{"operation":"document","citation":"CPF 120195004W","title":"TOTAL PEAKING SERVICES — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-04-02","effective_on":null,"summary":"CLOSED warning letter citing 193.2619(c)(2), 193.2717(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120195004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120195004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120195004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120195004W","body":"Warning Letter involving TOTAL PEAKING SERVICES. PHMSA's enforcement data identifies the cited regulations as 193.2619(c)(2),  193.2717(b). The case was opened on 2019-04-02 and is reported as closed as of 2019-04-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120195004W_Warning Letter_04022019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120195004W/120195004W_Warning%20Letter_04022019.pdf\n\n120195004W_Warning Letter_04022019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120195004W/120195004W_Warning%20Letter_04022019_text.pdf\n\n120195004W_Warning Letter_04022019_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 2, 2019\nAnthony Marone\nSenior Vice President, Gas Operations\nAVANGRID Networks\nTotal Peaking Services\n180 Marsh Hill Rd.\nOrange, CT 06477\nCPF 1-2019-5004W\nDear Mr. Marone:\nOn April 24 to April 30, 2018, an inspector from the Connecticut Department of Energy and\nEnvironmental Protection (CT DEEP), acting as Agent for Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of\nTitle 49 of the United States Code inspected Total Peaking Services’ (TPS) records and procedures\nat its LNG plant located in Bridgeport, Connecticut.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 193.2619 Control Systems\n…\n(c) Control systems in service, but not normally in operation, such as relief\nvalves and automatic shutdown devices, and control systems for internal shutoff\nvalves for bottom penetration tanks must be inspected and tested once each\ncalendar year, not exceeding 15 months, with the following exceptions:\n…\n(2) Control systems that are intended for fire protection must be inspected and\ntested at regular intervals not to exceed 6 months.\nTPS failed to inspect and test at regular intervals not to exceed 6 months, control systems that are\nintended for fire protection. Specifically, TPS failed to inspect and test UV detection at intervals\nnot to exceed 6 months.\n\n\n\nCPF 1-2019-5004W\nDuring the inspection, the CT DEEP inspector reviewed TPS’s Preventive Maintenance Work\nOrders from April 2016 to September 2017. Records provided showed UV detection inspections\nand tests were performed on 7/14/2016 and 9/18/2017. The interval between inspections and\ntests exceeded 6 months.\nTherefore, TPS failed to inspect and test a control system that is intended for fire protection, UV\ndetection, at regular intervals not to exceed 6 months.\n2. § 193.2717 Training, fire protection.\n…\n(b) A written plan of continuing instruction, including plant fire drills, must be\nconducted at intervals of not more than 2 years to keep personnel current on the\nknowledge and skills they gained in the instruction under paragraph (a) of this\nsection.\nTPS failed to conduct plant fire drills at intervals of not more than 2 years to keep personnel\ncurrent on the knowledge and skills they gained in the instruction under § 193.2717(a).\nDuring the inspection, the CT DEEP inspector reviewed records of TPS’s plant fire drills. The\nrecords demonstrated that TPS performed plant fire drills on November 12, 2014 and November\n29, 2016. This exceeds the maximum interval of 2 years by 17 days. Upon being informed of\nthis issue, TPS stated they will change the recurrence on this work order to 21 months to provide\nadequate time to complete future plant fire drills within the required interval.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential 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 confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300,\nWest Trenton, NJ 08628. Please refer to CPF 1-2019-5004W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120195004W_Warning Letter_04022019_text Page 2 of 2","truncated":false,"body_characters":4858}