{"operation":"document","citation":"CPF 420172001W","title":"RENAISSANCE OFFSHORE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-05","effective_on":null,"summary":"CLOSED warning letter citing 191.22(c)(2)(iii), 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420172001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420172001W","body":"Warning Letter involving RENAISSANCE OFFSHORE, LLC. PHMSA's enforcement data identifies the cited regulations as 191.22(c)(2)(iii),  192.805(b). The case was opened on 2017-04-05 and is reported as closed as of 2017-04-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420172001W_Warning Letter_04052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172001W/420172001W_Warning%20Letter_04052017.pdf\n\n420172001W_Warning Letter_04052017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420172001W/420172001W_Warning%20Letter_04052017_text.pdf\n\n420172001W_Warning Letter_04052017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 5, 2017\nMr. J. E. Skip Ward\nV.P. - Operations\nRenaissance Offshore, LLC\n920 Memorial City Way\nSuite 800\nHouston, TX 77024\nCPF 4-2017-2001W\nDear Mr. Ward:\nOn multiple dates between November 29, 2016 and March 24, 2017, representatives of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Renaissance Offshore, LLC (Renaissance) – Offshore Gas gathering\npipeline system in Houston, TX and Main Pass Area in Gulf of Mexico, LA.\nAs a result of the inspection, it is alleged 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. §192.805 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;\n\n\n\nRenaissance failed to ensure thorough evaluation that an employee was qualified to\nperform covered tasks; specifically task 12.0: Inspect Internal Pipe Surface.\nOn June 19, 2015, a contractor employee working for Renaissance, conducted the internal\ninspection on a cut section of exposed pipe that was removed from a riser at Main Pass 72\nplatform. The internal condition of said pipe was noted to be in “good” condition and\ndocumented on “Form 20.5: Exposed Pipe Inspection”. The PHMSA inspector reviewed\nthe qualification record for this individual, and found he was not qualified to perform this\ncovered task.\nAt the time of the inspection, Renaissance failed to provide documentation indicating the\nemployee was qualified to perform this covered task. If covered task 12.0 is performed by\na non-qualified individual, according to Renaissance Operator Qualification Program\nSection 11: Reevaluation Interval Spreadsheet, a qualified individual can monitor three\nnon-qualified personnel.\nAccording to Form 20.5 provided by Renaissance, a qualified employee was not present to\nobserve or direct this individual at the work site.\n2. §191.22 National Registry of Pipeline and LNG operators\n(c) Changes. Each operator of a gas pipeline, gas pipeline facility, LNG plant or LNG\nfacility must notify PHMSA electronically through the National Registry of Pipeline\nand LNG Operators at http:// opsweb.phmsa.dot.gov of certain events.\n(2) An operator must notify PHMSA of any of the following events not later than 60\ndays after the event occurs:\n(iii) A change in the entity (e.g., company, municipality) responsible for an existing\npipeline, pipeline segment, pipeline facility, or LNG facility;\nRenaissance acquired Segment 15172 from Talos Energy, LLC on May 1, 2015.\nRenaissance failed to notify PHMSA of this asset acquisition until November 9, 2015. As\na result, Renaissance exceeded this notification requirement by 132 days.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n2\n\n\n\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Renaissance Offshore, LLC being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2017-2001W. 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,\nRodrick M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5377}