# NFENERGIA LLC — Notice of Amendment

**Citation:** CPF 42025033NOA  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2025-07-03

CLOSED notice of amendment citing 193.2503(b), 193.2503(g), 193.2509(b)(3), 193.2605(b)(1), 193.2605(b)(2), 193.2611(a), 193.2613, 193.2619(a), 193.2625(a).

## Document text

Notice of Amendment involving NFENERGIA LLC. PHMSA's enforcement data identifies the cited regulations as 193.2503(b),  193.2503(g),  193.2509(b)(3),  193.2605(b)(1),  193.2605(b)(2),  193.2611(a),  193.2613,  193.2619(a),  193.2625(a). The case was opened on 2025-07-03 and is reported as closed as of 2025-10-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42025033NOA_Closure Letter_10102025_(24-298759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Closure%20Letter_10102025_(24-298759).pdf

42025033NOA_Closure Letter_10102025_(24-298759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Closure%20Letter_10102025_(24-298759)_text.pdf

42025033NOA_Notice of Amendment_07032025_(24-298759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Notice%20of%20Amendment_07032025_(24-298759).pdf

42025033NOA_Notice of Amendment_07032025_(24-298759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Notice%20of%20Amendment_07032025_(24-298759)_text.pdf

42025033NOA_Operator Response to Notice_09162025_(24-298759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Operator%20Response%20to%20Notice_09162025_(24-298759).pdf

42025033NOA_Closure Letter_10102025_(24-298759)_text.pdf

VIA ELECTRONIC MAIL TO: zahmed@newfortressenergy.com
October 10, 2025
Zak Ahmed
Managing Director
New Fortress Energy, LP
111 W 19th Street, 8th floor
New York, NY 10011
RE: CPF 4-2025-033-NOA
Dear Mr. Ahmed:
From April 22 to 24, 2024 of the on-site inspection, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected NFEnergía, LLC’s1 (NFEnergía) procedures for operations and maintenance of its
liquefied natural gas (LNG) facility in San Juan, Puerto Rico.
As a result of the inspection, NFEnergía was issued a Notice of Amendement on July 3, 2025,
which proposed amendement of your procedures. NFEnergía submitted its amended procedures on
September 16, 2025. My staff has reviewed the amended procedures, and it appears that the
inadequacies outlined in this Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Shakira Mosquera, HSSEQ Manager, NFEnergía LLC,
smosquera@newfortressenergy.com
Andrew Kohout, Director, Division of LNG Facility Reviews and Inspections, Office of
Energy Projects, Federal Energy Regulatory Commission, andrew.Kohout@ferc.gov
1NFEnergía is a subsidiary of New Fortress Energy, Inc.

42025033NOA_Notice of Amendment_07032025_(24-298759)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: cguinta@newfortressenergy.com
July 3, 2025
Christopher S. Guinta
Chief Financial Officer
New Fortress Energy Inc.
111 W 19th Street, 8th floor
New York, NY 10011
CPF 4-2025-033-NOA
Dear Mr. Guinta,
From April 22 to 24, 2024 of the on-site inspection, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected NFEnergía, LLC’s1 (NFEnergía) procedures for operations and maintenance
of its liquefied natural gas (LNG) facility in San Juan, Puerto Rico.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
NFEnergía’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written
procedures to provide safety in normal operation and in responding to
an abnormal operation that would affect safety. The procedures must
include provisions for:
(a) . . . .
(b) Startup and shutdown, including for initial startup,
performance testing to demonstrate that components will operate
satisfactory in service.
NFEnergía's written procedures for conducting normal operations were inadequate to provide for
safe operation of a LNG facility in accordance with § 193.2503(b). Specifically, NFEnergía's
operating procedures, San Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations
and Maintenance Plan (Rev. 0.1; April 18, 2024), and Program Procedure: Conduct of Operations
San Juan LNG Terminal, NFE-SAN JUAN-193-0002 (Rev. 0, April 17, 2024) failed to provide
1 NFEnergía is a subsidiary of New Fortress Energy, Inc.



instructions for performance testing to demonstrate that components will operate satisfactory in
service.
PHMSA proposes NFEnergía revise its written procedures to include provisions, including
instructions and identification of components, for performance testing to demonstrate that
components will operate satisfactory in service in accordance with § 193.2503(b).
2. § 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written
procedures to provide safety in normal operation and in responding to
an abnormal operation that would affect safety. The procedures must
include provisions for:
(a) .…
(g) Cooldown of components according to the requirements of
§ 193.2505.
NFEnergía's written procedures for conducting normal operations were inadequate to provide for
safe operation of a LNG facility in accordance with § 193.2503(g). Specifically, NFEnergía's San
Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations and Maintenance Plan
(Rev. 0.1; April 18, 2024), section 7.3.1 Cooldown (§ 193.2505), and Program Procedure:
Conduct of Operations San Juan LNG Terminal, NFE-SAN JUAN-193-0002 (Rev. 0, April 17,
2024) failed to provide instructions on how to limit the rate and distribution pattern to keep thermal
stresses within design limits during the cooldown periods, paying particular attention to the
performance of expansion and contraction devices, in accordance with § 193.2505. Additionally,
NFEnergía's procedures failed to identify components at its facility that are subjected to cooldown
rates and distribution patterns.
PHMSA proposes NFEnergía revise its written procedures to include provisions, including
instructions to personnel and identification of components, for the cooldown of components
according to the requirements of § 193.2505, in accordance with § 193.2503(g).
3. § 193.2509 Emergency procedures.
(a) . . . .
(b) To adequately handle each type of emergency identified under
paragraph (a) of this section and each fire emergency, each operator must
follow one or more manuals of written procedures. The procedures must
provide for the following:
(1) . . . .
(3) Coordinating with appropriate local officials in preparation of an
emergency evacuation plan, which sets forth the steps required to protect
the public in the event of an emergency, including catastrophic failure of
an LNG storage tank.



NFEnergía’s written procedures for adequately handling each type of emergency identified under
§ 193.2509(a) and each fire emergency were inadequate to provide for safe operation of a LNG
facility in accordance with § 193.2509(b)(3). Specifically, NFEnergía’s procedures, San Juan
Multi-Fuel Handling Facility Liquefied Natural Gas Operations and Maintenance Plan (Rev. 0.1;
April 18, 2024), section 7.3.3 Emergency Procedures (§ 193.2509), and Micro Fuel Handling
Facility Emergency Response Plan (Rev. 001, November 2, 2023), failed to provide instructions
on coordinating with appropriate local officials in preparation of an emergency evacuation plan,
which sets forth the steps required to protect the public in the event of an emergency, including
catastrophic failure of an LNG storage tank. NFEnergía’s procedures did not identify the
appropriate local authorities to be contacted in the event of an incident, and did not provide for
coordinating or participating in emergency drills designed to prepare NFEnergía personnel and
local authorities to respond to emergencies and foster cooperative relationships.
PHMSA proposes NFEnergía revise its written procedures to provide for coordinating with local
officials in preparation of an emergency evaluation plan in accordance with § 193.2509(b)(3).
4. § 193.2605 Maintenance procedures.
(a) . . . .
(b) Each operator shall follow one or more manuals of written
procedures for the maintenance of each component, including any
required corrosion control. The procedures must include:
(1) . . . .
(2) A description of other actions necessary to maintain the LNG
plant according to the requirements of this subpart.
§ 193.2611 Fire protection.
(a) Maintenance activities on fire control equipment must be
scheduled so that a minimum of equipment is taken out of service at
any one time and is returned to service in a reasonable period of time.
NFEnergía’s written procedures for conducting maintenance activities were inadequate to provide
for safe operation of a LNG facility in accordance with § 193.2605(b)(2). Specifically,
NFEnergía’s procedures, San Juan Multi-Fuel Handling Facility Liquefied Natural Gas
Operations and Maintenance Plan (Rev. 0.1; April 18, 2024), and Safe Work Practices, Fire
Protection, LNG San Juan, NFE-SAN JAN-193-007 (Rev. 0; April 17, 2024) failed to provide
adequate guidance on how NFEnergía performs maintenance activities on fire control equipment
so that a minimum of equipment is taken out of service at any one time and is returned to service
in a reasonable period of time in accordance with 193.2611(a). NFEnergía’s procedures did not
require a minimum amount of fire control equipment or identify how many pieces of equipment
can be taken out of service at any one time, or define a reasonable period of time to return
equipment to service.



PHMSA proposes NFEnergía revise its procedures to include requirements that enumerate the
minimum amount of fire control equipment that can be taken out of service at one time and define
the reasonable period of time needed to perform maintenance on fire control equipment before
returning to service in accordance with § 193.2611(a).
5. § 193.2605 Maintenance procedures.
(a) . . . .
(b) Each operator shall follow one or more manuals of written
procedures for the maintenance of each component, including any
required corrosion control. The procedures must include:
(1) The details of the inspections or tests determined under
paragraph (a) of this section and their frequency of performance; . . . .
§ 193.2613 Auxiliary power sources.
Each auxiliary power source must be tested monthly to check its
operational capability and tested annually for capacity. The capacity
test must take into account the power needed to start up and
simultaneously operate equipment that would have to be served by that
power source in an emergency.
NFEnergía's written procedures for conducting maintenance activities were inadequate to provide
for safe operation of a LNG facility in accordance with § 193.2605(b)(1). Specifically,
NFEnergía's San Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations and
Maintenance Plan (Rev. 0.1; April 18, 2024), did not identify what equipment must remain in
operation during an emergency, does not include the required capacity of the auxiliary power
sources, and does not provide instructions on how to test the capacity of the auxiliary power
sources in accordance with § 193.2613. Additionally, NFEnergía’s procedures did not provide
guidance on how auxiliary power source capacity test results must be recorded.
PHMSA proposes NFEnergía revise its written procedures to include requirements and
instructions for testing its auxiliary power sources monthly to check for operation capability and
annually for capacity in accordance with § 193.2613.
6. § 193.2605 Maintenance procedures.
(a) . . . .
(b) Each operator shall follow one or more manuals of written
procedures for the maintenance of each component, including any
required corrosion control. The procedures must include:
(1) . . . .
(2) A description of other actions necessary to maintain the LNG
plant according to the requirements of this subpart.
§ 193.2619 Control systems.
(a) Each control system must be properly adjusted to operate within
design limits.



NFEnergía's written procedures for conducting maintenance activities were inadequate to provide
for safe operation of a LNG facility in accordance with § 193.2605(b)(2). Specifically,
NFEnergía's San Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations and
Maintenance Plan (Rev. 0.1; April 18, 2024), section 8.9 Control Systems (§ 193.2619) failed to
identify each control system, provide instructions to NFEnergía's personnel regarding how to
inspect and adjust the control systems to operate within design limits, or define the design limits
for each control system.
PHMSA proposes NFEnergía revise its written procedures to include instructions for properly
adjusting each control system to operate within design limits, in accordance with § 193.2619(a).
7. § 193.2605 Maintenance procedures.
(a) . . . .
(b) Each operator shall follow one or more manuals of written
procedures for the maintenance of each component, including any
required corrosion control. The procedures must include:
(1) . . . .
(2) A description of other actions necessary to maintain the LNG
plant according to the requirements of this subpart.
§ 193.2625 Corrosion protection.
(a) Each operator shall determine which metallic components
could, unless corrosion is controlled, have their integrity or reliability
adversely affected by external, internal, or atmospheric corrosion
during their intended service life.
NFEnergía's written procedures for conducting maintenance activities were inadequate to provide
for safe operation of a LNG facility in accordance with § 193.2605(b)(2). Specifically,
NFEnergía's procedures, San Juan Multi-Fuel Handling Facility Liquefied Natural Gas
Operations and Maintenance Plan (Rev. 0.1; April 18, 2024), section 8.11 Corrosion Protection
(§ 193.2625), does not explain how NFEnergía personnel will determine which metallic
components require corrosion protection, explain which type of corrosion protection is appropriate
for each component, or provide guidance on how to categorize the degree of metal loss due to
corrosion and how to record it.
PHMSA proposes NFEnergía revise its written procedures to give instruction to personnel on how
to evaluate components that are susceptible to corrosion loss, determine which metallic
components could, have their integrity or reliability adversely affected by corrosion during their
intended service life, and how to categorize any corrosion loss and record it in accordance with
§ 193.2625(a).



Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. § 552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that NFEnergía maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Bryan Lethcoe, Director, Southwest, Pipeline and Hazardous
Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-
2025-033-NOA and, for each document you submit, please provide a copy in electronic format
whenever possible.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Komi Hassan, DOT Compliance Primary, NFEnergía, LLC,
khassan@newfortressenergy.com
Andrew Kohout, Director, Division of LNG Facility Reviews and Inspections
Office of Energy Projects, Federal Energy Regulatory Commission,
andrew.Kohout@ferc.gov

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/42025033NOA>
- Source ID: `phmsa-enforcement`
- SHA-256: `c2ba29213df667de87b3d8141acc38e8d2e9a0694cd84cbe07927681fe6bbade`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T16:16:48.241Z
- Document slug: `phmsa-enforcement-42025033noa`

### Source metadata

```json
{
  "cpf": "42025033NOA",
  "operator": "NFENERGIA LLC",
  "region": "Southwest",
  "pipelineType": "INTRASTATE LNG",
  "caseStatus": "CLOSED",
  "citedSections": [
    "193.2503(b)",
    "193.2503(g)",
    "193.2509(b)(3)",
    "193.2605(b)(1)",
    "193.2605(b)(2)",
    "193.2611(a)",
    "193.2613",
    "193.2619(a)",
    "193.2625(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
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  "jurisdiction": "US",
  "operatorName": "NFENERGIA LLC"
}
```
