{"operation":"document","citation":"CPF 12021017NOA","title":"UGI ENERGY SERVICES — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-04-19","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2503(c), 193.2509(b)(3), 193.2509(b)(4), 193.2605(b)(1), 193.2605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021017noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021017noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021017noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021017NOA","body":"Notice of Amendment involving UGI ENERGY SERVICES. PHMSA's enforcement data identifies the cited regulations as 193.2503(c),  193.2509(b)(3),  193.2509(b)(4),  193.2605(b)(1),  193.2605(b)(2). The case was opened on 2021-04-19 and is reported as closed as of 2022-05-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021017NOA_Closure Letter_05032022_(20-172065).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Closure%20Letter_05032022_(20-172065).pdf\n\n12021017NOA_Closure Letter_05032022_(20-172065)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Closure%20Letter_05032022_(20-172065)_text.pdf\n\n12021017NOA_Notice of Amendment_04192021_(20-172065).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Notice%20of%20Amendment_04192021_(20-172065).pdf\n\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Notice%20of%20Amendment_04192021_(20-172065)_text.pdf\n\n12021017NOA_Operator Response to Notice_05192021_(20-172065).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Operator%20Response%20to%20Notice_05192021_(20-172065).pdf\n\n12021017NOA_Order Directing Amendment_03112022_(20-172065).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Order%20Directing%20Amendment_03112022_(20-172065).pdf\n\n12021017NOA_Order Directing Amendment_03112022_(20-172065)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021017NOA/12021017NOA_Order%20Directing%20Amendment_03112022_(20-172065)_text.pdf\n\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: jhartz@ugies.com\nApril 19, 2021\nMr. Joseph Hartz\nVice President Asset Management\nUGI Energy Services\n1 Meridian Blvd\nWyomissing, PA 19610\nCPF 1-2021-017-NOA\nDear Mr. Hartz:\nFrom November 9, 2020 to November 18, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected UGI Energy Services’ (UGI) procedures and records for the Temple LNG Plant\nin Reading, Pennsylvania.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nUGI’s plans or procedures, as described below:\n1. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written\nprocedures to provide safety in normal operation and in responding to\nan abnormal operation that would affect safety. The procedures must\ninclude provisions for:\n(a) …\n(c) Recognizing abnormal operating conditions.\nUGI’s operating procedures were inadequate. Specifically, UGI’s Temple 1- LNG Maintenance\nManual, revised 7/15/20 and LNG Liquefaction System Manual (collectively, Operating\nProcedures) failed to include details for recognizing and responding to abnormal operating\nconditions (AOCs).\nDuring the inspection, the PHMSA inspector requested UGI’s procedures regarding abnormal\noperating conditions, and UGI provided its Operating Procedures. However, the Operating\nProcedures did not provide adequate guidance on how UGI personnel working outside of the\ncontrol room recognize and respond to AOCs, nor do they define or list AOCs that may exist at its\n\n\n\nCPF 1-2021-017-NOA\nLNG plant.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nrecognizing AOCs, UGI stated there was no further procedures.\nTherefore, UGI failed to include details in its manuals of written procedures for recognizing AOCs\nin accordance with § 193.2503(c). UGI must revise its procedures to include provisions for\nrecognizing AOCs.\n2. § 193.2509 Emergency procedures.\n(a) …\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator\nmust follow one or more manuals of written procedures. The\nprocedures must provide for the following:\n(1) Coordinating with appropriate local officials in preparation of\nan emergency evacuation plan, which sets forth the steps required to\nprotect the public in the event of an emergency, including catastrophic\nfailure of an LNG storage tank.\nUGI’s emergency procedures were inadequate. Specifically, UGI’s LNG Emergency Procedures\nManual and Asset Emergency Response Plan, revised 10/01/20 failed to provide details for\ncoordinating with appropriate local officials in preparation of an emergency evacuation plan,\nwhich sets forth the steps required to protect the public in the event of an emergency, including\ncatastrophic failure of an LNG storage tank.\nDuring the inspection, the PHMSA inspector requested UGI’s procedures regarding coordination\nwith local officials in preparation of an emergency evacuation plan. UGI provided its Emergency\nProcedures Manual and Asset Emergency Response Plan related to emergency types/actions and\npointed to the following sections of their manuals, which failed to demonstrate compliance.\nThe Asset Emergency Response Plan, revised 10/01/20, Page 5, stated in part, “The purpose of this\nEmergency Response Plan (ERP) is to provide consistent policies and procedures to manage an\nemergency effectively. This plan will assist in protecting the lives and health of the public and\nUGI Energy Services (UGIES) employees. This plan will provide guidance to protect and\nminimize damage to company property in the event of an emergency and provide protective\nmeasures to ensure minimal impact to the surrounding community during an emergency.”\nThe LNG Emergency Procedures Manual Section 2.4 stated in part, “UGI supervisory personnel\nshall coordinate with local officials keeping them advised of the location of the plant fire control\nequipment, the potential hazards at the plant, and the status of each emergency.”\nThese written procedures did not provide specific details for coordinating with appropriate local\nofficials in preparing emergency evacuation plans, nor did it discuss contents of emergency\nevaluation plans to include steps required to protect the public in the event of an emergency,\nincluding catastrophic failure of an LNG storage tank.\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 2 of 10\n\n\n\nCPF 1-2021-017-NOA\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\ncoordination with local officials in preparation of emergency evacuation plans, UGI did not\nprovide any additional information or response.\nTherefore, UGI failed to provide details for coordinating with appropriate local officials in\npreparation of an emergency evacuation plan in accordance with § 193.2509(b)(3). UGI must\nrevise its LNG Emergency Procedures Manual and Asset Emergency Response Plan to address\nthis requirement.\n3. § 193.2509 Emergency procedures.\n(a) …\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator\nmust follow one or more manuals of written procedures. The\nprocedures must provide for the following:\n(1) …\n(4) Cooperating with appropriate local officials in evacuations and\nemergencies requiring mutual assistance…\nUGI’s emergency procedures were inadequate. Specifically, UGI’s LNG Emergency Procedures\nManual failed to require cooperating with appropriate local officials in evacuations and\nemergencies requiring mutual assistance.\nDuring the inspection, the PHMSA inspector requested UGI’s procedures addressing\n§ 193.2509(b)(4), and UGI provided its Emergency Procedures Manual. The Emergency\nProcedures Manual stated in Section 2.4, “UGI supervisory personnel shall coordinate with local\nofficials keeping them advised of the location of the plant fire control equipment, the potential\nhazards at the plant, and the status of each emergency.”\nHowever, the written procedure did not provide any details or guidance related to the cooperation\nwith local officials in evacuations and emergencies requiring mutual assistance. The Emergency\nProcedures Manual also failed to define or mention any activity or requirement related to\nproviding mutual assistance.\nWhen the PHMSA inspector asked UGI if there were further written procedures regarding mutual\nassistance, UGI stated there were no specific requirements in their procedures on mutual assistance\nevents during evacuations and emergencies.\nTherefore, UGI failed to have emergency procedures which require cooperating with appropriate\nlocal officials in evacuations and emergencies requiring mutual assistance in accordance with\n§ 193.2509(b)(4). UGI must revise its Emergency Procedures Manual to include details\naddressing this requirement.\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 3 of 10\n\n\n\nCPF 1-2021-017-NOA\n4. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance;\nand…\nUGI’s maintenance procedures were inadequate. Specifically, UGI’s LNG Truck Transfer System\nManual, dated 7/10/19 and Temple 1-LNG Maintenance Manual, dated 7/15/20 (collectively,\nTransfer Hose Procedures) failed to provide details regarding testing of transfer hoses once each\ncalendar year, but with intervals not exceeding 15 months, to the maximum pump pressure or relief\nvalve setting in accordance with § 193.2621(a).\nSection 193.2621(a) states:\nHoses used in LNG or flammable refrigerant transfer systems must be:\n(a) Tested once each calendar year, but with intervals not exceeding 15 months, to the\nmaximum pump pressure or relief valve setting;\nDuring the inspection, the PHMSA inspector requested UGI’s procedure regarding testing and\ninspection of transfer hoses. UGI provided its Transfer Hose Procedures related to Temple I, as\nthis is the only area with a truck transfer system. The Temple 1-LNG Maintenance Manual, dated\n7/15/20, Sections 2.E. Trucking System and 2.F. Truck Rack Expansion System included a\nrequirement for a truck transfer hose pressure test to be performed at a 12-month frequency.\nHowever, the Transfer Hose Procedures did not provide a procedure requiring that each transfer\nhose must be tested to the maximum pump pressure or relief valve setting, or any details on how\nthe truck transfer hose pressure test is performed.\nWhen the PHMSA inspector requested additional information related to testing of transfer hoses,\nUGI did not provide any additional information or response.\nTherefore, UGI failed to include details in its written procedures that transfer hoses must be tested\nonce each calendar year, but with intervals not exceeding 15 months, to the maximum pump\npressure or relief valve setting in accordance with § 193.2621(a), as required by §193.2605(b).\nUGI must revise its Transfer Hose Procedures to include a detailed procedure for testing transfer\nhoses in accordance with § 193.2621(a).\n5. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance;\nand…\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 4 of 10\n\n\n\nCPF 1-2021-017-NOA\nUGI’s maintenance procedures were inadequate. Specifically, UGI’s Temple 1-LNG Maintenance\nManual, dated 7/15/20 and Temple II Tank and Sendout System Operations Manual, dated\n10/17/19 failed to address how it monitors for internal corrosion in accordance with the\nrequirements of § 193.2635(e).\nSection 193.2635(e) states:\nCorrosion protection provided as required by this subpart must be periodically monitored to\ngive early recognition of ineffective corrosion protection, including the following, as\napplicable:\n…\n(e) If a component is protected from internal corrosion, monitoring devices designed to\ndetect internal corrosion, such as coupons or probes, must be located where corrosion is most\nlikely to occur. However, monitoring is not required for corrosion resistant materials if the\noperator can demonstrate that the component will not be adversely affected by internal\ncorrosion during its service life. Internal corrosion control monitoring devices must be\nchecked at least two times each calendar year, but with intervals not exceeding 7 1/2 months.\nDuring the inspection, the PHMSA inspector requested UGI’s procedure regarding internal\ncorrosion monitoring. UGI provided its Temple 1-LNG Maintenance Manual and Temple II\nTank and Sendout System Operations Manual.\nThe Temple 1-LNG Maintenance Manual, procedure MP-45 Corrosion Protection, stated in part,\n“Per CFR Part 193.2636, WEG1 sampling and testing is to be conducted on a 6-month interval\nand not to exceed 7-months” …and that the protection systems are the “Corrosion inhibitors\ncontained within WEG and lube oil fluid.”\nThe Temple 1-LNG Maintenance Manual, however, referenced a non-existent code citation from\nCFR Part 193.\nThe Temple II Tank and Sendout System Operations Manual, procedure MP-1110 stated in part,\n“The WEG should be checked on an annual basis for the following attributes\n% glycol, PH, Corrosion inhibitor…”\nThe Temple 1-LNG Maintenance Manual, dated 7/15/20 and Temple II Tank and Sendout System\nOperations Manual, dated 10/17/19 failed to mention which components are subject to internal\ncorrosive attack and how they are protected from internal corrosion. Additionally, the Procedures\nfailed to describe UGI’s internal corrosion monitoring device requirements, including details such\nas where they are required or if any protected components utilizing corrosion resistant materials\nare excepted from monitoring.\nWhen the PHMSA inspector asked for additional information regarding internal corrosion\nmonitoring, UGI stated the CFR reference was outdated, however the WEG testing is conducted.\nTherefore, UGI failed to include details in its written Procedures for Temple I and Temple II\nregarding internal corrosion monitoring in accordance with § 193.2635(e), as required by\n1 Water-Ethylene Glycol\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 5 of 10\n\n\n\nCPF 1-2021-017-NOA\n§ 193.2605(b). UGI must revise its procedures to address § 193.2635(e).\n6. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance;\nand…\nUGI’s maintenance procedures were inadequate. Specifically, UGI’s Temple 1-LNG Maintenance\nManual, dated 7/15/20 and Temple II Tank and Sendout System Operations Manual, dated\n10/17/19 failed to provide adequate guidance requiring each auxiliary power source to be tested\nannually for capacity in accordance with § 193.2613.\nSection 193.2613 states:\nEach auxiliary power source must be tested monthly to check its operational capability and\ntested annually for capacity. The capacity test must take into account the power needed to\nstart up and simultaneously operate equipment that would have to be served by that power\nsource in an emergency.\nDuring the inspection, the PHMSA inspector requested UGI’s procedure regarding auxiliary\npower sources. The Temple 1-LNG Maintenance Manual Procedure stated in part (emphasis\nadded):\nThe Temple I facility’s temporary auxiliary power source is provided by a CUMMINS 500\nDFEK SPEC F, diesel fueled generator. The generator has a load capacity of 500KW for the\nfacility’s 480 VAC service. Load is transferred to the generator by way of an automatic transfer\nswitch.\nFrequency: Operational Test – Monthly\nCapacity Load Test – Annually\n…\nB. Capacity Load Test\nNote: The following procedure only needs to be performed if a commercial power outage\nhas not occurred in the prior 12-months.\nSimilarly, the Temple II Tank and Sendout System Operations Manual Procedure Section 15.51\nstated in part (emphasis added):\nGeneral: The Temple II facility’s standby power source is provided by Kawasaki GPS4000\nnatural gas turbine generator. The generator has a load capacity of 3.2MW for the facility’s\n4160V service.\nFrequency:\nOperational Test – Monthly\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 6 of 10\n\n\n\nCPF 1-2021-017-NOA\nCapacity Load Test – Annually\n…\nC. Capacity Load Test\nNote: The following procedure only needs to be performed if a commercial power outage\nrequiring the generator’s operation has not occurred in the prior 12-months.\nThe Auxiliary Power Procedures did not provide an adequate process that ensures that each\nauxiliary power source is tested annually for capacity, with the capacity test taking into account\nthe power needed to start up and simultaneously operate equipment that would have to be served\nby that power source in an emergency. A commercial power outage resulting in the generator’s\noperation may not provide an adequate test of the capacity of the power source as described in\n§ 193.2613.\nTherefore, UGI failed to include adequate details in its written maintenance procedures that each\nauxiliary power source is to be tested annually for capacity in accordance with § 193.2613, as\nrequired by § 193.2605(b). UGI must revise its procedures to require annual capacity testing of\nauxiliary power sources, and for the capacity testing to account for the specific requirements of\n§ 193.2613.\n7. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance;\nand…\nUGI’s maintenance procedures were inadequate. Specifically, UGI’s Temple II Tank and Sendout\nSystem Operations Manual, dated 10/17/19 failed to provide details regarding fire protection\ninspection frequencies for Temple II facilities, in accordance with § 193.2619(c)(2).\nSection 193.2619(c)(2) states:\n(c) Control systems in service, but not normally in operation, such as\nrelief valves and automatic shutdown devices, and control systems for\ninternal shutoff valves for bottom penetration tanks must be inspected and\ntested once each calendar year, not exceeding 15 months, with the following\nexceptions:\n(2) Control systems that are intended for fire protection must be\ninspected and tested at regular intervals not to exceed 6 months.\nDuring the inspection, the PHMSA inspector requested UGI’s procedure regarding control systems\nmeeting the requirements of § 193.2619(c)(2). UGI provided its procedures regarding control\nsystems for Temple II facilities.\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 7 of 10\n\n\n\nCPF 1-2021-017-NOA\nThe Temple II Tank and Sendout System Operations Manual, Procedure MP-1055 Fire\nDetection/Fire Protection Test and Inspection, included a process for testing its Detronics fire\ndetection system. However, these procedures did not provide any details or guidance requiring\nthat control systems intended for fire protection must be inspected and tested at regular intervals\nnot to exceed 6 months. When the PHMSA inspector asked if this information was contained in\nany UGI procedures, UGI provided Table 15.2.3 Temple II Sendout System Maintenance.\nHowever, this document was not incorporated or referenced in any UGI Procedures, nor did it\nappear to address inspection frequencies for all control systems intended for fire protection.\nTherefore, UGI failed to include details in its written procedures for Temple II facilities that control\nsystems intended for fire protection must be inspected and tested at regular intervals not to exceed\n6 months in accordance with § 193.2619(c)(2), as required by § 193.2605(b). UGI must revise its\nprocedures to provide details for fire protection control system inspection frequencies for its\nTemple II facilities.\n8. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance;\nand…\nUGI’s maintenance procedures were inadequate. Specifically, UGI’s Temple 1-LNG Maintenance\nManual, dated 7/15/20 and Temple II Tank and Sendout Systems Operations Manual, dated\n10/17/19 failed to provide details on inspecting LNG storage tank Temple T-II in accordance with\n§ 193.2623.\nSection 193.2623 states:\nEach 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\nor geophysical disturbance.\n(b) Inner tank leakage.\n(c) Effectiveness of insulation.\n(d) Frost heave.\nDuring the inspection, the PHMSA inspector requested UGI’s procedure regarding inspecting\nLNG storage tanks. UGI provided the written Tank Procedures related to Temple I and Temple II\nLNG storage tanks.\nThe Temple II Tank and Sendout Systems Operations Manual, Section 15.1, General stated in part,\n“In addition to the normal maintenance procedure, all LNG personnel shall note and report in\nwriting: Any abnormal ground movements that might impair the structural integrity, or reliability\nthe LNG-tank or plant piping systems.\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 8 of 10\n\n\n\nCPF 1-2021-017-NOA\n-Any malfunction that exposes process piping or vessels or the LNG-tank to an\noverpressure condition (beyond maximum operating pressure plus allowable build-up).\n-Any leak of gas or LNG from piping or vessels.\n-Any condition such as inner-tank leakage, ineffective insulation, or frost heave that\nimpairs the structural integrity of the LNG tank.”\nHowever, the Procedures did not provide any details or guidance on how UGI inspects or tests\nTemple Tank T-II for inner tank leakage, effectiveness of insulation and frost heave.\nWhen the PHMSA inspector asked UGI about the related Procedure, UGI stated that there are no\nprocesses or procedures for these inspections or tests because it is a concrete walled tank.\nHowever, Section 193.2623 does not provide exception for concrete walled tanks.\nTherefore, UGI failed to include details in its written procedures on inspecting or testing LNG\nstorage tank Temple T-II, as required by § 193.2605(b). UGI must revise its procedures to include\na process for inspecting or testing Temple T-II in accordance with § 193.2623.\n9. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedure must include:\n(1) …\n(2) A description of other actions necessary to maintain the LNG\nplant according to the requirements of this subpart.\nUGI’s maintenance procedures were inadequate. Specifically, UGI’s Temple 1-LNG Maintenance\nManual, dated 7/15/20 failed to include details that the LNG plant grounds must be free from\nrubbish, debris, and other material which present a fire hazard in accordance with § 193.2607(b).\nSection 193.2607(b) states:\nLNG plant grounds must be free from rubbish, debris, and other material which present a\nfire hazard. Grass areas on the LNG plant grounds must be maintained in a manner that does\nnot present a fire hazard.\nDuring the inspection, the PHMSA inspector requested UGI’s procedures regarding their process\nto maintain the facility to be free from the presence of foreign material and debris. UGI provided\nits Temple 1-LNG Maintenance Manual, dated 7/15/20, which failed to indicate any such\nrequirement.\nWhen the PHMSA inspector requested if there were additional procedures or guidance related to\nmaintaining the facility free from the presence of foreign material and debris, UGI did not provide\nany additional information or response.\nTherefore, UGI failed to include details in its written procedures that the LNG plant grounds must\nbe free from rubbish, debris, and other material which present a fire hazard in accordance with\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 9 of 10\n\n\n\nCPF 1-2021-017-NOA\n§ 193.2607(b), as required by §193.2605(b). UGI must revise its procedures to address this\nrequirement.\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 Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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. If you do not respond within 30 days of\nreceipt of this Notice, this 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 Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, 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 enforcement\naction will be closed.\nIt is requested (not mandated) that UGI Energy 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 Robert Burrough, Director, PHMSA Eastern Region,\n840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. In correspondence concerning this\nmatter, please refer to CPF 1-2021-017-NOA and, for each document you submit, please provide\na copy in electronic format whenever possible. Smaller files may be emailed to\nrobert.burrough@dot.gov. Larger files should be sent on 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\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12021017NOA_Notice of Amendment_04192021_(20-172065)_text Page 10 of 10\n\n12021017NOA_Closure Letter_05032022_(20-172065)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 3, 2022\nMr. Dante D’ Alessandro\nVice President – Engineering and Operations\nUGI Energy Services\n1 Meridian Boulevard\nWyomissing, PA 19610\nCPF 1-2021-017-NOA\nDear Mr. D’Alessandro:\nFrom November 9, 2020 to November 18, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) inspected UGI Energy Services’ (UGI) procedures for the\nTemple LNG Plant in Reading, Pennsylvania. As a result of the inspection, UGI was issued a\nNotice of Amendment (NOA) on April 19, 2021, which proposed amendment of your procedures.\nOn August 6, 2021 UGI submitted its amended procedures for items 2 – 9, only. On March 11,\n2022, PHMSA issued an Ordering Directing Amendment (Order) to UGI requiring UGI to amend\ncertain portions of its procedures. On April 18, 2022 UGI provided its response to the Order. My\nstaff reviewed the amended procedures, and it appears that the inadequacies outlined in this Order\nhave been corrected.\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\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12021017NOA_Order Directing Amendment_03112022_(20-172065)_text.pdf\n\nMarch 11, 2022\nVIA ELECTRONIC MAIL TO: ddalessandro@ugies.com\nMr. Dante D’Alessandro\nVice President – Engineering and Operations\nUGI Energy Services\n1 Meridian Boulevard\nWyomissing, Pennsylvania 19610\nRe: CPF No. 1-2021-017-NOA\nDear Mr. D’Alessandro:\nEnclosed please find the Order Directing Amendment issued in the above-referenced case to\nUGI Energy Services, LLC (UGIES). It makes findings of inadequate procedures, finds that\ncertain amended procedures provided by UGIES are adequate, and requires UGIES to amend\ncertain portions of its procedures for the Temple LNG Plant in Reading, Pennsylvania. When\nthe amendment of procedures has been completed, as determined by the Director, Eastern\nRegion, this enforcement action will be closed. Service of the Order by email is complete upon\ntransmission and acknowledgement of receipt, as provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA\nMr. Jeremy Kuhn, Manager, Pipeline Engineering & Compliance, UGIES,\njkuhn@ugies.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nUGI Energy Services, LLC, ) CPF No. 1-2021-017-NOA\n)\n)\n)\nRespondent. )\n____________________________________)\nORDER DIRECTING AMENDMENT\nFrom November 9, 2020 to November 18, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected UGI Energy Services, LLC’s (UGIES or Respondent) procedures and records\nfor the Temple LNG Plant in Reading, Pennsylvania.\nAs a result of the inspection, the Director, Eastern Region, OPS, issued to Respondent, by letter\ndated April 19, 2021, a Notice of Amendment (Notice). In accordance with 49 C.F.R. § 190.206,\nthe Notice proposed finding that certain of UGIES’s plans and procedures were inadequate to\nassure safe operation and proposed that Respondent amend its procedures for operations,\nmaintenance, and emergencies.\nUGIES responded to the Notice by letter dated May 19, 2021 (Response). In its Response,\nUGIES contested Item 1 of the Notice, but did not contest the remaining eight items. On August\n6, 2021, UGIES provided amended procedures in response to Item 2 through 9 of the Notice for\nreview and approval by the Director, Eastern Region. The company did not request a hearing\nand therefore waived its right to one.\nFINDING OF INADEQUATE PROCEDURES\nItem 1: The Notice alleged that Respondent’s procedures were inadequate with regard to\n49 C.F.R. § 193.2503(c), which states:\n§ 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written procedures\nto provide safety in normal operation and in responding to an abnormal\noperation that would affect safety. The procedures must include provisions\nfor:\n(a) . . . .\n(c) Recognizing abnormal operating conditions.\n\n\n\nCPF No. 1-2021-017-NOA\nPage 2\nThe Notice alleged that UGIES’s operating procedures were inadequate for recognizing and\nresponding to abnormal operating conditions (AOCs) with regard to § 193.2503(c). Specifically,\nthe Notice alleged the company’s procedures failed to provide adequate guidance on how UGIES\npersonnel working outside of the control room were to recognize and respond to AOCs.\nIn its Response, UGIES contested this allegation of inadequacy. Specifically, UGIES stated that\nits written alarm monitoring and response procedures discuss possible AOC scenarios for various\nassociated systems as well as resolutions to the AOCs identified. Further, UGIES points to\nsubsections in its alarm monitoring procedures that discuss how to handle AOCs when personnel\nare outside of the control room. Based on those references, UGIES argued that its procedures are\nadequate for safety and satisfy the applicable regulatory requirements.\nHaving reviewed UGIES procedure titled “Remote Alarm Monitoring” (Procedure), I find that it\nlacks sufficient detail to assure safe operation with regard to § 193.2503(c). While the Procedure\ndid include references to how personnel are to respond to certain alarms, it lacked adequate detail\nto clarify how operator personnel are to recognize and respond to all AOCs that would affect\nsafety. Specifically, the Procedure failed to establish the specific types of alarms received by the\nremote alarm monitoring system (for example, does the remote alarm monitoring system receive\nall the alarms the control center receives or only certain ones), how the Gas Operations\nSupervisor (GSOS) conducting the monitoring should contact appropriate personnel if they are\nunable to contact the LNG Technician on-call, and how the remote alarm incidents are\ndocumented. Further, the Procedure did not specify under what alarm scenarios the LNG\nTechnician should instruct the GSOS to conduct emergency shutdown (ESD). Additionally, the\nprocedures fail to specify whether other measures must be in place to respond to the AOC when\ninitiating ESD is not appropriate.\nAccordingly, based upon a review of all the evidence, I find that Respondent’s Procedure was\ninadequate, as alleged in the Notice, and revisions are required to include the additional\ninformation and clarifications referenced above in order to assure safety with regard to\n§ 193.2503(c).\nItem 2: The Notice alleged that Respondent’s procedures were inadequate with regard to\n49 C.F.R. § 193.2509(b)(3), which states:\n§ 193.2509 Emergency procedures.\n(a) . . . .\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator must\nfollow one or more manuals of written procedures. The procedures must\nprovide for the following:\n(3) Coordinating with appropriate local officials in preparation of an\nemergency evacuation plan, which sets forth the steps required to protect\nthe public in the event of an emergency, including catastrophic failure of an\nLNG storage tank.\nThe Notice alleged that UGIES’s emergency procedures were inadequate with regard to\n\n\n\nCPF No. 1-2021-017-NOA\nPage 3\n§ 193.2509(b)(3).1 In its Response, UGIES provided its amendments. The Director, Eastern\nRegion, reviewed the amended procedure and concluded that the inadequacies had been corrected.\nAccordingly, based upon a review of all the evidence, I find that Respondent’s procedures were\ninadequate, as alleged in the Notice, but have subsequently been adequately modified. Therefore,\nno further action is necessary with regard to this Item.\nItem 3: The Notice alleged that Respondent’s operations and maintenance procedures were\ninadequate with regard to 49 C.F.R. § 193.2509(b)(4), which states:\n§ 193.2509 Emergency procedures.\n(a) . . . .\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator must\nfollow one or more manuals of written procedures. The procedures must\nprovide for the following:\n(1) . . . .\n(4) Cooperating with appropriate local officials in evacuations and\nemergencies requiring mutual assistance and keeping those officials advised\nof:\nThe Notice alleged that UGIES’s emergency procedures were inadequate with regard to\n§ 193.2509(b)(4). In its Response, UGIES provided its amendments. The Director, Eastern\nRegion, reviewed the amended procedure and concluded that the inadequacies had been corrected.\nAccordingly, based upon a review of all the evidence, I find that Respondent’s procedures were\ninadequate, as alleged in the Notice, but have subsequently been adequately modified. Therefore,\nno further action is necessary with regard to this Item.\nItems 4 through 7: The Notice alleged that Respondent’s operations and maintenance\nprocedures were inadequate with regard to 49 C.F.R. § 193.2605(b)(1), which states:\n§ 193.2605 Maintenance procedures.\n(a) . . . .\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any required\ncorrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under paragraph\n(a) of this section and their frequency of performance; and\nThe Notice alleged that UGIES’s emergency procedures were inadequate with regard to\n§ 193.2605(b)(1). In its Response, UGIES provided its amendments. The Director, Eastern\nRegion, reviewed the amended procedure and concluded that the inadequacies had been corrected.\n1 It appears the Notice contained a typographical error and cited this regulation as § 193.2509(b)(1).\n\n\n\nCPF No. 1-2021-017-NOA\nPage 4\nAccordingly, based upon a review of all the evidence, I find that Respondent’s procedures were\ninadequate, as alleged in the Notice, but have subsequently been adequately modified. Therefore,\nno further action is necessary with regard to these Items.\nItem 8: The Notice alleged that Respondent’s operations and maintenance procedures were\ninadequate with regard to 49 C.F.R. § 193.2605(b)(1), which states:\n§ 193.2605 Maintenance procedures.\n(a) . . . .\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any required\ncorrosion control. The procedure must include:\n(1) The details of the inspections or tests determined under paragraph\n(a) of this section and their frequency of performance; and\nThe Notice alleged that UGIES’s emergency procedures were inadequate with regard to\n§ 193.2605(b)(1). In its Response, UGIES did not contest the allegation and provided its\namendments. The Director, Eastern Region, reviewed the amended procedures and found certain\ninadequacies still remain. Although the amendments clarified the temperature monitoring\nsystem and added a visual inspection of the outer tank if an alarm sounds, they did not contain\nadequate detail regarding the visual inspection requirement. In particular, the amended\nprocedures state that a visual inspection shall be performed if an alarm is received, but do not\ndescribe the process for conducting and documenting these inspections. The amended\nprocedures also do not include a requirement that a visual inspection of the outer tank be\nconducted within a specified interval of time if an alarm is not received. The procedures did not\ninclude a process for responding to issues discovered during a visual inspection. In addition, the\nprocedures did not include requirements that temperature transmitter calibration and testing be\nconducted at a specified frequency and documented.\nAccordingly, based upon a review of all the evidence, I find that Respondent’s emergency\nprocedures were inadequate, as alleged in the Notice, and revisions are required to include the\nadditional information and clarifications referenced above in order to assure safety with regard to\n§ 193.2605(b)(1).\nItem","truncated":true,"body_characters":42794}