{"operation":"document","citation":"CPF 520170015W","title":"TITAN ALASKA LNG — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-30","effective_on":null,"summary":"CLOSED warning letter citing 192.479(a), 192.745(a), 192.807(a), 192.807(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520170015W","body":"Warning Letter involving TITAN ALASKA LNG. PHMSA's enforcement data identifies the cited regulations as 192.479(a),  192.745(a),  192.807(a),  192.807(b). The case was opened on 2017-08-30 and is reported as closed as of 2017-08-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520170015W_Operator Response to Notice_10052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170015W/520170015W_Operator%20Response%20to%20Notice_10052017.pdf\n\n520170015W_Warning Letter_08302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170015W/520170015W_Warning%20Letter_08302017.pdf\n\n520170015W_Warning Letter_08302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170015W/520170015W_Warning%20Letter_08302017_text.pdf\n\n520170015W_Warning Letter_08302017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 30, 2017\nMr. Daniel W Britton\nPresident/CEO\nTitan Alaska LNG\n3408 International Street\nFairbanks, AK 99701\nCPF 5-2017-0015W\nDear Mr. Britton:\nOn March 13 through15, 2017 representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nTitan Alaska LNG (Titan) system facilities located in Wasilla, Alaska.\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\ninspected and the probable violations are:\n1. §192.479(a) Atmospheric corrosion control: General.\n(a) Each operator must clean and coat each pipeline or portion of pipeline that is\nexposed to the atmosphere, except pipelines under paragraph (c) of this section.\n(b) Coating material must be suitable for the prevention of atmospheric\ncorrosion.\nCoatings have degraded between the ground soil interface and the upstream shutoff valve\nflange. Maintenance painting was completed but found to be inadequate. Additionally, 2015\nrecommendations by operator’s corrosion consultant, Coffman Engineers which addressed the\n\n\n\nneed for pipe supports to be isolated from the piping to prevent steel on steel contact were\nmade but never implemented.\n2. §192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency\nmust be inspected and partially operated at intervals not exceeding 15 months,\nbut at least once each calendar year.\nAt the time of the inspection, annual records produced by Titan personnel lacked sufficient\ndetail about the inspection processes/tasks and whether the valves were partially operated as\nrequired by 192.745. In the absence of an established procedure for the maintenance of\ntransmission line valves it becomes difficult to determine whether the records are adequately\ncapturing all the required inspection and maintenance tasks. Examples of properly recorded\ntasks could include checking the torque of bolts on flanged fittings, stroking of the valve,\nlubricating the valve, or inspecting the valve for corrosion, damage, and leaks as defined by\n49 CFR 192.745.\n3. §192.807 Record keeping.\nEach operator shall maintain records that demonstrate compliance with this\nsubpart.\n(a) Qualification records shall include:\n(1) Identification of qualified individual(s);\n(2) Identification of the covered tasks the individual is qualified to perform;\n(3) Date(s) of current qualification; and\n(4) Qualification method(s).\n(b) Records supporting an individual's current qualification shall be maintained\nwhile the individual is performing the covered task. Records of prior\nqualification and records of individuals no longer performing covered tasks shall\nbe retained for a period of five years.\nAt the time of the inspection, the tasks of valve maintenance and coating applications were\nnot part of the operator's OQ program. Titan's onsite employees had been conducting valve\ninspection and maintenance tasks and painting tasks in the absence of Operator Qualification\nstandards according 192.807(a). Said covered tasks are defined by 49 CFR 192.801(b).\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a\ncivil penalty not to exceed $209,002 per violation per day the violation persists up to a\nmaximum of $2,090,022 for a related series of violations. 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.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-0015W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Chard (#155026)\n3","truncated":false,"body_characters":5534}