{"operation":"document","citation":"CPF 420141012W","title":"CADEVILLE 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(b)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420141012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420141012W","body":"Warning Letter involving CADEVILLE GAS STORAGE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.631(b)(4). 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\n420141012W_Operator Response to Notice_02202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141012W/420141012W_Operator%20Response%20to%20Notice_02202015.pdf\n\n420141012W_Warning_12102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141012W/420141012W_Warning_12102014.pdf\n\n420141012W_Warning_12102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420141012W/420141012W_Warning_12102014_text.pdf\n\n420141012W_Warning_12102014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 10, 2014\nMr. Robert B Raines Jr.\nSenior Vice President\nCadeville Gas Storage, LLC\n3 Riverway, Suite 1350\nHouston, TX 77056\nCPF 4-2014-1012W\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 Cadeville Gas Storage, LLC (“Cadeville”) in West\nMonroe, 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(b) Roles and responsibilities. Each operator must define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions. To provide for a\ncontroller's prompt and appropriate response to operating conditions, an operator must define\neach of the following:\n(4) A method of recording controller shift-changes and any hand-over of responsibility between\ncontrollers.\n\n\n\nCadeville failed to properly maintain a method of recording the shift-changes process between\nthe outgoing and incoming controllers.\nCardinal Gas Storage Partners, Control Room Procedure, Section 5.1.1(Shift Turnover Meeting)\nstates-\n“The record shall identify the incoming and outgoing controllers along with the topics\ncovered during the meeting and the date and time of the shift turnover.”\nDuring the record review of Cadeville Control Center, PHMSA revealed that shift turnover log\nsheets for 2013 and 2014 do not show the actual time the shift turn over took place between the\nControllers. Instead, Controllers simply noted “Days” or “Night” in the turnover logsheet.\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 Cadeville 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 4-2014-1012W. 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":4155}