{"operation":"document","citation":"CPF 120163003W","title":"TOTAL PEAKING SERVICES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-11-22","effective_on":null,"summary":"CLOSED warning letter citing 193.2017(a), 193.2639(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120163003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120163003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120163003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120163003W","body":"Warning Letter involving TOTAL PEAKING SERVICES. PHMSA's enforcement data identifies the cited regulations as 193.2017(a),  193.2639(a). The case was opened on 2016-11-22 and is reported as closed as of 2016-11-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120163003W_Warning Letter_11222016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163003W/120163003W_Warning%20Letter_11222016.pdf\n\n120163003W_Warning Letter_11222016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120163003W/120163003W_Warning%20Letter_11222016_text.pdf\n\n120163003W_Warning Letter_11222016_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nNovember 22, 2016\nAnthony Marone\nSenior Vice President, Gas Operations\nAVANGRID Networks\n180 Marsh Hill Rd.\nOrange, CT 06477\nCPF 1-2016-3003W\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.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. §193.2017 Plans and procedures\n(a) 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 failed to maintain at each LNG plant the plans and procedures required for that plant by this\npart. Specifically, the control box for the internal LNG tank shutoff valve was relocated on\nJanuary 29, 2013, but the change to the LNG plant plans and procedures was not made within 20\ndays after the relocation.\nDuring the inspection, the CT DEEP reviewed TPS records from 2013 through\n2015. Preventative Maintenance Work Order (WO) P102490 dated 5/1/2014 was generated to\nconduct a test on the internal valve system. The WO identified the location of the valve as\n\n\n\n1-2016-3003W\nbetween CP30 building and the Expander Compressors. The location was crossed out and a\nhandwritten note stating “control box repiped and moved to the LNG pump house. redue (sp)\nwork order” was included in the corrective action section of the WO. The corrective action was\nreviewed by TPS personnel and signed off on 5/12/2014 and 5/13/2014.\nOn 5/1/2015, TPS generated WO P103266 to conduct a test of the same valve that was tested in\n2014. The WO generated in 2015 did not include the location comments that were noted on the\nWO completed in 2014.\nThus, TPS failed to make each change to the plans or procedures available for review and\ninspection within 20 days after the change was made.\n2. §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-2001\n(incorporated by reference, see §193.2013) requires. Maintenance records, whether\nrequired by this part or NFPA-59A-2001, must be kept for a period of not less than five\nyears.\nTPS failed to keep an accurate record of the date and type of each maintenance activity\nperformed on each component to meet the requirements of this part.\nTPS utilizes a 500kW backup generator to supply auxiliary power to the plant in the event of an\nemergency. TPS conducted an operational test of the generator on April 9, 2015 and recorded\nthe results of the test on WO P103170.\n1. The corrective action section of the record indicated “ran emergency all in good working\norder.”\n2. The operational test section of the record indicated \"0\" output voltage on two of the three\nphases of the output. The record also indicated \"0\" oil pressure, “0” water temperature,\nand inconsistent frequency among the three outputs.\nThe “0” readings are inconsistent with the corrective action section of the record. The record\nwas signed by the TPS person that completed the work, as well as the TPS supervisor, with no\nexplanation of the apparent inconsistencies.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012,\nthe maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty\nnot to exceed $1,000,000 for a related series of violations. Also, for LNG facilities, an\nadditional penalty of not more than $50,000 for each violation may be imposed. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Failure to do so will result in Total\nPeaking Services being subject to additional enforcement action.\n120163003W_Warning Letter_11222016 Page 2 of 3\n\n\n\n1-2016-3003W\nNo reply to this letter is required. If you choose to reply, please address your correspondence to:\nByron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W.\nTrenton, NJ 08628 and please refer to CPF 1-2016-3003W. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document, you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted, and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\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\nCc: Karl Baker, CT DEEP\n120163003W_Warning Letter_11222016 Page 3 of 3","truncated":false,"body_characters":7048}