NIAGARA MOHAWK POWER CORP — Notice of Amendment

party submissionOfficial PDF12020002NOA_Operator Response to Notice (20-172064)_06092020.pdf#

12020002NOA_Closure Letter_07312020_(20-172064)_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY July 31, 2020 Mr. Badar Khan President National Grid USA 40 Sylvan Road Waltham, MA 02451 CPF 1-2020-002-NOA Dear Mr. Khan: On February 4-6, 2020, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on- site pipeline safety inspection of Niagara Mohawk Power Corporation’s (Niagara) procedures at its LNG plant in Providence, Rhode Island. As a result of the inspection, Niagara was issued a Notice of Amendment on May 12, 2020, which proposed amendment of your procedures. Niagara submitted its amended procedures on June 9, 2020. My staff 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, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration CC: Mr. Ross Turrini, Senior Vice President, Gas Processing & Engineering, Niagara Mohawk Power Corp. (via email)#

12020002NOA_Notice of Amendment (20-172064)_05122020_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY May 12, 2020 Badar Khan President National Grid USA 40 Sylvan Road Waltham, MA 02451 CPF 1-2020-002-NOA Dear Mr. Khan: From February 4-6, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Niagara Mohawk Power Corporation’s (Niagara) procedures at its LNG plant in Providence, Rhode Island. Niagara is a subsidiary of National Grid USA. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Niagara’s plans or procedures, as described below: 1. § 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; and Niagara’s maintenance procedures were inadequate. Specifically, Niagara’s G11 Standard for Corrosion Control at LNG Plants, Rev 5 and G12 Corrosion Control Evaluation Policy for LNG Plants, Rev 4 (Procedures), and its other procedures relative to training, failed to define what experience and training is necessary to qualify a person in corrosion control technology in accordance with § 193.2707(c).#

12020002NOA_Notice of Amendment (20-172064)_05122020_text.pdf, page 2CPF 1-2020-002-NOA Section 193.2707(c) states: Corrosion control procedures under § 193.2605(b), including those for the design, installation, operation, and maintenance of cathodic protection systems, must be carried out by, or under the direction of, a person qualified by experience and training in corrosion control technology. During the inspection, the PHMSA inspector requested Niagara’s procedures regarding corrosion control technology training and experience requirements. Niagara provided its Procedures. When the PHMSA inspector requested additional information on experience and training for corrosion control personnel, Niagara did not have a response. In email follow-ups after the inspection, Niagara stated, “National Grid has developed a separate training policy -G26 LNG Operations Department Training Program that should be read in conjunction with the corrosion control procedures. This policy lays out the departmental requirements for an operator from trainee to qualified operator and finally fully qualified operator…G12 Corrosion Control Evaluation Policy, states LNG Operations responsibility when dealing with corrosion (Atmospheric Corrosion) and the Corrosion Department…” These additional documents did not mention specific requirements for qualifying the person or people responsible for carrying out Niagara’s corrosion control procedures. It was established in these procedures that Niagara’s Corrosion Department is responsible for carrying out all aspects of the corrosion control procedures, except atmospheric corrosion. Niagara’s procedures state that its Corrosion Department utilizes its departmental workforce and qualified outside contractors to perform corrosion control tasks. None of the procedures provided by Niagara include any provisions for what experience and training is required to consider the contractor personnel, or the person directing the contractor personnel, to be qualified in corrosion control technology. Therefore, Niagara failed to include guidance in its procedures to define what experience and training is necessary to qualify a person in corrosion control technology in accordance with § 193.2707(c). 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 12020002NOA_Notice of Amendment (20-172064)_05122020_text Page 2 of 3#

12020002NOA_Notice of Amendment (20-172064)_05122020_text.pdf, page 3CPF 1-2020-002-NOA 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 Niagara Mohawk Power Corporation maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2020-002-NOA on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office. Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings CC: Mr. Ross Turrini, Senior Vice President, Gas Processing & Engineering, Niagara Mohawk Power Corp., 25 Hub Drive, Melville, NY 11747 12020002NOA_Notice of Amendment (20-172064)_05122020_text Page 3 of 3#