{"operation":"document","citation":"CPF 420161014W","title":"BBT MIDLA, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-11-08","effective_on":null,"summary":"CLOSED warning letter citing 192.303(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420161014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420161014W","body":"Warning Letter involving BBT MIDLA, LLC. PHMSA's enforcement data identifies the cited regulation as 192.303(a). The case was opened on 2016-11-08 and is reported as closed as of 2016-11-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420161014W_Warning Letter_11082016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161014W/420161014W_Warning%20Letter_11082016.pdf\n\n420161014W_Warning Letter_11082016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420161014W/420161014W_Warning%20Letter_11082016_text.pdf\n\n420161014W_Warning Letter_11082016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 8, 2016\nMr. Lawrence Rearick\nDirector, Pipeline Integrity\nAmerican Midstream Partners, LP\n919 Milam Street, Suite #2450\nHouston, TX 77002\nCPF 4-2016-1014W\nDear Mr. Rearick:\nOn October 18-20, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code were onsite and\ninspected your Natchez Pipeline new construction project in Monroe, 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:\n2. §192.303 Compliance with specifications or standards.\n(a) Each transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nAmerican Midstream failed to comply with Section 12.4.1.1 of their Pipeline Construction\nSpecification agreement. Section 12.4.1.1 states that “coated pipe shall be handled with belt or\ncanvas slings at least as wide as the pipe diameter.”\n\n\n\nDuring the field inspection of the Natchez Pipeline, PHMSA inspectors noted that the pipe being\nlowered into the trench was not being handled in accordance with the construction specifications.\nSpecifically, the pipe was being lowered with canvas straps that did not meet the minimum width\nstandards as per the construction specifications.\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 American Midstream Partners, LP, being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2016-1014W. 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\n2","truncated":false,"body_characters":3682}