NATIONAL FUEL GAS SUPPLY CORP — Warning Letter

party submissionOfficial PDF12026034WL_Operator Response to Notice_05082026_(25-329604).pdf#

12026034WL_Warning Letter_03182026_(25-329604)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 609.771.7800 WARNING LETTER VIA ELECTRONIC MAIL TO: delvecchioj@natfuel.com March 18, 2026 Joseph Del Vecchio President National Fuel Gas Supply Corporation 6363 Main Street Williamsville, NY 14221 CPF 1-2026-034-WL Dear Mr. Del Vecchio: On July 28, 2017 and March 15, 2021, pursuant to 49 United States Code (U.S.C.) § 60118(c) and 49 Code of Federal Regulations (CFR) § 190.341, National Fuel Gas Supply Corporation (NFG) filed special permit requests with the Pipeline & Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), for waivers from certain provisions of 49 CFR Part 192. PHMSA may issue special permits to pipeline operators if the agency determines that a waiver of a particular regulation or standard is not inconsistent with pipeline safety. On August 27, 2019, and October 15, 2021, PHMSA issued orders granting NFG special permits with certain conditions and limitations (Orders). See PHMSA-2017-0090 and PHMSA-2021-0042. On June 8, 2025, a representative of the PHMSA, OPS, Eastern Region, pursuant to 49 U.S.C. §§ 60101-60143, conducted an inspection of NFG’s FlexSteel gas transmission pipeline in McKean, Elk, and Cameron Counties, Pennsylvania subject to the Orders. As a result of the inspection, it is alleged that NFG has committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR) and the Orders. As stated in 49 CFR § 190.203(f), when information obtained from an inspection indicates that further PHMSA action is warranted, PHMSA may initiate one or more enforcement proceedings prescribed in 49 CFR §§ 190.207 through 190.235. The probable violation is: 1. Condition 6: Corrosion Control a) … c) NFG must perform external corrosion control monitoring on each buried metallic fitting in accordance with 49 CFR 192.465. NFG#

12026034WL_Warning Letter_03182026_(25-329604)_text.pdf, page 2CPF 1-2026-034-WL must perform CP monitoring at least once each calendar year, not exceeding 15 months. Corrosion control monitoring of the buried metallic fittings by a sampling basis is not permitted. NFG failed to properly perform external corrosion control monitoring on each buried metallic fitting in accordance with Condition 6.c. Specifically, NFG reported eight locations with invalid native or depolarized corrosion potential measurements, ranging from -809 millivolts to -1441 millivolts. During the inspection, PHMSA reviewed cathodic protection records for the special permit FlexSteel segments. NFG provided a set of Test Station History Reports (07/09/2025). This report documented invalid native or depolarized corrosion potential measurements, ranging from -809 millivolts to -1441 millivolts at 8 locations: 9976, 9988, 9989, 9990, 9991, 9992, 9993, 11147. Therefore, NFG failed to properly perform external corrosion control monitoring on each buried metallic fitting in accordance with Condition 6.c. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the items identified in this letter. Failure to do so may result in National Fuel Gas Supply Corporation being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-2026-034-WL. 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). Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Steven Glass, Assistant VP, NFGS, GlassS@natfuel.com Steven Monnie, Senior Manager, NFGS, MonnieS@natfuel.com Page 2 of 2#