# NATIONAL GRID LNG, L.P. — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120063004
- **title:** NATIONAL GRID LNG, L.P. — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2006-08-16
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2511(c), 193.2619(c), 193.2619(d), 193.2621(a), 193.2713(b).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120063004
**body:**

Notice of Probable Violation involving NATIONAL GRID LNG, L.P.. PHMSA's enforcement data identifies the cited regulations as 193.2511(c),  193.2619(c),  193.2619(d),  193.2621(a),  193.2713(b). The case was opened on 2006-08-16 and is reported as closed as of 2008-05-08. Proposed civil penalty: $108,000. Assessed civil penalty: $108,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120063004_FinalOrder_09132007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120063004/120063004_FinalOrder_09132007.pdf

120063004_finalorder_09132007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120063004/120063004_finalorder_09132007_text.pdf

120063004_finalorder_09132007_text.pdf

U S Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Ave S E
Washington DC 20590
SEP & 3 2007
Mr. Steven L. Zelkowitz, President
KeySpan LNG, LP
121 Terminal Road
Providence, RI 02905
Re: CPF No. : 1-2006-3004
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in the
above-referenced case. It makes findings of violation, specifies actions to be taken to comply
with the pipeline safety regulations, and assesses a civil penalty. I acknowledge receipt of and
accept your wire transfer for $108, 000 as payment in full of the civil penalty assessed in the
Final Order. Because further actions are required with respect to the compliance terms contained
in the Final Order, this case remains open Your receipt of the Final Order constitutes service of
that document under 49 C. F. R, ) 190. 5.
Thank you for your cooperation in this matter.
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Byron Coy, Director, Eastern Region, PHMSA
CERTIFIED MAIL — RETURN RECEIPT RE UESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of
KeySpan LNG, LP,
Respondent
CPF No. 1-2006-3004
FINAL ORDER
On August 16, 2006, in accordance with 49 C, F. R. ( 190. 207, the Director, Eastern Region,
Pipeline and Hazardous Materials Administration, Office of Pipeline Safety (PHMSA), ' issued a
Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice)
to KeySpan LNCr, LP (Respondent or KeySpan). The Notice proposed finding that Respondent
had violated 49 C. F. R. )$ 193. 2619, 193. 2621, 193 2713, and 193. 2511, and proposed assessing
a civil penalty of $108, 000 for the alleged violations. The Notice also proposed that Respondent
take certain measures to correct the alleged violations. Respondent responded to the Notice by
letter dated September 8, 2006, but did not contest the allegations, the amount of the proposed
civil penalty, or the proposed compliance order Respondent also provided information
concerning the corrective actions it had taken and enclosed payment in full of the proposed civil
penalty. Respondent wire transferred said penalty amount ($108, 000) on September 15, 2006,
waiving further right to respond and authorizing the entry of this Final Order.
FINDINGS OF VIOLATIONS
Pursuant to 49 C. F. R. $ 190. 213 and 49 U, S C. $ 60122, I find that Respondent violated the
following sections of 49 C F. R. Part 193, as more fully described in the Notice:
' Effective February 20, 2005, PHMSA succeeded the Research and Special Programs Admimstration as the agency
responsible for regulating safety in pipelme transportation and hazardous matenals transportation See, section 108
of the Norman Y Mmeta Research and Special Programs Improvement Act (Pubhc law 108-426, 118 Stat. 2423-
2429 (November 30, 2004)) See also, 70 Fed Reg 8299 (February 18, 2005) redelegatmg the pipeline safety
authorities and functions to the PHMSA administrator



Item 1. The Notice alleged that Respondent violated 49 C. F. R. $ 193. 2619(c), which
states:
g 193. 2619. Control systems.
(a) .
(c) Control systems in service, but not normally in operation,
such as relief valves and automatic shutdown devices, and control systems
for internal shutoff valves for bottom penetration tanks must be inspected
and tested once each calendar year, not exceeding 15 months.
The Notice alleged that Respondent violated 49 C. F. R. $ 193. 2619(c) by failing to
inspect and test certain control systems in service, but not normally in operation, once
each calendar year, but at intervals not to exceed 15 months. Six relief valves (SV-Cl-
01, SV-C1-02, SV-C1-03, SV-C2-01, SV-C2-02, and SV-C2-03) in the region of the
boil-off gas compressors were not inspected and tested in 2003.
Item 2. The Notice alleged that Respondent violated 49 C. F. R. $ 193. 2619(d), which
states:
g 193. 2619. Control systems.
(a)
(d) Control systems that are normally in operation, such as
required by a base load system, must be inspected and tested once
each calendar year but with intervals not exceeding 15 months.
The Notice alleged that Respondent violated 49 C. F R. ( 193 2619(d) by failing to
inspect and test certam control systems that are normally in operation, once each calendar
year but at intervals not to exceed 15 months. Twenty-nine of Respondent's control
systems were not inspected and tested within the required 15-month interval.
Item 3. The Notice alleged that Respondent violated 49 C. F R. $ 193, 2621(a), which
states:
g 193. 2621. Testing transfer hoses.
Hoses used in LNG or flammable refrigerant transfer systems
must be.
(a) Tested once each calendar year, but with intervals not
exceedmg 15 months, to the maximum pump pressure or relief
valve setting.
The Notice alleged that Respondent violated 49 C. F. R. ) 193. 2621(a) by failing to test
hoses used in Respondent's flammable refrigerant transfer systems once each calendar
year, but with intervals not to exceed 15 months. Testing of the Chicksan and vapor
return lmes at Respondent's truck loading station was not conducted within the required
15-month interval



Item 4. The Notice alleged that Respondent violated 49 C. F. R. $ 193. 2713(b), which
states:
g 193. 2713. Training: operations and maintenance.
(a) . .
(b) A written plan of continuing instruction must be conducted
at intervals of not more than two years to keep all personnel current
on the knowledge and skills they gained in the program of initial
instruction.
The Notice alleged that Respondent violated 49 C. F. R. $ 193. 2713(b) by failing to
conduct continuing instruction of its personnel at intervals not to exceed two years.
KeySpan failed to train one individual within the required two-year interval regarding
first-aid training.
Item 5. The Notice alleged that Respondent violated 49 C. F. R. $ 193, 2511(c), which
states:
g 193. 2511. Personnel safety.
(a) . .
(c) Each LNG plant must be equipped with suitable first-aid
material, the location of which is clearly marked and readily available
to personnel.
The Notice alleged that Respondent violated 49 C. F. R. ) 193. 2511(c) by failing to equip
its LNG plant with suitable first-aid material. The eyewash in two first-aid kits had
exceeded their 2005 expiration dates.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent. Having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $108, 000, which amount has already been paid by
Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1, 2, 3, 4, and 5 for various
violations of Part 193.
Under 49 U. S. C. ) 60118(a), each person who engages in the transportation of gas or who owns
or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601



Pursuant to the authority of 49 U. S. C. $ 60118(b) and 49 C. F. R. $ 190, 217, Respondent is
ordered to take the following actions to ensure compliance with the pipeline safety regulations
applicable to its operations. I therefore order that Respondent take the following corrective
measures:
1. In regard to Items 1, 2, 3, 4, and 5 of the Notice, KeySpan shall prepare and
implement an audit program whose purpose is to ensure that accurate, timely records are
prepared for compliance activities, and that these activities are conducted within the
timeframes and schedules specified in the pipeline safety regulations. At a minimum, the
written audit program procedures must (1) require continuous review of all compliance
activity records, (2) assign responsibility for conducting these reviews, (3) identify the
corrective actions KeySpan will implement when audit results indicate that Respondent's
records reflect insufficient proof that activities have been performed, that activities were
not performed, or that they were performed late
2. Within 60 days following receipt of the Final Order, KeySpan shall provide the
written audit program procedures required in Item 1 to the Director, Eastern Region,
PHMSA.
3. KeySpan shall maintam documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director,
Eastern Region, PHMSA. The total cost associated with preparation of the audit program
shall be reported.
The terms and conditions of this Fmal Order are effective on receipt.
gyp 18 2007
Date Issued
J
NA ey . Wiese,
ciate Administrator
for Pipeline Safety
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