{"operation":"document","citation":"CPF 420181009W","title":"LA STORAGE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-07-19","effective_on":null,"summary":"CLOSED warning letter citing 192.465(a), 192.465(d), 192.605(b)(3), 192.736(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420181009W","body":"Warning Letter involving LA STORAGE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.465(d),  192.605(b)(3),  192.736(b). The case was opened on 2018-07-19 and is reported as closed as of 2018-07-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420181009W_Warning Letter_07192018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181009W/420181009W_Warning%20Letter_07192018.pdf\n\n420181009W_Warning Letter_07192018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181009W/420181009W_Warning%20Letter_07192018_text.pdf\n\n420181009W_Warning Letter_07192018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 19, 2018\nJohn Pirraglia\nVice President\nLA Storage, LLC\n2925 Briarpark Dr., Suite 850\nHouston, TX 77042\nCPF 4-2018-1009W\nDear Mr. Pirraglia:\nOn July 10 - 11, and September 25 - 28, 2017, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected your LA Storage, LLC (LAS) facilities in Houston, Texas and Lake Charles,\nLouisiana.\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 (CFR). The items inspected\nand the probable violations are:\n1. §192.736 Compressor stations: Gas detection.\n(b) Except when shutdown of the system is necessary for maintenance under\nparagraph (c) of this section, each gas detection and alarm system required by this\nsection must\n(1) Continuously monitor the compressor building for a concentration of gas\nin air of not more than 25 percent of the lower explosive limit; and\n(2) If that concentration of gas is detected, warn persons about to enter the\nbuilding and persons inside the building of the danger.\n\n\n\nLAS failed to provide adequate warning to persons entering compressor building from the\nsouthwest side. During the field inspection, PHMSA inspector observed LAS test the Ragley\nCompressor Station gas detection for indication of gas at 5% LEL. The gas detection system has\nthree visual alarms; one strobe light outside on the northeast corner of the compressor building,\none strobe light outside on the southwest corner of the compressor building, and a strobe light\ninside the compressor building. There are no audible alarms. LA Storage used calibrated gas to\ntest sensor S4000C 1500AA at 5% LEL. The sensor detected gas at 5% and gave indication to\nthe control room as well as inside the compressor station. Additionally, the northeast strobe light\noutside of the compressor building illuminated as expected. However, the southwest strobe light\noutside of the compressor building failed to illuminate to give indication of gas leak inside the\ncompressor building.\nOn September 28, 2017 LAS repaired light, replaced bulb and provided record FORM OM500-\n02 – Compressor Station Gas Detector Calibration/Repair Report which documents the repair\nactions and Work Order # #16003.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(3) Making construction records, maps, and operating history available to\nappropriate operating personnel.\nLAS failed to document the correct MAOP on their maps, records, and control room console. At\nthe time of inspection, the PHMSA inspector found the MAOP on LA Storage records, maps, and\ncontrol room console for the LAS pipeline to be inaccurate. The records, maps, and console all\nlisted a MAOP of 1284psi which is actually the MOP of LAS pipeline. The MAOP for LAS\npipeline is 1460psi.\nOn October 2, 2017 LAS fixed maps, records, and screen shot of control room console with the\ncorrect MOP and MAOP for LAS pipeline.\n3. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once each\ncalendar year, but with intervals not exceeding 15 months, to determine whether the\ncathodic protection meets the requirements of §192.463. However, if tests at those\nintervals are impractical for separately protected short sections of mains or\ntransmission lines, not in excess of 100 feet (30 meters), or separately protected service\nlines, these pipelines may be surveyed on a sampling basis. At least 10 percent of these\nprotected structures, distributed over the entire system must be surveyed each\ncalendar year, with a different 10 percent checked each subsequent year, so that the\nentire system is tested in each 10-year period.\n2\n\n\n\n(d) Each operator shall take prompt remedial action to correct any deficiencies\nindicated by the monitoring.\nLA Storage failed to take prompt remedial action to correct a deficiency with the Transco\nInter./Targa Crossing test station.\nAfter reviewing pipe-to-soil potential survey records for July 2016 and July 2017 the PHMSA\ninspector found Transco Inter./Targa Crossing test lead was missing. At the time of inspection,\nSeptember 2017, the test station was still missing and there was no work order in place to address\nthis deficiency.\nOn October 5, 2017 LAS provided an inspection report, pictures, and Work Order #15988\ndocuments on the repair of the test lead at the Transco/Targa crossing.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related 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 LA Storage, LLC 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 4-2018-1009W. 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,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6996}