{"operation":"document","citation":"CPF 520143001W","title":"TITAN ALASKA LNG — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-08-20","effective_on":null,"summary":"CLOSED warning letter citing 193.2503, 193.2503(c), 193.2503(d), 193.2503(f), 193.2509(b)(4), 193.2513(c), 193.2619(c)(2), 193.2717(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520143001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520143001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520143001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520143001W","body":"Warning Letter involving TITAN ALASKA LNG. PHMSA's enforcement data identifies the cited regulations as 193.2503,  193.2503(c),  193.2503(d),  193.2503(f),  193.2509(b)(4),  193.2513(c),  193.2619(c)(2),  193.2717(c). The case was opened on 2014-08-20 and is reported as closed as of 2014-08-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520143001W_warning letter_08202014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520143001W/520143001W_warning%20letter_08202014.pdf\n\n520143001W_warning letter_08202014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520143001W/520143001W_warning%20letter_08202014_text.pdf\n\n520143001W_warning letter_08202014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL—RETURN RECEIPT REQUESTED\nAugust 20, 2014\nDaniel Britton\nPresident\nTitan Alaska LNG\n3408 International Street\nFairbanks, AK 99701\nCPF 5-2014-3001W\nDear Mr. Britton:\nOn July 14 to 15, 2014, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Titan\nAlaska LNG’s (Titan) records and visually inspected your LNG facility in Houston, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §193.2509 Emergency procedures.\n(b) To adequately handle each type of emergency identified under paragraph (a) of\nthis section and each fire emergency, each operator must follow one or more\nmanuals of written procedures. The procedures must provide for the following:\n(4) Cooperating with appropriate local officials in evacuations and emergencies\nrequiring mutual assistance and keeping these officials advised of:\n(i) The LNG plant fire control equipment, its location, and quantity of units located\nthroughout the plant;\n(ii) Potential hazards at the plant, including fires;\n(iii) Communication and emergency control capabilities at the LNG plant\n(iv) The status of each emergency.\nTitan could not produce records showing that they have communicated their emergency plans\nfor evacuation to local officials. Each record should show that evacuation plans were\ncoordinated with local authorities and newly elected officials. These records should indicate\nthe extent of the evacuation preparations with local authorities. The records should, also,\n\n\n\nindicated coordinating with appropriate local officials in evacuations and emergencies\nrequiring mutual assistance. Titan was not able to produce any such records.\n2. §193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written procedures to provide\nsafety in normal operation and in responding to an abnormal operation that would\naffect safety. The procedures must include provisions for:\n(c) Recognizing abnormal operating conditions.\n(d) Purging and inserting components according to the requirements of §193.2517.\n(f) In the case of liquefaction, maintaining temperatures, pressures, pressure\ndifferentials and flow rates, as applicable, within their design limits for:\n(1) Boilers;\n(2) Turbines and other prime movers;\n(3) Pumps, compressors, and expanders;\n(4) Purification and regeneration equipment; and\n(5) Equipment within cold boxes.\nTitan did not record their Abnormal Operating Conditions (AOC) events. Furthermore, they\ndid not purge the transfer houses after each truck fill. Titan also failed to provide the design\nlimits for all equipment used during liquefaction.\nTitan admitted they had a few power failures in the past. Titan’s manuals of written\nprocedures consider a power failure to be an AOC. Titan could not produce documentation\nof how it responded, investigated, and corrected each event identified as an AOC; nor did\nthey check variations from normal operations after abnormal operation had ended at\nsufficient critical locations.\nTitan has a truck loading facility and LNG is transferred on a continuous basis, but Titan\nfailed to produce documentation showing all transfer hoses were purged following each truck\nfill. Additionally, Titan’s liquefaction process is conducted daily and your company did not\nhave documentation showing the design limits for maintaining temperatures, pressures,\npressure differentials, and flow rate of equipment—such as prime movers, pumps,\ncompressors, cold boxes, etc.\n3. §193.2619 Control systems.\n(c) Control systems in service, but not normally in operation, such as relief valves\nand automatic shutdown devices, and control systems for internal shutoff valves for\nbottom penetration tanks must be inspected and tested once each calendar year, not\nexceeding 15 months, with the following exceptions:\n(2) Control systems that are intended for fire protection must be inspected and\ntested at regular intervals not to exceed 6 months\nTitan failed to show inspection records for the fire protection control system at the required 6\nmonth interval. While Titan was able to show records for the previous annual inspection\n2\n\n\n\nconducted in September 2013, your company should have conducted an inspection in March\n2014. There are no records to indicate that occurred.\nThe control systems that are intended for fire protection must be inspected and tested at\nregular intervals not exceeding 6 months. Titan did not inspect its fire protection system\nonce every 6 months.\n4. §193.2513 Transfer procedures.\n(c) In addition to the requirements of paragraph (b) of this section, the procedures\nfor cargo transfer must be located at the transfer area and include provisions for\npersonnel to:\n(1) Be in constant attendance during all cargo transfer operations;\n(2) Prohibit the backing of tank trucks in the transfer area, except when a person is\npositioned at the rear of the truck giving instructions to the driver;\n(3) Before transfer, verify that:\n(i) Each tank car or tank truck complies with applicable regulations governing its\nuse;\n(ii) All transfer hoses have been visually inspected for damage and defects;\n(iii) Each tank truck is properly immobilized with chock wheels, and electrically\ngrounded; and,\n(iv) Each tank truck engine is shut off unless it is required for transfer operations;\n(4) Prevent a tank truck engine that is off during transfer operations from being\nrestarted until the transfer lines have been disconnected and any released vapors\nhave dissipated;\n(5) Prevent loading LNG into a tank car or tank truck that is not in exclusive LNG\nservice or that does not contain a positive pressure if it is in exclusive LNG service,\nuntil after the oxygen content in the tank is tested and if it exceeds 2 percent by\nvolume, purged in accordance with a procedure that meets the requirements of\nAGA \"Purging Principles and Practice\";\n(6) Verify that all transfer lines have been disconnected and equipment cleared\nbefore the tank car or tank truck is moved from the transfer position; and,\nTitan did not have the cargo transfer procedures required by Part 193.2513(c) at the transfer\nsite. Part 193.5213(c) requires specific provisions of items during a cargo transfer which\ninclude LNG, Ethylene, Propane, etc. Titan has procedures for its personnel to follow;\nhowever, they were unable to provide a record that such procedures were completed at the\ntransfer site. A checklist should be provided for each cargo transfer, and kept at the transfer\nsite.\n5. §193.2717 Training, fire protection.\n(c) Plant fire drills must provide personnel hands-on experience in carrying out\ntheir duties under the fire emergency procedures required by § 193.2509.\nTitan did not conduct a drill for its personnel that provides hands-on experience in carrying\nout their duties under the fire emergency procedures. While Titan’s procedural manuals\n3\n\n\n\nrequires its operating personnel to conduct a fire drill annually, there was no documentation\nthat training was conducted at the required frequencies.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. Also, for LNG facilities, an additional\npenalty of not more than $50,000 for each violation may be imposed. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in Titan\nAlaska LNG being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2014-3001W and send all documents to our office at 188 W. Northern Lights\nBlvd., Suite 520, Anchorage, AK 99503. For each document you submit, please provide a\ncopy in electronic format to PHP-WRADMIN@dot.gov whenever possible. Be advised that\nall material you submit in response to this enforcement action is subject to being made\npublicly available. If you believe that any portion of your responsive material qualifies for\nconfidential 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\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 R. Guisinger (#145245)\n4","truncated":false,"body_characters":9863}