{"operation":"document","citation":"CPF 420167001W","title":"STONE ENERGY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-04-28","effective_on":null,"summary":"CLOSED warning letter citing 194.111(a), 194.119(a), 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420167001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420167001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420167001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420167001W","body":"Warning Letter involving STONE ENERGY. PHMSA's enforcement data identifies the cited regulations as 194.111(a),  194.119(a),  195.402(a). The case was opened on 2016-04-28 and is reported as closed as of 2016-04-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420167001W_Warning Letter_04282016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420167001W/420167001W_Warning%20Letter_04282016.pdf\n\n420167001W_Warning Letter_04282016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420167001W/420167001W_Warning%20Letter_04282016_text.pdf\n\n420167001W_Warning Letter_04282016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 28, 2016\nMr. Keith Seilhan\nSenior Vice President – Gulf of Mexico\nStone Energy Corporation\n625 East Kaliste Saloom Road\nLafayette, LA 70508\nCPF 4-2016-7001W\nDear Mr. Seilhan:\nOn February 9-13, 2015, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code were onsite and\ninspected your Stone Energy Corporation (Stone) - offshore liquid crude pipeline related records\nand procedures in the field office located in Lafayette, LA.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation(s) are:\n1. §194.119 Submission and approval procedures\n(a) Each operator shall submit two copies of the response plan required by this part.\nCopies of the response plan shall be submitted to: Office of Pipeline Safety,\nPipeline and Hazardous Materials Safety Administration, Department of\nTransportation, PHP 80, 1200 New Jersey Avenue, SE, Washington, DC 20590-\n0001. Note: Submission of plans in electronic format is preferred.\n\n\n\nStone transported crude oil in the pipeline but failed to submit a response plan and failed to meet\nthe requirements of §194.7 prior to February 10, 2015.\nDuring the inspection, Stone provided the East Cameron 46 High Consequence Area Analysis\ndated April 26, 2012. While reviewing it, PHMSA inspectors noted the onshore facility could\naffect navigable waters of the USA. Since the late 1990’s, Stone has operated approximately 22.4\nmiles of 6-inch steel pipeline departing from the East Cameron 46 Platform to the onshore facility\n(3.6 miles) in Grand Chenier, Louisiana.\nStone submitted a response plan to PHMSA as required by §194.7 for review and approval on\nFebruary 10, 2015. No documentation indicating a response plan was submitted prior to February\n10, 2015 was provided.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nStone failed to keep the recently updated appropriate parts of their Operations and Maintenance\n(O&M) manual as well as their emergency manual at EC 46 platform where operations and\nmaintenance activities are being conducted.\nDuring the field inspection of the EC 46 platform, the operator advised PHMSA inspectors that\ntheir O&M and Emergency manuals are located on the platform via intranet and/or SEMPCheck\nto all qualified company employees. When the PHMSA inspector randomly selected a qualified\nemployee, who performed an inspection on FSV at EC 46 and the supervisor to show the current\nmanuals on intranet/SEMPCheck, they were unable to find it. The most recent revision date for\nthe O&M including the Emergency Response Plan is February 2, 2015. However, the hard copies\nof these manuals available at EC 46 platform were dated February 2005.\n3. §194.111 Response plan retention.\n(a) Each operator shall maintain relevant portions of its response plan at the\noperator's headquarters and at other locations from which response activities may be\nconducted, for example, in field offices, supervisors' vehicles, or spill response\ntrailers.\n2\n\n\n\nStone failed to maintain relevant portions of its response plan at the EC 46 platform where response\nactivities may be conducted. During the field inspection of Stone Energy EC 46 platform on\nFebruary 11, 2015, PHMSA inspectors were not provided the most recent Regional Oil Spill\nResponse Plan.\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 exceed\n$100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in\nthis case, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to\ndo so will result in Stone Energy Corporation 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 4-2016-7001W. 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 the\nredacted 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":6313}