# EAST TENNESSEE NATURAL GAS, LLC (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment

- **operation:** document
- **citation:** CPF 42022027NOA
- **title:** EAST TENNESSEE NATURAL GAS, LLC (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-01-26
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 193.2503(b), 193.2503(c), 193.2503(g), 193.2505(a), 193.2513(a), 193.2513(b), 193.2513(c), 193.2605(b)(1), 193.2613, 193.2621(a), 193.2717(a), 193.2717(b), 193.2717(c).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42022027NOA
**body:**

Notice of Amendment involving EAST TENNESSEE NATURAL GAS, LLC (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulations as 193.2503(b),  193.2503(c),  193.2503(g),  193.2505(a),  193.2513(a),  193.2513(b),  193.2513(c),  193.2605(b)(1),  193.2613,  193.2621(a),  193.2717(a),  193.2717(b),  193.2717(c). The case was opened on 2022-01-26 and is reported as closed as of 2022-12-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42022027NOA_Closure Letter_12142022_(21-209158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022027NOA/42022027NOA_Closure%20Letter_12142022_(21-209158).pdf

42022027NOA_Closure Letter_12142022_(21-209158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022027NOA/42022027NOA_Closure%20Letter_12142022_(21-209158)_text.pdf

42022027NOA_Notice of Amendment_01262022_(21-209158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022027NOA/42022027NOA_Notice%20of%20Amendment_01262022_(21-209158).pdf

42022027NOA_Notice of Amendment_01262022_(21-209158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022027NOA/42022027NOA_Notice%20of%20Amendment_01262022_(21-209158)_text.pdf

42022027NOA_Operator Response to Notice_03252022_(21-209158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022027NOA/42022027NOA_Operator%20Response%20to%20Notice_03252022_(21-209158).pdf

42022027NOA_Notice of Amendment_01262022_(21-209158)_text.pdf

NOTICE OF AMENDMENT
ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
January 26, 2022
Michele Harradence
Senior Vice President and Chief Operating Officer
East Tennessee Natural Gas, LLC
5400 Westheimer Court
Houston, Texas 77056
CPF 4-2022-027-NOA
Dear Ms. Harradence:
From July 12, 2021 through August 17, 2021, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code,
inspected East Tennessee Natural Gas, LLC’s (ETNG) plans and procedures for its Peak Shaving
Liquified Natural Gas (LNG) facility located in Sullivan County, Tennessee.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
ETNG’s plans or procedures, as described below:
1. § 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written procedures to provide safety
in normal operation and in responding to an abnormal operation that would affect safety.
The procedures must include provisions for:
(a) . . .
(b) Startup and shutdown, including for initial startup, performance testing to
demonstrate that components will operate satisfactory in service.
ETNG’s written LNG Operations Manual, Liquefaction System (Date: 06/27/2018), is inadequate
because it does not include instructions for documenting startup and shutdown sequences in
accordance with § 193.2503(b).



Specifically, ETNG’s procedures regarding liquefaction system startup and shutdown instructs
ETNG personnel to follow an ordered sequence to perform startup and shutdown processes;
however, the procedure does not include provisions for recording the startup or shutdown to
demonstrate that the procedure is followed.
ETNG must amend its written procedures to include provisions to demonstrate that startup and
shutdown sequences are followed as per the written procedure in accordance with § 193.2503.
2. § 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written procedures to provide safety
in normal operation and in responding to an abnormal operation that would affect safety.
The procedures must include provisions for:
(a) . . .
(c) Recognizing abnormal operating conditions.
ETNG’s written LNG Operations Manual, Miscellaneous Procedures, Tab P (Date: 10/23/2017),
is inadequate because it does not include details for recognizing and responding to abnormal
operating conditions (AOCs).
ETNG’s procedures regarding AOCs do not include guidance related to recognizing and
responding to AOCs. Moreover, the same procedure references ETNG’s procedure “5-2050
Response to Abnormal Operating Operations,” which is applicable to gas transmission pipelines
subject to 49 CFR part 192 only.
ETNG must amend its written procedures to include provisions for recognizing and responding to
AOCs for its LNG operations.
3. § 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written procedures to provide safety
in normal operation and in responding to an abnormal operation that would affect safety.
The procedures must include provisions for:
(a) . . .
(g) Cooldown of components according to the requirements of § 193.2505.
§ 193.2505 Cooldown.
(a) The cooldown of each system of components that is subjected to cryogenic
temperatures must be limited to a rate and distribution pattern that keeps thermal
stresses within design limits during the cooldown period, paying particular attention to
the performance of expansion and contraction devices.
ETNG’s written LNG Operations Manual Send-Out (Date: 06/27/2018), is inadequate because it
does not include requirements for components subjected to cryogenic temperatures to be limited
to a rate and distribution pattern that keeps thermal stresses within design limits during the
cooldown period. ETNG’s procedure states:
2



Initial cooldown of the pump skid is accomplished by opening the
Internal Tank Valve, latching check valve T1R open and opening
valve V-T1P. This allows flow to by-pass valve V-T1Q thru by-pass
line 3/4A11-P-4. This is done to slowly lower the temperature of the
process piping and equipment to reduce thermal shock. After 72
hours, valve V-T1P can be closed and cooldown continued thru V-
T1Q.
ETNG’s procedure does not include temperature measurements to determine the cooldown rate of
components subject to cryogenic temperatures. ETNG’s procedure only requires that the initial
cooldown is performed over 72 hours without temperature measurements.
ETNG must amend its written procedures to include temperature rate and distribution
measurement during the cooldown period of components subjected to cryogenic temperatures to
keep thermal stresses within the design limit.
4. § 193.2513 Transfer procedures.
(a) Each transfer of LNG or other hazardous fluid must be conducted in accordance with
one or more manuals of written procedures to provide for safe transfers.
(b) The transfer procedures must include provisions for personnel to:
(1) Before transfer, verify that the transfer system is ready for use, with connections
and controls in proper positions, including if the system could contain a combustible
mixture, verifying that it has been adequately purged in accordance with a
procedure which meets the requirements of “Purging Principles and Practices
(incorporated by reference, see § 193.2013)”;
(2) Before transfer, verify that each receiving container or tank vehicle does not
contain any substance that would be incompatible with the incoming fluid and that
there is sufficient capacity available to receive the amount of fluid to be transferred;
(3) Before transfer, verify the maximum filling volume of each receiving container
or tank vehicle to ensure that expansion of the incoming fluid due to warming will
not result in overfilling or overpressure;
(4) When making bulk transfer of LNG into a partially filled (excluding cooldown
heel) container, determine any differences in temperature or specific gravity
between the LNG being transferred and the LNG already in the container and, if
necessary, provide a means to prevent rollover due to stratification.
(5) Verify that the transfer operations are proceeding within design conditions and
that overpressure or overfilling does not occur by monitoring applicable flow rates,
liquid levels, and vapor returns.
(6) Manually terminate the flow before overfilling or overpressure occurs; and
(7) Deactivate cargo transfer systems in a safe manner by depressurizing, venting,
and disconnecting lines and conducting any other appropriate operations.
(c) In addition to the requirements of paragraph (b) of this section, the procedures for
cargo transfer must be located at the transfer area and include provisions for personnel
to:
(1) Be in constant attendance during all cargo transfer operations;
3



(2) Prohibit the backing of tank trucks in the transfer area, except when a person is
positioned at the rear of the truck giving instructions to the driver;
(3) Before transfer, verify that:
(i) Each tank car or tank truck complies with applicable regulations governing its
use;
(ii) All transfer hoses have been visually inspected for damage and defects;
(iii) Each tank truck is properly immobilized with chock wheels, and electrically
grounded; and
(iv) Each tank truck engine is shut off unless it is required for transfer operations;
(4) Prevent a tank truck engine that is off during transfer operations from being
restarted until the transfer lines have been disconnected and any released vapors have
dissipated;
(5) Prevent loading LNG into a tank car or tank truck that is not in exclusive LNG
service or that does not contain a positive pressure if it is in exclusive LNG service,
until after the oxygen content in the tank is tested and if it exceeds 2 percent by
volume, purged in accordance with a procedure that meets the requirements of
“Purging Principles and Practices (incorporated by reference, see § 193.2013)”.
(6) Verify that all transfer lines have been disconnected and equipment cleared before
the tank car or tank truck is moved from the transfer position; and
(7) Verify that transfers into a pipeline system will not exceed the pressure or
temperature limits of the system.
ETNG’s written LNG Operations Manual, Miscellaneous Procedures, Tab S (Date: 06/27/2018),
is inadequate because it does not include instructions to perform hazardous fluid transfers.
ETNG’s procedure does not provide any instructions regarding the transfer process other than for
operating personnel to escort the delivery vehicle in and out of the facility.
ETNG must amend its written procedures to include detailed procedures for hazardous fluid
transfer process in accordance with § 193.2513. ETNG’s procedures should be expanded to
include all aspects related to the transfer process, including ensuring the tank truck or car complies
with applicable regulations governing its use; a visual inspection of hoses for damage and defects;
ensuring each tank truck is properly immobilized with chock wheels, and electrically grounded;
and ensuring that each tank truck is turned off unless it is required for transfer operations.
5. § 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;
§ 193.2613 Auxiliary power sources.
Each auxiliary power source must be tested monthly to check its operational capability
and tested annually for capacity. The capacity test must take into account the power
4



needed to start up and simultaneously operate equipment that would have to be served
by that power source in an emergency.
ETNG’s written LNG Operations Manual (Date: 06/27/2018),did not include a provision to test
auxiliary power sources monthly in order to check operational capability, or a provision to test
auxiliary power sources annually for capacity, in accordance with § 193.2613.
PHMSA requested ETNG’s test procedure regarding the Uninterruptible Power Supply (UPS)
system used as an auxiliary power source. ETNG responded that while it performed inspections,
it had not formalized the procedure and planned to make the appropriate revisions in the next
review cycle of its facilities procedures.
ETNG must amend its written procedures to include performing a monthly operational capability
test and an annual capacity test on its UPS system in accordance with § 193.2613.
6. § 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;
§ 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 exceeding 15 months, to the
maximum pump pressure or relief valve setting;
ETNG’s written LNG Maintenance Manual, M-4 Sendout System, Tab C (Date: 8/6/2018), is
inadequate as it does not include instructions for transfer hoses used in LNG or flammable
refrigerants transfer systems to be pressure tested to maximum pump pressure or relief valve
setting. ETNG’s procedure only states the interval and duration of the pressure test and the
documentation of the test results.
ETNG must amend its written procedure to include instructions for transfer hoses used in LNG or
flammable refrigerants transfer systems to be pressure tested to maximum pump pressure or relief
valve setting in accordance with § 193.2621(a).
7. § 193.2717 Training: fire protection.
(a) All personnel involved in maintenance and operations of an LNG plant, including
their immediate supervisors, must be trained according to a written plan of initial
instruction, including plant fire drills, to:
(1) Know the potential causes and areas of fire;
5



(2) Know the types, sizes, and predictable consequences of fire; and
(3) Know and be able to perform their assigned fire control duties according to the
procedures established under § 193.2509 and by proper use of equipment provided
under § 193.2801.
(b) A written plan of continuing instruction, including plant fire drills, must be
conducted at intervals of not more than two years to keep personnel current on the
knowledge and skills they gained in the instruction under paragraph (a) of the section.
(c) Plant fire drills must provide personnel hands-on experience in carrying out their
duties under the fire emergency procedures required by § 193.2509.
ETNG’s written procedures for training related to fire protection contained within its LNG
Operations Manual, Personnel, Tab A (Date: 10/23/2017), is inadequate because it does not
include details of initial and continuing fire protection training, including plant fire drills for
operation, maintenance, and supervisory personnel.
During the inspection, ETNG representatives stated that all personnel attend a two-day training at
LNG Fire School for initial fire protection training. Additionally, ETNG stated that the local fire
department is not trained to conduct LNG fire protection activities, and during an actual emergency
the local fire department will rely on the expertise of ETNG personnel for LNG fire protection
skills. PHMSA’s inspector requested procedures for initial fire training, and ETNG provided its
LNG Operations Manual, Personnel, Tab A (Date: 10/23/2017), which includes fire protection
training. However, the procedures do not include details regarding the two-day training at LNG
Fire School. Furthermore, ETNG’s procedures require personnel to review various fire protection
training activities and conduct hands-on plant fire drills.
PHMSA requested ETNG’s Plant Fire Drill Plan, and ETNG provided an informal fire drill
procedure without any document control. ETNG’s plant fire drill is divided into two types of
training, Code 1 and Code 2. ETNG’s plant fire drill procedures describe scenarios for Code 2
training, but there are no instructions regarding Code 1 training in the submitted procedures.
ETNG must amend its procedures to include details on initial and refresher fire protection training
for operation, maintenance, and supervisory personnel in accordance with § 193.2717. ETNG
must revise its Plant Fire Drills Plan to include potential causes, sizes, areas, and consequences of
a fire, and instructions for personnel to perform their duties according to emergency procedures as
required by § 193.2509.
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 Compliance
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).
6



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
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 East Tennessee Natural Gas, LLC maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Mary McDaniel, Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 4-2022-027-NOA and, for each document you submit,
please provide a copy in electronic format whenever possible.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Harold North, Senior Engineer of Operational Compliance, Enbridge,
harold.north@enbridge.com;
Leo Rosas Jr., Supervisor of Operational Compliance, Enbridge,
leo.rosasjr@enbridge.com;
Andrew Kohout, P.E., Director, Division of LNG Facility Reviews and Inspections
Office of Energy Projects, Federal Energy Regulatory Commission,
andrew.kohout@ferc.gov
7

42022027NOA_Closure Letter_12142022_(21-209158)_text.pdf

VIA ELECTRONIC MAIL
December 14, 2022
Michele Harradence
Senior Vice President and Chief Operating Officer
East Tennessee Natural Gas, LLC
5400 Westheimer Court
Houston, Texas 77056 CPF 4-2022-027-NOA
Dear Ms. Harradence:
From July 12, 2021, through August 17, 2021, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code,
inspected East Tennessee Natural Gas, LLC’s (ETNG) plans and procedures for its Peak Shaving
Liquified Natural Gas (LNG) facility located in Sullivan County, Tennessee. As a result of the
inspection, East Tennessee Natural Gas, LLC was issued a Notice of Amendment (Notice) on
January 26, 2022, which proposed amendments to ETNG’s procedures.
ETNG submitted its amended procedures on 03/25/2022 followed by 06/08/2022, 08/17/2022,
08/30/2022, and 10/17/2022 submittals. PHMSA reviewed the amended procedures, and it appears
that the inadequacies outlined in this Notice 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 in this matter.
Sincerely,
Bryan Lethcoe
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Harold North, Senior Engineer of Operational Compliance, Enbridge,
harold.north@enbridge.com;
Leo Rosas Jr., Supervisor of Operational Compliance, Enbridge,
leo.rosasjr@enbridge.com.
Andrew Kohout, P.E., Director, Division of LNG Facility Reviews and Inspections
Office of Energy Projects, Federal Energy Regulatory Commission,
andrew.kohout@ferc.gov
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