{"operation":"document","citation":"CPF 42025033NOA","title":"NFENERGIA LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-03","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2503(b), 193.2503(g), 193.2509(b)(3), 193.2605(b)(1), 193.2605(b)(2), 193.2611(a), 193.2613, 193.2619(a), 193.2625(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025033noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025033noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025033noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025033NOA","body":"Notice of Amendment involving NFENERGIA LLC. PHMSA's enforcement data identifies the cited regulations as 193.2503(b),  193.2503(g),  193.2509(b)(3),  193.2605(b)(1),  193.2605(b)(2),  193.2611(a),  193.2613,  193.2619(a),  193.2625(a). The case was opened on 2025-07-03 and is reported as closed as of 2025-10-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025033NOA_Closure Letter_10102025_(24-298759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Closure%20Letter_10102025_(24-298759).pdf\n\n42025033NOA_Closure Letter_10102025_(24-298759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Closure%20Letter_10102025_(24-298759)_text.pdf\n\n42025033NOA_Notice of Amendment_07032025_(24-298759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Notice%20of%20Amendment_07032025_(24-298759).pdf\n\n42025033NOA_Notice of Amendment_07032025_(24-298759)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Notice%20of%20Amendment_07032025_(24-298759)_text.pdf\n\n42025033NOA_Operator Response to Notice_09162025_(24-298759).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025033NOA/42025033NOA_Operator%20Response%20to%20Notice_09162025_(24-298759).pdf\n\n42025033NOA_Closure Letter_10102025_(24-298759)_text.pdf\n\nVIA ELECTRONIC MAIL TO: zahmed@newfortressenergy.com\nOctober 10, 2025\nZak Ahmed\nManaging Director\nNew Fortress Energy, LP\n111 W 19th Street, 8th floor\nNew York, NY 10011\nRE: CPF 4-2025-033-NOA\nDear Mr. Ahmed:\nFrom April 22 to 24, 2024 of the on-site inspection, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected NFEnergía, LLC’s1 (NFEnergía) procedures for operations and maintenance of its\nliquefied natural gas (LNG) facility in San Juan, Puerto Rico.\nAs a result of the inspection, NFEnergía was issued a Notice of Amendement on July 3, 2025,\nwhich proposed amendement of your procedures. NFEnergía submitted its amended procedures on\nSeptember 16, 2025. My staff has reviewed the amended procedures, and it appears that the\ninadequacies outlined in this Notice of Amendment have 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,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Shakira Mosquera, HSSEQ Manager, NFEnergía LLC,\nsmosquera@newfortressenergy.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections, Office of\nEnergy Projects, Federal Energy Regulatory Commission, andrew.Kohout@ferc.gov\n1NFEnergía is a subsidiary of New Fortress Energy, Inc.\n\n42025033NOA_Notice of Amendment_07032025_(24-298759)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: cguinta@newfortressenergy.com\nJuly 3, 2025\nChristopher S. Guinta\nChief Financial Officer\nNew Fortress Energy Inc.\n111 W 19th Street, 8th floor\nNew York, NY 10011\nCPF 4-2025-033-NOA\nDear Mr. Guinta,\nFrom April 22 to 24, 2024 of the on-site inspection, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected NFEnergía, LLC’s1 (NFEnergía) procedures for operations and maintenance\nof its liquefied natural gas (LNG) facility in San Juan, Puerto Rico.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nNFEnergía’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written\nprocedures to provide safety in normal operation and in responding to\nan abnormal operation that would affect safety. The procedures must\ninclude provisions for:\n(a) . . . .\n(b) Startup and shutdown, including for initial startup,\nperformance testing to demonstrate that components will operate\nsatisfactory in service.\nNFEnergía's written procedures for conducting normal operations were inadequate to provide for\nsafe operation of a LNG facility in accordance with § 193.2503(b). Specifically, NFEnergía's\noperating procedures, San Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations\nand Maintenance Plan (Rev. 0.1; April 18, 2024), and Program Procedure: Conduct of Operations\nSan Juan LNG Terminal, NFE-SAN JUAN-193-0002 (Rev. 0, April 17, 2024) failed to provide\n1 NFEnergía is a subsidiary of New Fortress Energy, Inc.\n\n\n\ninstructions for performance testing to demonstrate that components will operate satisfactory in\nservice.\nPHMSA proposes NFEnergía revise its written procedures to include provisions, including\ninstructions and identification of components, for performance testing to demonstrate that\ncomponents will operate satisfactory in service in accordance with § 193.2503(b).\n2. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written\nprocedures to provide safety in normal operation and in responding to\nan abnormal operation that would affect safety. The procedures must\ninclude provisions for:\n(a) .…\n(g) Cooldown of components according to the requirements of\n§ 193.2505.\nNFEnergía's written procedures for conducting normal operations were inadequate to provide for\nsafe operation of a LNG facility in accordance with § 193.2503(g). Specifically, NFEnergía's San\nJuan Multi-Fuel Handling Facility Liquefied Natural Gas Operations and Maintenance Plan\n(Rev. 0.1; April 18, 2024), section 7.3.1 Cooldown (§ 193.2505), and Program Procedure:\nConduct of Operations San Juan LNG Terminal, NFE-SAN JUAN-193-0002 (Rev. 0, April 17,\n2024) failed to provide instructions on how to limit the rate and distribution pattern to keep thermal\nstresses within design limits during the cooldown periods, paying particular attention to the\nperformance of expansion and contraction devices, in accordance with § 193.2505. Additionally,\nNFEnergía's procedures failed to identify components at its facility that are subjected to cooldown\nrates and distribution patterns.\nPHMSA proposes NFEnergía revise its written procedures to include provisions, including\ninstructions to personnel and identification of components, for the cooldown of components\naccording to the requirements of § 193.2505, in accordance with § 193.2503(g).\n3. § 193.2509 Emergency procedures.\n(a) . . . .\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator must\nfollow one or more manuals of written procedures. The procedures must\nprovide for the following:\n(1) . . . .\n(3) Coordinating with appropriate local officials in preparation of an\nemergency evacuation plan, which sets forth the steps required to protect\nthe public in the event of an emergency, including catastrophic failure of\nan LNG storage tank.\n\n\n\nNFEnergía’s written procedures for adequately handling each type of emergency identified under\n§ 193.2509(a) and each fire emergency were inadequate to provide for safe operation of a LNG\nfacility in accordance with § 193.2509(b)(3). Specifically, NFEnergía’s procedures, San Juan\nMulti-Fuel Handling Facility Liquefied Natural Gas Operations and Maintenance Plan (Rev. 0.1;\nApril 18, 2024), section 7.3.3 Emergency Procedures (§ 193.2509), and Micro Fuel Handling\nFacility Emergency Response Plan (Rev. 001, November 2, 2023), failed to provide instructions\non coordinating with appropriate local officials in preparation of an emergency evacuation plan,\nwhich sets forth the steps required to protect the public in the event of an emergency, including\ncatastrophic failure of an LNG storage tank. NFEnergía’s procedures did not identify the\nappropriate local authorities to be contacted in the event of an incident, and did not provide for\ncoordinating or participating in emergency drills designed to prepare NFEnergía personnel and\nlocal authorities to respond to emergencies and foster cooperative relationships.\nPHMSA proposes NFEnergía revise its written procedures to provide for coordinating with local\nofficials in preparation of an emergency evaluation plan in accordance with § 193.2509(b)(3).\n4. § 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.\n§ 193.2611 Fire protection.\n(a) Maintenance activities on fire control equipment must be\nscheduled so that a minimum of equipment is taken out of service at\nany one time and is returned to service in a reasonable period of time.\nNFEnergía’s written procedures for conducting maintenance activities were inadequate to provide\nfor safe operation of a LNG facility in accordance with § 193.2605(b)(2). Specifically,\nNFEnergía’s procedures, San Juan Multi-Fuel Handling Facility Liquefied Natural Gas\nOperations and Maintenance Plan (Rev. 0.1; April 18, 2024), and Safe Work Practices, Fire\nProtection, LNG San Juan, NFE-SAN JAN-193-007 (Rev. 0; April 17, 2024) failed to provide\nadequate guidance on how NFEnergía performs maintenance activities on fire control equipment\nso that a minimum of equipment is taken out of service at any one time and is returned to service\nin a reasonable period of time in accordance with 193.2611(a). NFEnergía’s procedures did not\nrequire a minimum amount of fire control equipment or identify how many pieces of equipment\ncan be taken out of service at any one time, or define a reasonable period of time to return\nequipment to service.\n\n\n\nPHMSA proposes NFEnergía revise its procedures to include requirements that enumerate the\nminimum amount of fire control equipment that can be taken out of service at one time and define\nthe reasonable period of time needed to perform maintenance on fire control equipment before\nreturning to service in accordance with § 193.2611(a).\n5. § 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) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance; . . . .\n§ 193.2613 Auxiliary power sources.\nEach auxiliary power source must be tested monthly to check its\noperational capability and tested annually for capacity. The capacity\ntest must take into account the power needed to start up and\nsimultaneously operate equipment that would have to be served by that\npower source in an emergency.\nNFEnergía's written procedures for conducting maintenance activities were inadequate to provide\nfor safe operation of a LNG facility in accordance with § 193.2605(b)(1). Specifically,\nNFEnergía's San Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations and\nMaintenance Plan (Rev. 0.1; April 18, 2024), did not identify what equipment must remain in\noperation during an emergency, does not include the required capacity of the auxiliary power\nsources, and does not provide instructions on how to test the capacity of the auxiliary power\nsources in accordance with § 193.2613. Additionally, NFEnergía’s procedures did not provide\nguidance on how auxiliary power source capacity test results must be recorded.\nPHMSA proposes NFEnergía revise its written procedures to include requirements and\ninstructions for testing its auxiliary power sources monthly to check for operation capability and\nannually for capacity in accordance with § 193.2613.\n6. § 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.\n§ 193.2619 Control systems.\n(a) Each control system must be properly adjusted to operate within\ndesign limits.\n\n\n\nNFEnergía's written procedures for conducting maintenance activities were inadequate to provide\nfor safe operation of a LNG facility in accordance with § 193.2605(b)(2). Specifically,\nNFEnergía's San Juan Multi-Fuel Handling Facility Liquefied Natural Gas Operations and\nMaintenance Plan (Rev. 0.1; April 18, 2024), section 8.9 Control Systems (§ 193.2619) failed to\nidentify each control system, provide instructions to NFEnergía's personnel regarding how to\ninspect and adjust the control systems to operate within design limits, or define the design limits\nfor each control system.\nPHMSA proposes NFEnergía revise its written procedures to include instructions for properly\nadjusting each control system to operate within design limits, in accordance with § 193.2619(a).\n7. § 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.\n§ 193.2625 Corrosion protection.\n(a) Each operator shall determine which metallic components\ncould, unless corrosion is controlled, have their integrity or reliability\nadversely affected by external, internal, or atmospheric corrosion\nduring their intended service life.\nNFEnergía's written procedures for conducting maintenance activities were inadequate to provide\nfor safe operation of a LNG facility in accordance with § 193.2605(b)(2). Specifically,\nNFEnergía's procedures, San Juan Multi-Fuel Handling Facility Liquefied Natural Gas\nOperations and Maintenance Plan (Rev. 0.1; April 18, 2024), section 8.11 Corrosion Protection\n(§ 193.2625), does not explain how NFEnergía personnel will determine which metallic\ncomponents require corrosion protection, explain which type of corrosion protection is appropriate\nfor each component, or provide guidance on how to categorize the degree of metal loss due to\ncorrosion and how to record it.\nPHMSA proposes NFEnergía revise its written procedures to give instruction to personnel on how\nto evaluate components that are susceptible to corrosion loss, determine which metallic\ncomponents could, have their integrity or reliability adversely affected by corrosion during their\nintended service life, and how to categorize any corrosion loss and record it in accordance with\n§ 193.2625(a).\n\n\n\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.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 NFEnergía maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Bryan Lethcoe, Director, Southwest, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-\n2025-033-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Komi Hassan, DOT Compliance Primary, NFEnergía, LLC,\nkhassan@newfortressenergy.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections\nOffice of Energy Projects, Federal Energy Regulatory Commission,\nandrew.Kohout@ferc.gov","truncated":false,"body_characters":17578}