SOUTHERN GULF LNG COMPANY LLC — Notice of Amendment

party submissionOfficial PDF42024061NOA_Operator Response to Notice_12132024_(24-297302).pdf#

42024061NOA_Notice of Amendment_11192024_(24-297302)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: kim dang@kindermorgan.com November 19, 2024 Kimberly Dang Chief Executive Officer Kinder Morgan 1001 Louisiana St, STE 1000 Houston, TX 77002 CPF 4-2024-061-NOA Dear Ms. Dang: From February 26 to 29, 2024, of the on-site inspection, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Southern Gulf LNG Company LLC’s (Gulf LNG) procedures for operating and maintaining its liquefied natural gas (LNG) facility in Pascagoula, Mississippi. As a result of the inspection, PHMSA has identified the apparent inadequacies found within Gulf LNG’s plans or procedures. The items inspected and the inadequacies are described below: 1. § 193.2509 Emergency procedures. (a) . . . . (b) To adequately handle each type of emergency identified under paragraph (a) of this section and each fire emergency, each operator must follow one or more manuals of written procedures. The procedures must provide for the following: (1) . . . . (3) Coordinating with appropriate local officials in preparation of an emergency evacuation plan, which sets forth the steps required to protect the public in the event of an emergency, including catastrophic failure of an LNG storage tank. Gulf LNG’s written emergency response plan was inadequate to handle each type of emergency in accordance with § 193.2509(b)(3). Specifically, Gulf LNG’s Emergency Response Plan, EHS- PLA-001, (Rev. 13; January 10, 2024) failed to include operator- and facility-specific procedures for coordinating with appropriate local officials in the emergency evacuation plan that sets forth the steps required to protect the public in the event of an emergency, including catastrophic failure of an LNG storage tank.#

42024061NOA_Notice of Amendment_11192024_(24-297302)_text.pdf, page 2After the issuance of the preliminary written findings report, Gulf LNG submitted preliminary revised procedures, Emergency Response Plan, EHS-PLA-001, (Rev. 13; January 10, 2024). The proposed revisions corrected the inadequacy. Once the procedure is published, no further revisions are required. 2. § 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) . . . . (2) A description of other actions necessary to maintain the LNG plant according to the requirements of this subpart. § 193.2637 Remedial measures. Prompt corrective or remedial action must be taken whenever an operator learns by inspection or otherwise that atmospheric, external, or internal corrosion is not controlled as required by this subpart. Gulf LNG’s written procedures for conducting maintenance activities were inadequate to assure safe operation of a pipeline facility in accordance with § 193.2605(b)(2). Specifically, Gulf LNG’s procedures, Internal Corrosion Control, LNG O&M 906, (October 1, 2017) and Inspecting for Atmospheric Corrosion, LNG O&M 918, (November 1, 2021), failed to provide a timeframe for “prompt” remediation of all types of corrosion in accordance with § 193.2637. After the issuance of the preliminary written findings report, Gulf LNG submitted revised procedures. Gulf LNG added a timeframe for prompt remediation in Inspecting for Atmospheric Corrosion, LNG O&M 918, (April 4, 2024). However, Gulf LNG failed to add a similar definition to Internal Corrosion Control, LNG O&M 906, (October 1, 2017). Gulf LNG must revise its procedures to define a “prompt” timeframe for the remediation of internal corrosion. 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).#

42024061NOA_Notice of Amendment_11192024_(24-297302)_text.pdf, page 3Following 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 60 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 Gulf LNG maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2024-061-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Darwin Stillson, PM / FSO / Compliance / Environmental, Gulf LNG, darwin_stillson@kindermorgan.com#

42024061NOA_Closure Letter_03212025_(24-297302)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: kim dang@kindermorgan.com March 21, 2025 Kimberly Dang Chief Executive Officer Kinder Morgan 1001 Louisiana St, Suite 1000 Houston, TX 77002 RE: CPF 4-2024-061-NOA Dear Ms. Dang: From February 26 to 29, 2024, of the on-site inspection, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), reviewed Southern Gulf LNG Company, LLC’s (Gulf LNG) procedures for operating and maintaining its liquefied natural gas (LNG) facility in Pascagoula, Mississippi. As a result of the inspection, Gulf LNG was issued a Notice of Amendment on November 19, 2024, which proposed amendment of your procedures. Gulf LNG submitted advanced copies of the amended procedures in response to the Notice of Amendment on December 12, 2024, and submitted its final amended procedures on February 3, 2025. My staff has 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 that no further action is necessary, and this case is now closed. Thank you for your cooperation. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Darwin Stillson, PM / FSO / Compliance / Environmental, Gulf LNG, darwin_stillson@kindermorgan.com Zach Ragain, Director – Engineering Compliance Codes and Standards, Gulf LNG, zach_ragain@kindermorgan.com#