{"operation":"document","citation":"CPF 120163002M","title":"TOTAL PEAKING SERVICES — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-11-22","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2017(a), 193.2605(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120163002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120163002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120163002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120163002M","body":"Notice of Amendment involving TOTAL PEAKING SERVICES. PHMSA's enforcement data identifies the cited regulations as 193.2017(a),  193.2605(b). The case was opened on 2016-11-22 and is reported as closed as of 2017-02-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120163002M_Closure Letter_02232017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163002M/120163002M_Closure%20Letter_02232017.pdf\n\n120163002M_Closure Letter_02232017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163002M/120163002M_Closure%20Letter_02232017_text.pdf\n\n120163002M_Notice of Amendment_11222016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163002M/120163002M_Notice%20of%20Amendment_11222016.pdf\n\n120163002M_Notice of Amendment_11222016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163002M/120163002M_Notice%20of%20Amendment_11222016_text.pdf\n\n120163002M_Operator Response to Notice_12192016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163002M/120163002M_Operator%20Response%20to%20Notice_12192016.pdf\n\n120163002M_Closure Letter_02232017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 23, 2017\nAnthony Marone\nSenior Vice President, Gas Operations\nAVANGRID Networks\n180 Marsh Hill Road\nOrange, CT 06477\nCPF 1-2016-3002M\nDear Mr. Marone:\nBetween February 22-26, 2016, inspectors from the Connecticut Department of Energy and\nEnvironmental Protection (CT DEEP), acting as agents for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nTotal Peaking Services’ (TPS) procedures, records, and LNG plant facilities in Milford, CT. As a\nresult of the inspection, TPS was issued a Notice of Amendment on November 22, 2016, which\nproposed amendment of your procedures.\nTPS submitted its amended procedures on December 19, 2016. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120163002M_Notice of Amendment_11222016_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nNovember 22, 2016\nAnthony Marone\nSenior Vice President, Gas Operations\nAVANGRID Networks\n180 Marsh Hill Road\nOrange, CT 06477\nCPF 1-2016-3002M\nDear Mr. Marone:\nBetween February 22-26, 2016, inspectors from the Connecticut Department of Energy and\nEnvironmental Protection (CT DEEP), acting as agents for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nTotal Peaking Services’s (TPS) procedures, records, and LNG plant facilities in Milford, CT.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTPS’s plans or procedures, as described below:\n1. §193.2605 Maintenance procedures.\nb) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The procedures\nmust include:\n(1) The details of the inspections or tests determined under paragraph (a) of this section\nand their frequency of performance; and\n(2) A description of other actions necessary to maintain the LNG plant according to the\nrequirements of this subpart.\nTPS’s procedures were inadequate in that they failed to clearly identify the specific piping that\nmust be included in the atmospheric corrosion control preventive maintenance inspections.\nTPS performed atmospheric corrosion checks on the piping downstream of the vaporizers in\naccordance with Preventive Maintenance (PM) Work Order form PM ID Number 352. The\n\"work requested\" field on PM ID Number 352 stated “HE-86-A, B &C Vaporizers, Evaluate &\nPaint Necessary Piping, Evaluate & Paint Equipment and Necessary Piping as needed.” The\n\n\n\n1-2016-3002M\nphrase “necessary piping” does not provide sufficient guidance on what piping is included in the\ninspection, such as the piping outside of the vaporizer building.\n2. §193.2017 Plans and procedures\na) Each operator shall maintain at each LNG plant the plans and procedures required for\nthat plant by this part. The plans and procedures must be available upon request for\nreview and inspection by the Administrator or any State Agency that has submitted a\ncurrent certification or agreement with respect to the plant under the pipeline safety laws\n(49 U.S.C. 60101 et seq.). In addition, each change to the plans or procedures must be\navailable at the LNG plant for review and inspection within 20 days after the change is\nmade.\nTPS procedures for maintaining a system of records as evidence that personnel have undergone\nand satisfactorily completed the required training programs as per §193.2719(a)(2) were\ninadequate. §193.2719(a)(2) states that: Each operator shall maintain a system of records\nwhich—(2) Provide evidence that personnel have undergone and satisfactorily completed the\nrequired training programs.\nDuring the inspection, CT DEEP inspectors reviewed TPS Preventative Maintenance Work\nOrder records for firefighting training and operating manual review. The bottom of each record\nprovided six blank spaces for the following information:\n“Completed By:______________ Completion Date:__/__/__\nSIGN OFF: Production __/__/__ Maintenance __/__/__\nSigned: ___________________ _____________________”\nTPS personnel indicated that the work orders for training are generated automatically at the\nrequired interval, and that once training is completed, personnel and supervisors sign off on the\nwork order prior to closing it. CT DEEP’s review of training work orders identified\ninconsistencies in how the records labelled PM ID numbers 303 and 464 were completed such\nas:\n1. 2. 3. “Completed by” was initialed, printed or signed\n“Signed” was signed, initialed or blank\n“Maintenance” and “Completed Date” were completed or blank\nIn addition,\nTPS’s procedures did not provide sufficient guidance on items such as:\n1. Individuals responsible for completing each field on the form\n2. Entries that must be printed\n3. Entries that must be signed\n4. Requirements for stamping and signing as “CLOSED”\n3. §193.2017 Plans and procedures\na) Each operator shall maintain at each LNG plant the plans and procedures required for\nthat plant by this part. The plans and procedures must be available upon request for\nreview and inspection by the Administrator or any State Agency that has submitted a\ncurrent certification or agreement with respect to the plant under the pipeline safety laws\n120163002M_NOA_11222016 Page 2 of 4\n\n\n\n1-2016-3002M\n(49 U.S.C. 60101 et seq.). In addition, each change to the plans or procedures must be\navailable at the LNG plant for review and inspection within 20 days after the change is\nmade.\nTPS’s procedures for ensuring that each change to the plans or procedures were available at the\nLNG plant for review and inspection within 20 days after the change is made were\ninadequate. Specifically, TPS’s procedures did not include details on items such as:\n1. The process for ensuring that verbal and input from field personnel are taken into\nconsideration\n2. Documentation of decisions made related to input received field personnel.\n4. §193.2605 Maintenance procedures.\nb) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The procedures\nmust include:\n(1) The details of the inspections or tests determined under paragraph (a) of this section\nand their frequency of performance; and\n(2) A description of other actions necessary to maintain the LNG plant according to the\nrequirements of this subpart.\nTPS’s procedures for thermographic inspection of an LNG tank using an infrared (IR)\nthermometer were inadequate to maintain the LNG plant according to the requirements of this\nsubpart. §193.2623 states that:\n“Each LNG storage tank must be inspected or tested to verify that each of the following\nconditions does not impair the structural integrity or safety of the tank:\n(a) Foundation and tank movement during normal operation and after a major meteorological or\ngeophysical disturbance.\n(b) Inner tank leakage.\n(c) Effectiveness of insulation.\n(d) Frost heave”\nTPS Work Order form PM ID Number 338 does record temperature readings at designated\nnumbered locations on the LNG tank; however, other factors that could affect the temperature\nreadings, such as the ambient temperature, frost, or cloud cover, are not recorded.\nTPS’s procedures failed to provide details such as:\n1. Collection and assessment of specific information that could indicate a potential\nproblem, such as\na. Readings that fall outside of a typical range\nb. The presence of frost\n2. Conditions under which the inspection must be performed (such as on overcast days to\neliminate the heating effects of sunlight).\n3. Documentation requirements.\n120163002M_NOA_11222016 Page 3 of 4\n\n\n\n1-2016-3002M\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document, you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted, and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. Failure to respond within 30 days of\nreceipt of this Notice constitutes a waiver of your right to contest the allegations in this Notice,\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this\nNotice without further notice to you, and to issue an Order Directing Amendment. If your plans\nor procedures are found inadequate as alleged in this Notice, you may be ordered to amend your\nplans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting\nthis Notice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that Total Peaking Services maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Byron E. Coy, PE, Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. In correspondence concerning this\nmatter, please refer to CPF 1-2016-3002M and, for each document you submit, please provide a\ncopy in electronic format whenever possible.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\nCc: Karl Baker, CT DEEP\n120163002M_NOA_11222016 Page 4 of 4","truncated":false,"body_characters":11858}