{"operation":"document","citation":"CPF 420141011W","title":"PERRYVILLE GAS STORAGE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-12-10","effective_on":null,"summary":"CLOSED warning letter citing 192.631(g)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420141011W","body":"Warning Letter involving PERRYVILLE GAS STORAGE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.631(g)(2). The case was opened on 2014-12-10 and is reported as closed as of 2014-12-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420141011W_Operator Response to Notice_02202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141011W/420141011W_Operator%20Response%20to%20Notice_02202015.pdf\n\n420141011W_Warning_12102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141011W/420141011W_Warning_12102014.pdf\n\n420141011W_Warning_12102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141011W/420141011W_Warning_12102014_text.pdf\n\n420141011W_Warning_12102014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 10, 2014\nMr. Robert B Raines Jr.\nSenior Vice President\nPerryville Gas Storage, LLC\n3 Riverway, Suite 1350\nHouston, TX 77056\nCPF 4-2014-1011W\nDear Mr. Raines:\nDuring the month of April through May 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code inspected your Perryville Gas Storage facilities in Winnsboro, LA.\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 violation(s) are:\n1. § 192.631 Control room management\n(g) Operating experience. Each operator must assure that lessons learned from its operating\nexperience are incorporated, as appropriate, into its control room management procedures\nby performing each of the following:\n(2) Include lessons learned from the operator's experience in the training program\nrequired by this section.\nPerryville failed to follow its Control Room Management Procedure for not conducting the\noperating experience review training on lessons learned. During the inspection, PHMSA\nidentified two Abnormal Operating Condition (AOC) events that took place in Perryville Gas\nStorage facilities. The two AOCs were the loss of communication on 4/24/2014 and an\nunexpected station blowdown without an alarm on 4/12/2014.\n\n\n\nUnder Cardinal Control Room Management program, Section-Lessons Learned and Corrective\nActions clearly states:\n“Controllers shall confirm that lessons learned from its operating experience have been\nreviewed with corrective actions implemented as needed for:\n• Controller fatigue\n• Field equipment\n• The operation of any relief device\n• Procedures\n• SCADA system configuration, and\n• SCADA system performance\nThe records provided by Perryville do not reflect the operating experience review as well as\nlessons learned.\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 item(s) identified in this letter.\nFailure to do so will result in Perryville being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF4-2014-1011W. 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","truncated":false,"body_characters":4320}