{"operation":"document","citation":"CPF 520173003W","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 193.2637.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520173003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520173003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520173003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520173003W","body":"Warning Letter involving TITAN ALASKA LNG. PHMSA's enforcement data identifies the cited regulation as 193.2637. 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\n520173003W_Operator Response To Notice_10052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520173003W/520173003W_Operator%20Response%20To%20Notice_10052017.pdf\n\n520173003W_Warning Letter_08302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520173003W/520173003W_Warning%20Letter_08302017.pdf\n\n520173003W_Warning Letter_08302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520173003W/520173003W_Warning%20Letter_08302017_text.pdf\n\n520173003W_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 5-2017-3003W\nDear Mr. Britton:\nOn March 13 through 16, 2017, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Titan Alaska LNG’s (Titan) records and procedures at the LNG facility near Point\nMacKenzie, Alaska.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violation is:\n1. §193.2637 Remedial measures.\nPrompt corrective or remedial action must be taken whenever an operator learns\nby inspection or otherwise that atmospheric, external, or internal corrosion is not\ncontrolled as required by this subpart.\nCoffman Engineering recommended in reports dated 2015 and 2016 that pipeline supports\nand pipeline isolation be installed to prevent corrosion of the carrier pipe. The pipeline rests\non support members which are not isolated with a dielectric pad, this has caused external\ncorrosion at several locations on the underside of the pipeline, at the 6 o’clock\n\n\n\nposition. Coffman Engineering made note of this during their audits, but Titan, has yet to\nremedy. Additionally, no record of the repair was made available at the time of the\ninspection.\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. Also, for LNG facilities, an\nadditional penalty of not more than $76,352 for each violation may be imposed. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the item 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 5-2017-3003W. 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 R. Guisinger (#155012)","truncated":false,"body_characters":3821}