{"operation":"document","citation":"CPF 42025007NOPV","title":"UGI ENERGY SERVICES — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-10-01","effective_on":null,"summary":"CLOSED notice of probable violation citing 193.2503(g), 193.2505(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025007nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025007nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025007nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025007NOPV","body":"Notice of Probable Violation involving UGI ENERGY SERVICES. PHMSA's enforcement data identifies the cited regulations as 193.2503(g),  193.2505(a). The case was opened on 2025-10-01 and is reported as closed as of 2026-04-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025007NOPV_Closure Letter_04092026_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_Closure%20Letter_04092026_(24-301886).pdf\n\n42025007NOPV_Closure Letter_04092026_(24-301886)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_Closure%20Letter_04092026_(24-301886)_text.pdf\n\n42025007NOPV_Final Order_12232025_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_Final%20Order_12232025_(24-301886).pdf\n\n42025007NOPV_Final Order_12232025_(24-301886)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_Final%20Order_12232025_(24-301886)_text.pdf\n\n42025007NOPV_Operator Response to Notice and Request for Informal Consultation_10302025_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_Operator%20Response%20to%20Notice%20and%20Request%20for%20Informal%20Consultation_10302025_(24-301886).pdf\n\n42025007NOPV_PCO_10012025_(24-301886).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_PCO_10012025_(24-301886).pdf\n\n42025007NOPV_PCO_10012025_(24-301886)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025007NOPV/42025007NOPV_PCO_10012025_(24-301886)_text.pdf\n\n42025007NOPV_Closure Letter_04092026_(24-301886)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nVIA ELECTRONIC MAIL TO: jhartz@ugies.com\nApril 9, 2026\nJoseph Hartz\nPresident\nUGI Energy Services, LLC\n835 Knitting Mills Way\nWyomissing, PA 19610\nCPF 4-2025-007-NOPV\nDear Mr. Hartz:\nOn December 23, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to UGI Energy Services, LLC’s (UGI). a Final Order in the above-referenced case. This\nOrder included a Compliance Order.\nBased on our review of the documentation you provided, it has been determined that UGI has\ncomplied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\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\nDante D’Alessandro, Vice President, Global Engineering, UGI Energy Services, LLC,\nddalessandro@ugies.com\nBrianne Kurdock, Esq, Babst Calland, BKurdock@babstcalland.com\n\n\n\nLindsay Berkstresser, Energy and Regulatory Counsel, UGI Energy Services, LLC,\nberkstresserl@ugicorp.com\nTyler Chlebowski, Operations Energy Supervisor, UGI Energy Services, LLC,\ntchlebowski@ugies.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections, Office of\nEnergy Projects, Federal Energy Regulatory Commission, Andrew.Kohout@ferc.gov\n2\n\n42025007NOPV_Final Order_12232025_(24-301886)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDecember 23, 2025\nVIA ELECTRONIC MAIL TO: jhartz@ugies.com\nJoseph Hartz\nPresident\nUGI Energy Services, LLC\n835 Knitting Mills Way\nWyomissing, Pennsylvania 19610\nRe: CPF No. 4-2025-007-NOPV\nDear Mr. Hartz:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and specifies actions that need to be taken to comply with the pipeline safety\nregulations. When the terms of the compliance order are completed, as determined by the\nDirector, Southwest Region, this enforcement action will be closed. Service of the Final Order\nby e-mail is effective upon the date of transmission and acknowledgement of receipt as provided\nunder 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA\nDante D’Alessandro, Vice President, Global Engineering, UGI Energy Services, LLC,\nddalessandro@ugies.com\nBrianne Kurdock, Esq, Babst Calland, BKurdock@babstcalland.com\nLindsay Berkstresser, Energy and Regulatory Counsel, UGI Energy Services, LLC,\nberkstresserl@ugicorp.com\nTyler Chlebowski, Operations Energy Supervisor, UGI Energy Services, LLC,\ntchlebowski@ugies.com\n\n\n\n2\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\n3\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nUGI Energy Services, LLC, )\na subsidiary of UGI Corporation, ) CPF No. 4-2025-007-NOPV\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn October 1, 2025, pursuant to 49 CFR § 190.207, the Director, Southwest Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to UGI Energy Services,1\nLLC (Respondent). The Notice proposed finding that Respondent had violated the pipeline\nsafety regulations in 49 CFR Part 193. The Notice also proposed certain measures to correct the\nviolation. Respondent did not contest the allegation of violation or corrective measures but\nrequested an informal consultation to discuss the terms of the proposed compliance order.\nSouthwest Region and Respondent met virtually on November 18, 2025, via Microsoft Teams, to\ndiscuss the proposed compliance order in the Notice.\nBased upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the\npipeline safety regulations listed below, as more fully described in the enclosed Notice, which is\nincorporated by reference:\n49 CFR § 193.2503(g) (Item 1) ─ Respondent failed to follow its manual of\nwritten procedures to provide safety in normal operations during the cooldown of\ncomponents, as required.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCompliance Actions\nPursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the violation. The Director may grant an\nextension of time to comply with any of the required items upon a written request timely\nsubmitted by the Respondent and demonstrating good cause for an extension. Upon completion\n1 UGI Energy Services is a wholly-owned subsidiary of UGI Corporation.\n\n\n\n4\nof the ordered actions, Respondent may request that the Director close the case. Failure to\ncomply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223\nor in referral to the Attorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR\n§ 190.5.\n___________________________________ _________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nNOTICE OF PROBABLE VIOLATION\nAND\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: jhartz@ugies.com\nOctober 1, 2025\nJoseph Hartz\nPresident\nUGI Energy Services, LLC\n835 Knitting Mills Way\nWyomissing, PA 19610\nCPF 4-2025-007-NOPV\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), Office of Pipeline Safety (OPS), pursuant\nto Chapter 601 of 49 United States Code (U.S.C.) inspected UGI Energy Services, LLC’s1 (UGI)\nTemple liquefied natural gas (LNG) facility in Reading, Pennsylvania.\nAs a result of the inspection, it is alleged that UGI has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 193.2503 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(g) Cooldown of components according to the requirements of\n§ 193.2505.\n1 UGI is a wholly-owned subsidiary of UGI Corporation.\n\n\n\n§ 193.2505 Cooldown.\n(a) The cooldown of each system of components that is subjected to\ncryogenic temperatures must be limited to a rate and distribution\npattern that keeps thermal stresses within design limits during the\ncooldown period, paying particular attention to the performance of\nexpansion and contraction devices.\nUGI failed to follow its manual of written procedures to provide safety in normal operation during\ncooldown of components in accordance with § 193.2503(g). Specifically, UGI failed to cool down\nthe LNG Subcooler System at or below the specified maximum cooldown rate of 2.0°F/min for\ncooldowns on January 19, 2022, and October 19, 2023, in accordance with the requirements of\n§ 193.2505(a) and section VII.B.2 of UGI’s procedure, LNG Subcooler System Manual (Rev. 5;\nFebruary 12, 2024). Additionally, the cooldowns performed were not conducted in accordance\nwith the liquefaction subcooler manufacturer’s manual, which called for restricting the cooldown\nrate of the liquefaction subcooler to a maximum of 1.8°F/min if there is a potential for the\ntemperature difference between the inlet fluid and exchanger metal to exceed 50ºF.\nOn January 19, 2022, UGI averaged a 4.5°F/min cooldown rate, cooling the system from roughly\n32°F at 10:25 AM to -260°F at 11:30 AM. During the first ten minutes of the cooldown operation,\nthe cooldown rate was 10.7°F/min. On October 19, 2023, UGI averaged a 16°F/min cooldown\nrate for the first five minutes of the cooldown. In both cooldowns, UGI exceeded the specified\nmaximum cooldown rate of 2.0°F/min found in UGI’s procedures. Exceeding the maximum\ncooldown rate can damage safety-related components.\nOn December 2, 2024, UGI submitted revised procedures, LNG Manual, Section 2.2.400,\n(November 25, 2024), to include operator- and facility-specific procedures and to align with\nmanufacturer recommendations for the LNG subcooler cooldown.\nTherefore, UGI failed to follow its manual of written procedures to provide safety in normal\noperation during cooldown of components in accordance with § 193.2503(g).\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023, and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023, and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022, and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,412 for a related series of violations. For violation\noccurring on or after May 3, 2021, and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for2\n\n\n\na related series of violations. For violation occurring on or after January 11, 2021, and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019, and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to propose a civil penalty assessment at this time.\nProposed Compliance Order\nWith respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety\nAdministration proposes to issue a Compliance Order to UGI Energy Services, LLC. Please refer\nto the Proposed Compliance Order, which is enclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be 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 your receipt of this Notice, you have 30 days to respond as described in the enclosed\nResponse Options. If you do not respond within 30 days of receipt of this Notice, this constitutes\na waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to\nyou and to issue a Final Order. If you are responding to this Notice, we propose that you submit\nyour correspondence to my office within 30 days from receipt of this Notice. The Region Director\nmay extend the period for responding upon a written request timely submitted demonstrating good\ncause for an extension.\nIn your correspondence on this matter, please refer to CPF 4-2025-007-NOPV and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n3\n\n\n\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\ncc: Jeremy D. Kuhn, Manager Pipeline Engineering & Compliance, UGI Energy Services,\nLLC, jkuhn@ugies.com\nMegan Comstock, Compliance Engineer, UGI Energy Services, LLC,\nmcomstock@ugies.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections Office of\nEnergy Projects, Federal Energy Regulatory Commission Andrew.Kohout@ferc.gov\n4\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to UGI Energy Services, LLC, a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of UGI Energy\nServices with the pipeline safety regulations:\nA. In regard to Item 1 of the Notice pertaining to UGI’s failure to follow its manual of\nwritten procedures to provide safety in normal operation during cooldown of\ncomponents in accordance with § 193.2503(g), UGI must conduct an evaluation to\ndetermine if exceeding the maximum cooldown rate damaged any components\nsubject to cryogenic temperatures, including whether any design thermal stress\nlimits were exceeded. The evaluation must be completed by the liquefaction\nsubcooler manufacturer (or a qualified third-party firm approved by the Director,\nSouthwest Region, PHMSA). The evaluation, or request to approve the use of a\nqualified third-party firm, must be submitted to the Director, Southwest Region,\nwithin 90 days of receipt of the Final Order (or within 90 days of approval to use a\nqualified third-party firm).\ni. If the subcooler is found to have been materially damaged, UGI must\nprepare and submit a plan to repair the components. If thermal stresses were\ndetermined to have exceeded design limits, UGI must prepare and submit a\nmitigation plan to ensure that the subcooler will not experience thermal\noverstress failure in the future. Submit each plan, if applicable, within 270\ndays of receipt of the Final Order (or within 270 days of approval to use a\nqualified third-party firm). UGI must submit all records related to the repair\nwork, including Work Orders, photography documenting repair work\ncompletion, to the Director, Southwest Region Director within 30 days of\nthe completion of repair work.\nB. UGI must provide monthly progress reports on the above corrective actions related\nto Item 1 to the Director, Southwest Region. The monthly progress reports must\ninclude but are not limited to: progress made during the timeframe covered by that\nmonthly report, progress anticipated in the timeframe of the next monthly report,\nany ongoing or anticipated delays and the justification for those delays. The first\nmonthly progress report is due to the Director, Southwest Region, within 30 days\nafter receipt of the Final Order.\nC. It is requested (not mandated) that UGI Energy Services, LLC, maintain\ndocumentation of the safety improvement costs associated with fulfilling this\nCompliance Order and submit the total to Bryan Lethcoe, Director, Southwest\nRegion, Office of Pipeline Safety, Pipeline and Hazardous Materials Safety\nAdministration. It is requested that these costs be reported in two categories: 1)\ntotal cost associated with preparation/revision of plans, procedures, studies and\nanalyses, and 2) total cost associated with replacements, additions and other\nchanges to pipeline infrastructure.5","truncated":false,"body_characters":18181}