nhandling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least one each calendar year. This\nmanual must be prepared before operations of a pipeline system commence. Appropriate\nparts of the manual must be kept at locations where operations and maintenance activities\nare conducted.\n\n\n\nSea Robin failed to follow their procedures while conducting hydrostatic pressure tests on several\nsections of the replacement pipe for the re-route of pipeline #709. Sea Robin abandoned\napproximately 843 feet of 24 inch pipe replacing it with approximately 1210 feet of like pipe.\nThe abandonment/replacement was performed to re-route pipeline #709 (segment #3330) around\nthe toppled Devon platform, Eugene Island 330A. During the review of construction records for\nthis re-route, it was noted that three pressure tests performed by Pipeline Services International\n(PSI) did not follow the Panhandle Energy procedures. PSI was a contractor working for Sea\nRobin. The Panhandle Energy Standard Operating Procedure SOP I.19 Pressure Testing, section\n7.1.8 Pressurizing, step 9 states, ‘HOLD the P (leak test) for 15 minutes with no pressure loss.\nRECORD readings every 5 minutes during the initial leak test’. After the leak test is completed\nand the desired test pressure has been achieved, the pressure test begins. Step 17 further states,\n‘RECORD the deadweight pressures and ambient temperatures at regular intervals not to exceed\n15 minutes’. In all three hydrostatic pressure tests, the initial leak test was not documented as\nrequired by the procedure. Pressure readings were not documented every 5 minutes. One reading\nwas taken on the 15-minute interval. Beyond the two-hour stabilization period of the three\npressure tests, the deadweight pressures and ambient temperature readings were recorded every\n30 minutes. The requirement was not to exceed an interval of 15 minutes for recording the\npressure and temperature readings.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Sea Robin subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2012-2001W. 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,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n2","truncated":false,"body_characters":5109}