{"operation":"document","citation":"CPF 420131005W","title":"STL PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-02-06","effective_on":null,"summary":"CLOSED warning letter citing 192.605, 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420131005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420131005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420131005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420131005W","body":"Warning Letter involving STL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605,  192.805(b). The case was opened on 2013-02-06 and is reported as closed as of 2013-02-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420131005W_Warning_02062013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131005W/420131005W_Warning_02062013.pdf\n\n420131005W_Warning_02062013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420131005W/420131005W_Warning_02062013_text.pdf\n\n420131005W_Warning_02062013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 6, 2013\nMr. Richard Watson\nPresident\nSTL Pipeline, LLC\n235 Mulberry Drive\nMandeville, LA 70448\nCPF 4-2013-1005W\nDear Mr. Watson:\nIn June and November 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nOffshore Gas Gathering facility located at MI-632.\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 the\nprobable violations are:\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.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n\n\n\n(8) Periodically reviewing the work done by operator personnel to determine\nthe effectiveness and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedure when deficiencies are found.\nSTL Pipeline LLC (STL) failed to follow their procedures to review work performed by\noperations personnel to determine the effectiveness and adequacy of the procedures used in\nnormal operation and maintenance and modifying the procedure when deficiencies are found.\nSTL O&M Section 1.11 Operating Personnel 192.605(b)(8) states:\n\"Annually (during operator qualification reviews), STL Pipeline will review the\nwork done by operator personnel to determine the effectiveness of the procedures\nused in normal operations, abnormal operations and maintenance tasks. During\nthis evaluation STL pipeline will take corrective action if deficiencies are\ndiscovered.\nSTL Pipeline periodically reviews the work done by operator and contract\npersonnel (including their response to abnormal operating conditions, safety\nrelated conditions, and incidents) to determine the effectiveness and adequacy of\nthe procedures used. Procedure modifications will be evaluated if deficiencies are\nfound.\"\nThe STL pipeline is operated by contract staff through Shamrock Management/Matagorda Island\nGas Operators (Shamrock/MIGO). As stated by Shamrock/MIGO personnel, there were no\nannual reviews of work conducted during operator qualification reviews or periodically during\nwork performed by qualified personnel or contractors.\n2. 192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(b) Ensure through evaluation that individuals performing covered tasks are\nqualified.\nAt the time of the inspection, STL had failed to ensure through evaluation that individuals who\nhad performed the listed covered tasks were qualified, as required by 192.805(b).\nThose tasks are: CT#26 Inspect, Test and Calibrate Pressure Limiting Devices; CT#27 Inspect,\nTest and Calibrate Pressure Switches and Transmitters; CT#45 Perform Leakage Surveys\nand CT#16G/16L Perform Leak Surveys for Liquid/Gas Pipelines (Aerial Patrols).\nSTL provided records where these inspections had been completed, but certain contract\nemployees that performed the respective covered tasks were not properly qualified, as per the\nSTL Operator Qualification Program (OQ Program).\nSTL OQ Program Section 3.4 “Contractor Records” states:\n2\n\n\n\n\"The contractor will also be required to submit a copy of their operator\nqualification records / program reviews / program evaluations / personnel\nevaluations prior to conducting covered task on jurisdictional pipeline facilities.\"\nIn a subsequent visit on November 1, 2012, PHMSA staff reviewed OQ records of operations\npersonnel qualified through The Operator Qualification Solutions Group (OQSG) after the June\n2012 visit. PHMSA staff further confirmed that the STL OQ Program has been amended to\nallow for qualification through OQSG.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\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 items identified in this letter.\nFailure to do so will result in STL Pipeline, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2013-1005W. 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\n3","truncated":false,"body_characters":6258}