{"operation":"document","citation":"CPF 120203002M","title":"HOPKINTON LNG CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-06-16","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120203002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120203002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120203002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120203002M","body":"Notice of Amendment involving HOPKINTON LNG CO. PHMSA's enforcement data identifies the cited regulation as 193.2605(b)(2). The case was opened on 2020-06-16 and is reported as closed as of 2020-07-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120203002M_Closure Letter_07162020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120203002M/120203002M_Closure%20Letter_07162020.pdf\n\n120203002M_Closure Letter_07162020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120203002M/120203002M_Closure%20Letter_07162020_text.pdf\n\n120203002M_Notice of Amendment_06162020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120203002M/120203002M_Notice%20of%20Amendment_06162020.pdf\n\n120203002M_Notice of Amendment_06162020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120203002M/120203002M_Notice%20of%20Amendment_06162020_text.pdf\n\n120203002M_Operator Response to Notice_06262020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120203002M/120203002M_Operator%20Response%20to%20Notice_06262020.pdf\n\n120203002M_Closure Letter_07162020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 16, 2020\nJames J. Judge\nChairman, President and Chief Executive Officer\nEversource Energy\n300 Cadwell Drive\nSpringfield, MA 01104\nCPF 1-2020-3002M\nDear Mr. Judge:\nFrom May 7 - May 9, 2019, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of Hopkinton LNG Co.’s (Hopkinton LNG) Liquefier Project in\nHopkinton, Massachusetts. As a result of the inspection, Hopkinton LNG was issued a Notice of\nAmendment on June 16, 2020, which proposed amendment of your procedures.\nHopkinton LNG submitted its amended procedures on or around June 26, 2020. My staff reviewed\nthe amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCC: Miguel Rodriguez, Manager LNG Operations (via email)\n\n120203002M_Notice of Amendment_06162020_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 16, 2020\nJames J. Judge\nChairman, President and Chief Executive Officer\nEversource Energy\n300 Cadwell Drive\nSpringfield, MA 01104\nCPF 1-2020-3002M\nDear Mr. Judge:\nFrom May 7, 2019 to May 9, 2019, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\nperformed a construction inspection of Hopkinton LNG Co.’s (Hopkinton LNG) Liquefier Project\nin Hopkinton, Massachusetts.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nHopkinton LNG’s plans or procedures, as described below:\n1. § 193.2605 Maintenance procedures.\n(a) …\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedures must include:\n(1) …\n(2) A description of other actions necessary to maintain the LNG\nplant according to the requirements of this subpart.\nHopkinton LNG's written procedures for the maintenance of each component were inadequate.\nSpecifically, Hopkinton LNG's procedures 3.3 External Corrosion Control and 3.5 Internal\nCorrosion Control failed to adequately address the requirements of § 193.2605(b)(2) as it pertains\nto § 193.2637.\n\n\n\nCPF 1-2020-3002M\nSection 193.2637 states:\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.\nDuring the inspection, a PHMSA inspector reviewed Hopkinton LNG’s procedure 3.3 External\nCorrosion Control, Section N, which stated in part \"Take prompt corrective or remedial action for\nany deficiency in external corrosion protection discovered as a result of any test survey or\ninspection.\" The inspector also reviewed Hopkinton LNG’s procedure 3.5 Internal Corrosion\nControl, Section F, which stated in part \"Take prompt corrective or remedial action for any\ndeficiency in internal corrosion protection discovered as a result of any test, survey, or inspection.\"\nThese two procedures used the phrase “prompt corrective or remedial action”, but failed to provide\na description of the necessary actions as required by § 193.2605(b)(2). Specifically, corrosion\nbeing a time dependent treat, the procedures lacked a description of actions that include a\ntimeframe for remediation of corrosion control deficiencies.\nThus, Hopkinton LNG’s written procedures for maintenance as required by § 193.2605 were\ninadequate as it pertains to § 193.2637.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Hopkinton LNG Co. maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region,\n840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2020-3002M\n120203002M_Notice of Amendment_06162020_text Page 2 of 3\n\n\n\nCPF 1-2020-3002M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\nUSB flash drive accompanied by the original paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nCC: Miguel Rodriguez, Manager LNG Operations (via email)\n120203002M_Notice of Amendment_06162020_text Page 3 of 3","truncated":false,"body_characters":7901}