{"operation":"document","citation":"CPF 120083002W","title":"HOPKINTON LNG CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-25","effective_on":null,"summary":"CLOSED warning letter citing 193.2635, 193.2637.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120083002w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120083002w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120083002w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120083002W","body":"Warning Letter involving HOPKINTON LNG CO. PHMSA's enforcement data identifies the cited regulations as 193.2635,  193.2637. The case was opened on 2008-09-25 and is reported as closed as of 2008-09-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120083002W_Warning Letter_09252008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120083002W/120083002W_Warning%20Letter_09252008_text.pdf\n\n120083002W_Warning_Letter_09252008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120083002W/120083002W_Warning_Letter_09252008.pdf\n\n120083002W_Warning Letter_09252008_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 25, 2008\nMr. Phil Andreas\nVice President, Operations\nNSTAR/Hopkinton LNG Corporation\n1 NSTAR Way\nWestwood, MA 02090-9230\nCPF 1-2008-3002W\nDear Mr. Andreas:\nFrom March 25 to March 28, 2008, representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour liquefied natural gas plant in Hopkinton, Massachusetts.\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 the\nprobable violation(s) are:\n\n\n\n1. §193.2635 Monitoring corrosion control.\nCorrosion protection provided as required by this subpart must be periodically\nmonitored to give early recognition of ineffective corrosion protection, including the\nfollowing, as applicable:\n(a) Each buried or submerged component under cathodic protection must be tested\nat least once each calendar year, but with intervals not exceeding 15 months, to\ndetermine whether the cathodic protection meets the requirements of §192.463 of\nthis chapter.\nOperator failed to meet the calendar year requirement in its monitoring of external corrosion of\nthe galvanic anode system protecting the underground propane tank used in the liquefaction\nprocess. The operator monitored for external corrosion in December 2006 and in January 2008.\nEvidence consists of the test records for those two evaluations.\n2. §193.2637 Remedial measures.\nPrompt corrective or remedial action must be taken whenever an operator learns by\ninspection or otherwise that atmospheric, external, or internal corrosion is not\ncontrolled as required by this subpart.\nOperator found deficiencies in the external corrosion control due to low pipe-to-soil readings on\nits galvanic anode system in December 2006 and January 2008. As of March 2008, the condition\nhad not been corrected.\nEvidence includes external corrosion monitoring records from 2005 to 2008, procedures, order\nfor replacement parts and photos.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. Also, for LNG facilities, an additional penalty of not more than\n$50,000 for each violation may be imposed. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitems identified in this letter. Failure to do so will result in Hopkinton LNG Corporation being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2008-3002W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n2\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n3\n\n120083002W_Warning_Letter_09252008.pdf\n\n409 3rd Street, SW, Suite 300\nWashington, DC 20024\nPipeline and\nAdministration\nHazardous Materials safety\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 25, 2008\nMr. Phil Andreas\nVice President, Operations\nNSTAR/Hopkinton LNG Corporation\n1 NSTAR Way\nWestwood, MA 02090-9230\nCPF 1-2008-3002W\nDear Mr. Andreas:\nFrom March 25 to March 28, 2008, representative of the Pipeline and Hazardous Materials\nSafer administratial gas Man Hopkinton, Massachuset 49 United States Code inspected\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 the\nprobable violation(s) are:\n\n\n\n§193.2635 Monitoring corrosion control.\nCorrosion protection provided as required by this subpart must be periodically\nfollowing, as applicable:\nmonitored to give early recognition of ineffective corrosion protection, including the\n(a) Each buried or submerged component under cathodic protection must be tested\nat least once each calendar year, but with intervals not exceeding 15 months, to\ndetermine whether the cathodic protection meets the requirements of §192.463 of\nthis chapter.\nOperator failed to meet the calendar year requirement in its monitoring of external corrosion of\nthe galvanic anode system protecting the underground propane tank used in the liquefaction\nprocess. The operator monitored for external corrosion in December 2006 and in January 2008.\nEvidence consists of the test records for those two evaluations.\n8193.2637 Remedial measures.\nPrompt corrective or remedial action must be taken whenever an operator learns by\ninspection or otherwise that atmospheric, external, or internal corrosion is not\ncontrolled as required by this subpart.\nOperator found deficiencies in the external corrosion control due to low pipe-to-soil readings on\nits galvanic anode system in December 2006 and January 2008. As of March 2008, the condition\nhad not been corrected.\nEvidence includes external corrosion monitoring records from 2005 to 2008, procedures, order\nfor replacement parts and photos.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. Also, for LNG facilities, an additional penalty of not more than\n$50,000 for each violation may be imposed. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitems identified in this letter. Failure to do so will result in Hopkinton LNG Corporation being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2008-3002W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n2\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nmah Nerdoff\nDirector, Eastern Rezion\nByron Coy, PE\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":7823}