{"operation":"document","citation":"CPF 42025006NOA","title":"UGI ENERGY SERVICES — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-08","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2605(b), 193.2605(c), 193.2617(a), 193.2617(b), 193.2619(a), 193.2619(b), 193.2619(c), 193.2619(d), 193.2619(e), 193.2717(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025006noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025006noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025006noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025006NOA","body":"Notice of Amendment involving UGI ENERGY SERVICES. PHMSA's enforcement data identifies the cited regulations as 193.2605(b),  193.2605(c),  193.2617(a),  193.2617(b),  193.2619(a),  193.2619(b),  193.2619(c),  193.2619(d),  193.2619(e),  193.2717(a). The case was opened on 2025-05-08 and is reported as closed as of 2025-07-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025006NOA_Closure Letter_07232025_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025006NOA/42025006NOA_Closure%20Letter_07232025_(24-301886).pdf\n\n42025006NOA_Closure Letter_07232025_(24-301886)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025006NOA/42025006NOA_Closure%20Letter_07232025_(24-301886)_text.pdf\n\n42025006NOA_Notice of Amendment_05082025_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025006NOA/42025006NOA_Notice%20of%20Amendment_05082025_(24-301886).pdf\n\n42025006NOA_Notice of Amendment_05082025_(24-301886)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025006NOA/42025006NOA_Notice%20of%20Amendment_05082025_(24-301886)_text.pdf\n\n42025006NOA_Operator Response to Notice_05292025_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025006NOA/42025006NOA_Operator%20Response%20to%20Notice_05292025_(24-301886).pdf\n\n42025006NOA_Closure Letter_07232025_(24-301886)_text.pdf\n\nVIA ELECTRONIC MAIL TO: jhartz@ugies.com\nJuly 23, 2025\nJoseph Hartz\nPresident\nUGI Energy Services, LLC\n835 Knitting Mills Way\nWyomissing, PA 19610\nRE: CPF 4-2025-006-NOA\nDear Mr. Hartz:\nFrom May 6 to May 8, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nUGI Energy Services, LLC’s (UGI) procedures for operating and maintaining its Temple liquefied\nnatural gas (LNG) facility in Reading, Pennsylvania. As a result of the inspection, UGI was issued\na Notice of Amendment on May 8, 2025, which proposed amendment of your procedures.\nUGI submitted amended procedures in response to the Notice of Amendment on July 1, 2025. My\nstaff has reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Rena Heim, Principal Engineer - Standards & Compliance, UGI Energy Services, LLC,\nrheim@ugies.com\nMegan Comstock, Compliance Engineer, UGI Energy Services, LLC,\nmcomstock@ugies.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections\nOffice of Energy Projects, Federal Energy Regulatory Commission\nAndrew.kohout@ferc.gov\n\n42025006NOA_Notice of Amendment_05082025_(24-301886)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: jhartz@ugies.com\nMay 8, 2025\nJoseph Hartz\nPresident\nUGI Energy Services, LLC\n835 Knitting Mills Way\nWyomissing, PA 19610\nCPF 4-2025-006-NOA\nDear Mr. Hartz:\nFrom May 6 to May 8, 2024, of the on-site inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected UGI Energy Services, LLC’s1 (UGI) procedures for operating and\nmaintaining its Temple liquefied natural gas (LNG) facility in Reading, Pennsylvania.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within UGI’s\nplans or procedures. The items inspected and the inadequacies are described below:\n1. § 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 procedures must include:\n(1) . . . .\n(c) Each operator shall include in the manual required by\nparagraph (b) of this section instructions enabling personnel who\nperform operation and maintenance activities to recognize conditions\nthat potentially may be safety-related conditions that are subject to the\nreporting requirements of § 191.23 of this subchapter.\n1 UGI is a wholly owned subsidiary of UGI Corporation.\n\n\n\nUGI’s written procedures for conducting maintenance activities were inadequate to assure safe\noperation of a pipeline facility in accordance with § 193.2605(c). Specifically, UGI’s procedures,\nTemple I - LNG Maintenance Manual, 009-11-MP-001001 (Rev. 21; June, 13 2024) and Temple\nII Tank and Sendout System Operations Manual, 168281-000-02-MA-000002 (Rev. 13; June 13,\n2024), failed to provide instructions enabling personnel who perform operation and maintenance\nactivities to recognize conditions that potentially may be safety-related conditions that are subject\nto the reporting requirements of § 191.23.\nUGI must revise its procedures to include operator- and facility-specific instructions to assist\npersonnel who perform operation and maintenance activities in recognizing conditions that\npotentially may be safety-related conditions that are subject to the reporting requirements of §\n191.23.\n2. § 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 procedures must include:\n§ 193.2617 Repairs.\n(a) Repair work on components must be performed and tested in a\nmanner which:\n(1) As far as practicable, complies with the applicable requirements\nof Subpart D of this part; and\n(2) Assures the integrity and operational safety of the component\nbeing repaired.\n(b) For repairs made while a component is operating, each operator\nshall include in the maintenance procedures under § 193.2605\nappropriate precautions to maintain the safety of personnel and\nproperty during repair activities.\nUGI’s manuals of written procedures for the maintenance of each component were inadequate\nassure safety during repairs in accordance with § 193.2617. Specifically, UGI’s procedures,\nTemple I - LNG Maintenance Manual, 009-11-MP-001001 (Rev. 21; June, 13 2024) and Temple\nII Tank and Sendout System Operations Manual, 168281-000-02-MA-000002 (Rev. 13; June 13,\n2024), failed to require that repair work on components be performed and tested in a manner which,\nas far as practicable, complies with the applicable requirements of Part 193, Subpart D, in\naccordance with § 193.2617(a)(1). In addition, UGI’s procedures failed to assure the integrity and\noperational safety of the component being repaired in accordance with § 193.2617(a)(2). UGI’s\nprocedures also failed to include appropriate precautions to maintain the safety of personnel and\nproperty for repairs made while a component is operating in accordance with § 193.2617(b).\nUGI must revise its procedures to include operator- and facility-specific instructions for\nconducting repairs in accordance with the requirements of § 193.2617.\n\n\n\n3. § 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 procedures must include:\n§ 193.2619 Control systems.\n(a) Each control system must be properly adjusted to operate within\ndesign limits.\n(b) If a control system is out of service for 30 days or more, it must\nbe inspected and tested for operational capability before returning it to\nservice.\n(c) Control systems in service, but not normally in operation, such\nas relief valves and automatic shutdown devices, and control systems\nfor internal shutoff valves for bottom penetration tanks must be\ninspected and tested once each calendar year, not exceeding 15 months,\nwith the following exceptions:\n(1) Control systems used seasonally, such as for liquefaction or\nvaporization, must be inspected and tested before use each season.\n(2) Control systems that are intended for fire protection must be\ninspected and tested at regular intervals not to exceed 6 months.\n(d) Control systems that are normally in operation, such as required\nby a base load system, must be inspected and tested once each calendar\nyear but with intervals not exceeding 15 months.\n(e) Relief valves must be inspected and tested for verification of the\nvalve seat lifting pressure and reseating.\nUGI’s manuals of written procedures for the maintenance of each component were inadequate to\nassure safety during maintenance on control systems in accordance with § 193.2619. Specifically,\nthe maintenance schedules in UGI’s procedures, Temple I - LNG Maintenance Manual, 009-11-\nMP-001001 (Rev. 21; June, 13 2024) and Temple II Tank and Sendout System Operations Manual,\n168281-000-02-MA-000002 (Rev. 13; June 13, 2024), failed to identify which components are\ncontrol systems and therefore also failed to identify which control systems are intended for fire\nprotection.\nUGI must revise its procedures to identify which components are control systems and the requisite\ninspection interval in accordance with § 193.2619.\n\n\n\n4. § 193.2717 Training: fire protection.\n(a) All personnel involved in maintenance and operations of an\nLNG plant, including their immediate supervisors, must be trained\naccording to a written plan of initial instruction, including plant fire\ndrills, to:\nUGI’s written plan of initial instruction, including plant fire drills, for conducting fire protection\ntraining were inadequate to assure safe operation of a pipeline facility in accordance with §\n193.2717(a). Specifically, UGI’s procedure, LNG Personnel Qualifications And Training Manual\n(Rev. 1, May 29, 2024), failed to require that “[all] personnel involved in maintenance and\noperations of an LNG plant, including their immediate supervisors,” receive fire protection\ntraining.\nUGI must revise its written plan of initial instruction to ensure that “[all] personnel involved in\nmaintenance and operations of an LNG plant, including their immediate supervisors” are trained\nin fire protection in accordance with § 193.2717(a).\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\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 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 60 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.\n\n\n\nIt is requested (not mandated) that UGI maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to 4-2025-\n006-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Alexander Bohr, Senior Supervisor – Compliance Engineering, abohr@ugies.com","truncated":false,"body_characters":12745}