STATE OF WASHINGTOR UTILITIES AND TRANSPORTATION COMMISSION 1300 S. Everyman Park Dr. S.W., FLO. Box 47250 03mph, Washington 98504-7250 (380] 684-1160 0 (360) 535-3203 CERTIFIED MAIL December 19, 2014 Mike Cohen Managing Partner Point Ruston, LLC 5219 N. Shirley St. #100 Ruston, WA 98407 - Dear Mr. Cohen: RE: 2014 Point Ruston LLC Petroleum Gas one Jurisdictional Distribution located in?Ruston and Tacoma= WA - Field Ingpection gasp. No. 6112) Sta? from the Washington Utilities and Transportation Commission (sta?) conducted an inepection of the propane tank and distribution system serving Point Ruston, LLC, buildings 2A and ZB on December 2, 2014. Upon con?rming that more than 10 customers are being provided with propane gas ?om a propane distribution system, we have detenm'ned that pipe system supplying propane to buildings 2A and ZB is jmisdiotional and subject to the rules de?ned in 49 CFR Part 191, 192 and WAC 480?93. - Our inspection indicates six probable violations as noted in the enclosed report. We also noted one area of concern, which unless corrected, could potentiniiy lead to ?xture violation of state and/or federal pipeline safety rules. Your response needed Please review the attached report and respond in writing by January 20, 2015. The reSponse should include how and when you plan? to bring the probable violations and area of concern into full compliance. What happens after you respond to this letter? The attached report presents staffs decision on probable violations and does not constitute a ?nding of violation by the commission at this time. Respect. Professionalism. Ammo. Point Ruston, LLC 2014 Jurisdictional Distribution System December 19, 2014 Page 2 After you respond "in writing to this letter, there are several possible actions the commission, in its discretion, may take with respect to this matter. For example, the commission may: 0 Issue an administrative penalty under RCW 81.88.040, or; 0 Institute a complaint, seeking monetary penalties, changes in the company?s practices, or other relief authorized by law, and justi?ed by the circumstances, or; Consider the matter resolved without further commission action. 'We have not yet decided whether to pursue a complaint or penalty in this matter. Should an administrative law judge decide to pursue a complaint or penalty, your company will have an opportunity to present its position directly to the commissioners. If you have any questions or if we may be of any assistance, please contact Lex Vinsel at (3 60) 664-1319. Please refer to the subject matter described above in any future correspondence pertaining to this inspection. Sincerely, Pipeline Safety Director Enclosure cc: Loren Cohen, Partner, Point Ruston, LLC .Conor McCarthy, In?House Attorney, MC Construction, LLC Joeseph Harrison, Site Construction Manager, Point Ruston, LLC Yuchin Santory, Project Manager, Point Ruston, LLC UTILITIES AND TRANSPORTATION COMMISSION 2014 Petroleum Gas (Tl-opens) Pipdine Safety Inspection Point Ruston, LLC Ruston and Tacoma, WA The following probable violations and area of concern of Title 49 CFR Part 192 and WAC 480- 93 were noted as a result of the 2014 inspection of the Point Ruston, LLC buildings 2A and 2B. The inspection included an inspection of thepropane tank and the buildings 2A (1 service) and ZB (20 customers). PROBABLE VIOLATIONS l. 49 CFR Part 192.1 What is the scope of this part? This part prescribes minimum sa?ty requirements for pipeline facilities and the . tranSportation of gas including pipeline facilities and the of gas within the limits of the outer continental shelf as that term is o?q?ined in the Outer Continental Shelf Lands Act (43 U. S. C. 1331). This part does not apply to? (5) system that transports only petroletan gas or petroleum gas/air mixtures to- (0 Fewer than 10 customers, if no portion of the system?is located in a public place; or (ii) A single customer; if the system is located entirely on the customers premises (no matter if a portion of the system is located in a public place). Operator Point Ruston, LLC transports petroleum gas (propane) to more than 10 customers in the Point Rnston, LLC building 23. The-refute, Point Ruston isjm'isdietiooel to 49 2. 49 CFR Part 1 2.11 Petroleum 3 stems. Each plant that supplies petroleum gas by pipeline to a natural gas distribution system must meet the requirements of this part MWA 58 and 5 9. Eaehpioeline system subject to this part that n'ansportspetroleom gas or petroleum gas/air mixtures must meet the requirements ofthis port and of ANSWPA 58 and 59. In the event of a con?ict between this part 58 and 59, ANSWPA 58 and 5 9 prevail. Findings]: Operator must provide evidence that propane system was designed and constructed in accordance with the requirements in 58 59. WAC meson Filing requirements fer desigg' speci?cation, and construction procedures. - (1) Any gas pipeline company intending to construct or operate a gas pipeline in this state must file all applicable construction procedures, designs, and speci?cations used for each gas pipeline with the commission at least forty?ve days prior to the initiation of construction activity. All procedures must detail the acceptable types of materials, ?ttings, and components for the different bones of facilities in the gas pipeline company's system. (2) Except in an emergency, a gas pipeline company must submit to the commission for review, at least faint-five days prior to construction, any construction plans that do not conform with a gas pipeline companyis existing and accepted construction procedures, designs, and speci?cations on ?le with the commission. Findinggs Point Ruston, LLC did not submit applicable construction procedures, designs and speci?cations to be used in construction 45 days prior to the initiation of construction . activity. The Point Ruston Propane Distribution section of the pipeline in question was complete on September 25, 2014, during my ?rst observation of the site. Point Ruston must show that the propane system was constructed in accordance with 49 CFR ?192 and WAC 480?93. WAC 480-915-013 Covered tasks. (I) Background 49 CFR ??192. 803 through 192.809 prescribe the requirements associated with qnalh?ications for gas pipeline company personnel to perform "covered tasks. 49 CFR ?192.80] contains a de?nition of "covered task. In WAC 480-99999, the commiSsion adopts 49 CFR ??192.801 through 192.809. However, in this section, the commission includes "new constructibn" in the de?nition of "covered task (2) Accordingly for the pinpose of this chapter, the commission de?nes a covered task that will be sabject to the requirements of 49 CFR 92.803 through 192.809 as an activity, identified by the gas pipeline company that: Is performed on a ga'sp?oeline; Is an operations, maintenance, or new construction task; (6) Is performed as a requirement of Part 19.? and A?ects the operation or integrity of the gas pipeline. (3) In all other respects, the requirements of 49 CFR ??192. 801 through 192. 809 apply to this chapter. (4) The equipment and facilities used by a gas pipeline company for training and qualification of employees must be similar to the equipment and facilities on which the employee will pet?n'm the covered task Findings): Point Ruston, LLC could not provide a copy of their Operator Quali?cation program nor show that system operators are quali?ed to operate and construct the propane system. WAC 480-93480 Plans and procedures; I . (1) Each gas pipeline company must have and follow agas pipeline plan and procedure manual (manaay?r operation, maintenance, inspection, and emergency response activities that is specific to the gas pipeline companyis system. The manual must include plans and procedures for meeting allT applicable requirements of 49 CFR :51 91, I92 and chapter 480-93 WAC, and any plans or procedures used by a gas pipeline compamt?s associated contractors. (2) The manual mast be filed with the commission ?rtyh?ve days prior to the Operation of any gas pipeline. Each gas phieline company ntust?le revisions to the mantra! with the commission annually The commission may, after notice and opportunity for hearing, require that a manual be revised or amended. Applicable portions of the manual related to a procedure being performed on the pipeline must be retained on-site where the activity is beingpeijbrmed (3) The manual mast. be written in detail a person with adequate training to petform the tasks described. For example, a manual should contain speci?c, detailed, step?by-step on how to maintain a regulator or recti?er, conduct a leak survey or conduct a pressure test. Findings}: Point Ruston, LLC could not provide a copy of their Plans and Procedures. A book with generic fusing procedure from Amerigas was submitted as their fusing procedure. Some plastic pipe speci?cations were included in the submittal. Point Ruston is required to submit an Operations and Maintenance manual to the commission. The manual must be compliant with 49 CFR ?192.605 and WAC 480-93480. WAC 439-93470 Tests and reports lor pipelines. (-10) Pressure testing eqahament must be maintained tested for accuracy, or calibrated, in accordance with the mana?ctureris recommendations. When there are no manufacturers recommendations, thenpressare testing equipment must be tested for accuracy at an appropriate schedule determined by the gas pipeline compaml. Test must be tagged with the calibration or accuracy check expiration date. Yhe requirements of this section also apply to equipment such as pressure charts, gauges, dead weights or other devices used to test, monitor or check system pressures or setpoints. Findings]: . During observation of a pressure test of the Point Raster} Propane Distribution pipeline, I notedthat the test meter did not have a calibration sticker showing when 0?100 PSI gauge was due for calibration. Operator told me that the meter was only two months old and had been bought just for this job. When asked about the calibration of the gauge, the Operator said that he had thrown the paperwork in the box away. AREAS OF CONCERN OR FIELD OBSERVATIONS Sta?? observed that the 2B common room the ground ?oor smelled ofa carbon rich atmosphere after the log insert was used prior to our inspection. This observation leads me to suspect that the carbon rich atmosphere is the result oftoo rich of a gas to air ratio. This could be caused by installing a natural gas appliance and using propane gas as the fuel.