{"operation":"document","citation":"CPF 120143004W","title":"TOTAL PEAKING SERVICES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-12-16","effective_on":null,"summary":"CLOSED warning letter citing 193.2639(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120143004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120143004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120143004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120143004W","body":"Warning Letter involving TOTAL PEAKING SERVICES. PHMSA's enforcement data identifies the cited regulation as 193.2639(a). The case was opened on 2014-12-16 and is reported as closed as of 2014-12-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120143004W_Warning Letter_12162014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120143004W/120143004W_Warning%20Letter_12162014.pdf\n\n120143004W_Warning Letter_12162014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120143004W/120143004W_Warning%20Letter_12162014_text.pdf\n\n120143004W_Warning Letter_12162014_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nOVERNIGHT EXPRESS MAIL\nDecember 16, 2014\nMr. Robert Allessio\nSenior Vice President, United Resources Inc.\n157 Church Street\nNew Haven, CT 06510\nCPF 1-2014-3004W\nDear Mr. Allessio:\nBetween April 7-10, 2014, inspectors from the Connecticut Department of Energy and Environmental\nProtection (DEEP), acting as agents for the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Total Peaking Services (TPS)\nprocedures, records and LNG plant facilities in Milford, CT.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation is:\n1. §193.2639 Maintenance records\n(a) Each operator shall keep a record at each LNG plant of the date and type of each\nmaintenance activity performed on each component to meet the requirements of this part.\nFor each LNG facility that is designed and constructed after March 31, 2000 the operator\nshall also maintain related periodic inspection and testing records that NFPA 59A\n(incorporated by reference, see § 193.2013) requires. Maintenance records, whether\nrequired by this part or NFPA 59A must be kept for a period of not less than five years.\nThe TPS record for the elevation survey of aboveground piping was missing two elevations in the piping\narea survey dated 12/6/2013. The elevations were on previous surveys and no explanation was provided\nin the survey record as to why they were not included in the 12/6/2013 survey.\nTPS representatives stated that there were circumstances with a new set of stairs that may have obstructed\nthe points from being surveyed.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\n\n\n\n1-2014-3004W\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nAlso, for LNG facilities, an additional penalty of not more than $50,000 for each violation may be\nimposed. We have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item identified in this letter. Failure to do so will result in TPS being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to: Byron\nCoy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628\nand please refer to CPF 1-2014-3004W. Be advised that all material you submit in response to this\nenforcement action 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 complete\noriginal document you must provide a second copy of the document with the portions you believe qualify\nfor confidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response letter\npertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Karl Baker, CT DEEP\n120143004W-WL-12162014 Page 2 of 2","truncated":false,"body_characters":4496}