{"operation":"document","citation":"CPF 520121011W","title":"PUGET SOUND ENERGY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-05-17","effective_on":null,"summary":"CLOSED warning letter citing 192.13(c), 192.731(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520121011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520121011W","body":"Warning Letter involving PUGET SOUND ENERGY. PHMSA's enforcement data identifies the cited regulations as 192.13(c),  192.731(a). The case was opened on 2012-05-17 and is reported as closed as of 2012-05-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520121011W_Warning Letter_05172012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121011W/520121011W_Warning%20Letter_05172012.pdf\n\n520121011W_Warning Letter_05172012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520121011W/520121011W_Warning%20Letter_05172012_text.pdf\n\n520121011W_Warning Letter_05172012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 17, 2012\nMs. Sue McLain\nSenior Vice President of Delivery Operations\nPuget Sound Energy\n10885 NE 4th Street\nBellevue, WA 98004\nCPF 5-2012-1011W\nDear Ms. McLain:\nOn March 29-31, 2011, a representative of the Washington Utilities and Transportation\nCommission (WUTC), on behalf of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Puget Sound Energy’s\n(PSE) Jackson Prairie Storage Facility in Chehalis, Washington.\nAs a result of the inspection, it appears that you have committed two probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.731(a), Except for rupture discs, each pressure relieving device in a compressor\nstation must be inspected and tested in accordance with §§192.739 and 192.743, and\nmust be operated periodically to determine that it opens at the correct set pressure.\nPuget Sound Energy did not test all of their relief devices in their compressor stations at the\nrequired frequency. CFR §192.731(a) requires that relief devices in compressor stations be\ninspected and tested at the frequency noted in §192.739(a), which is once each calendar year not\nto exceed 15 months. Records indicate that over pressure protection relief devices for three\ncompressor station dehydration vessels, #76, #44 and #43, were not inspected and tested during\ncalendar year 2009 and exceeded 15 months between inspection and testing.\n\n\n\n2. §192.13(c), Each operator shall maintain, modify as appropriate, and follow the\nplans, procedures, and programs that it is required to establish under this part.\nIn order to meet the requirements of §192.485 for transmission corrosion issues, PSE procedure\n4515.1760 requires engineering notification for pits over a certain depth as outlined in PSE’s\nO&M manual. PSE’s engineering department will then determine follow up requirements. At the\ntime of this inspection records indicated that in 2009, several areas of localized pitting were found\nunder the wrap located at the soil-to-air interface of some pipe risers. These pits had a depth\ngreater than that requiring engineering notification. Records were not available indicating that\nnotification was made. This is a probable violation of §192.13(c), failure to follow PSE’s\nprocedure 4515.1760.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\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 Puget Sound Energy 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 5-2012-1011W. 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,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: David Lykken, Washington UTC\nPHP-60 Compliance Registry\nPHP-500 R. Reineke (#134761)\n2","truncated":false,"body_characters":4518}