{"operation":"document","citation":"CPF 42025038NOA","title":"EAST TENNESSEE NATURAL GAS, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-08","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2017(c), 193.2503(g), 193.2505(a), 193.2505(b), 193.2509(a), 193.2509(b)(1), 193.2605(a), 193.2605(b), 193.2605(b)(2), 193.2605(c), 193.2617(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025038noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025038noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025038noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025038NOA","body":"Notice of Amendment involving EAST TENNESSEE NATURAL GAS, LLC. PHMSA's enforcement data identifies the cited regulations as 193.2017(c),  193.2503(g),  193.2505(a),  193.2505(b),  193.2509(a),  193.2509(b)(1),  193.2605(a),  193.2605(b),  193.2605(b)(2),  193.2605(c),  193.2617(a). The case was opened on 2025-07-08 and is reported as closed as of 2025-12-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025038NOA_Closure Letter_12122025_(24-298760).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025038NOA/42025038NOA_Closure%20Letter_12122025_(24-298760).pdf\n\n42025038NOA_Closure Letter_12122025_(24-298760)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025038NOA/42025038NOA_Closure%20Letter_12122025_(24-298760)_text.pdf\n\n42025038NOA_Notice of Amendment_07082025_(24-298760).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025038NOA/42025038NOA_Notice%20of%20Amendment_07082025_(24-298760).pdf\n\n42025038NOA_Notice of Amendment_07082025_(24-298760)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025038NOA/42025038NOA_Notice%20of%20Amendment_07082025_(24-298760)_text.pdf\n\n42025038NOA_Operator Response to Notice_08052025_(24-298760).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025038NOA/42025038NOA_Operator%20Response%20to%20Notice_08052025_(24-298760).pdf\n\n42025038NOA_Closure Letter_12122025_(24-298760)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com\nDecember 12, 2025\nCynthia Hansen\nExecutive Vice President and President\nEnbridge, Inc.\n915 North Eldridge Pkwy, Suite 1100\nHouston, Texas 77079\nRE: CPF 4-2025-038-NOA\nDear Ms. Hansen:\nFrom June 4 to 6, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of Title 49 of the United States Code (U.S.C.),\ninspected East Tennessee Natural Gas, LLC’s (ETNG) procedures for the operation and\nmaintenance of its liquefied natural gas (LNG) facilities in Kingsport, Tennessee.\nAs a result of this inspection, PHMSA issued ETNG a Notice of Amendment on July 8, 2025,\nproposing revisions to its procedures. ETNG submitted its amended procedures on August 5, 2025.\nMy staff has reviewed the amended procedures, and it appears that the inadequacies identified in\nthe Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Peter Seydewitz, Director, Operational Excellence, Enbridge, Inc.,\npeter.seydewitz@enbridge.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections - Office of\nEnergy Projects, Federal Energy Regulatory Commission,\nAndrew.Kohout@ferc.gov\n\n42025038NOA_Notice of Amendment_07082025_(24-298760)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com\nJuly 8, 2025\nCynthia Hansen\nExecutive Vice President and President\nEnbridge, Inc.\n915 North Eldridge Pkwy, Suite 1100\nHouston, Texas 77079\nCPF 4-2025-038-NOA\nDear Ms. Hansen:\nFrom June 4 to 6, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nEast Tennessee Natural Gas, LLC’s1 (ETNG) procedures for operations and maintenance of its\nliquefied natural gas (LNG) facilities in Kingsport, Tennessee.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nETNG’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\nto an abnormal operation that would affect safety. The procedures\nmust include provisions for:\n(a) . . . .\n(g) Cooldown of components according to the requirements of\n§ 193.2505.\n§ 193.2505 Cooldown.\n(a) The cooldown of each system of components that is subjected\nto cryogenic temperatures must be limited to a rate and distribution\npattern that keeps thermal stresses within design limits during the\n1 East Tennessee Natural Gas, LLC, is a subsidiary of Enbridge, Inc.\n\n\n\ncooldown period, paying particular attention to the performance of\nexpansion and contraction devices.\n(b) After cooldown stabilization is reached, cryogenic piping\nsystems must be checked for leaks in areas of flanges, valves, and\nseals.\nETNG’s written procedures for conducting normal operations activities were inadequate to provide\nfor safe operation of an LNG facility in accordance with § 193.2503(g). Specifically, ETNG’s\nprocedures, including Liquefied Natural Gas Operations Manual - Storage Tank Procedures,\nOPS-67.100-5 (Version 1.0; Dec. 2, 2024), Liquified Natural Gas Operations Manual - Send-Out\nProcedure, OPS-67.100-6 (Version 1.0; Oct. 15, 2024), and Liquified Natural Gas Operations\nManual - Miscellaneous Procedures, OPS-67.100-12 (Version 1.0, Oct. 21, 2024) failed to specify\nrates and distribution patterns to keep thermal stresses within design limits in accordance with\n§ 193.2505(a). In addition, none of the procedures included instructions for performing the\ncooldown of components in accordance with the requirements by § 193.2505(a) and (b).\nPHMSA proposes that ETNG revise its written procedures to include detailed instructions,\nincluding cooldown rates of components to keep thermal stresses within design limits, of how the\ncooldown of components is to be performed according to the requirements of § 193.2505, in\naccordance with § 193.2503(g).\n2. § 193.2509 Emergency procedures.\n(a) Each operator shall determine the types and places of\nemergencies other than fires that may reasonably be expected to occur\nat an LNG plant due to operating malfunctions, structural collapse,\npersonnel error, forces of nature, and activities adjacent to the plant.\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator\nmust follow one or more manuals of written procedures. The\nprocedures must provide for the following:\n(1) Responding to controllable emergencies, including notifying\npersonnel and using equipment appropriate for handling the\nemergency.\nETNG’s written procedures for adequately handling each type of emergency identified under\n§ 193.2509(a) were inadequate to provide for safe operation of a LNG facility in accordance with\n§ 193.2509(b). Furthermore, the procedures provided inadequate guidance regarding the response\nto controllable emergencies, including notifying personnel and using equipment appropriate for\nhandling the emergency in accordance with § 193.2509(b)(1) Specifically, ETNG’s procedure,\nLNG Operations Manual Emergency Tab B (Rev. 16; January 6, 2022) failed include response\nprocedures for handling emergencies other than fires that may reasonably be expected to occur at\nan LNG plant due to operating malfunctions, structural collapse, personnel error, forces of nature,\nand activities adjacent to the plant as required by under § 193.2509(a). ETNG’s procedures\nincluded instructions for handling only fires and spills.\n\n\n\nIn addition, ETNG’s Liquified Natural Gas Operations Manual - Emergency Procedures OPS-\n67.100-16 (Version 1.1; Nov, 14, 2024) also does not list any other type of emergencies other than\nfires. Finally, ETNG’s procedure, LNG Operations Manual Emergency Tab B (Rev. 16; Jan. 6,\n2022), section IV.A does not contain detailed instruction of how personnel should respond to a\ncontrollable rupture emergency, including notifying personnel and using equipment appropriate\nfor handling the emergency.\nTherefore, PHMSA proposes ETNG revise its written procedures to include the types and places\nof emergencies other than fires that may reasonably be expected to occur at an LNG plant due to\noperating malfunctions, structural collapse, personnel error, forces of nature, and activities\nadjacent to the plant as required by § 193.2509(a). ETNG must also include instructions for\npersonnel responding to controllable emergencies, including notifying personnel and using\nequipment appropriate for handling the emergency in accordance with § 193.2509(b)(1).\n3. § 193.2605 Maintenance procedures.\n(a) Each operator shall determine and perform, consistent with\ngenerally accepted engineering practice, the periodic inspections or\ntests needed to meet the applicable requirements of this subpart and\nto verify that components meet the maintenance standards prescribed\nby this subpart.\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 procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance; and\n(2) A descriptions of other actions necessary to maintain the LNG\nplant according to the requirements of this subpart.\nETNG’s written procedures for conducting maintenance activities were inadequate to provide for\nsafe operation of a LNG facility in accordance with § 193.2605(b). Specifically, ETNG’s\nprocedures, LNG Maintenance Manual M-1 Maintenance Procedures Tab A (Rev. 8; Aug. 8,\n2018) and Hazardous Energy Control Lockout/Tagout Procedure SAF-58.300 (Version 1.1, Apr.\n2, 2024) failed to identify components that are required to be inspected and tested, to include details\nof the inspections or tests determined under paragraph (a) of § 193.2604, the activities required to\nmaintain each component, including any required corrosion control, frequency of performance, or\nany descriptions of other actions necessary to maintain the LNG plant according the requirements\nof Subpart G, in accordance with § 193.2509(b)(1) and (2).\nTherefore, PHMSA proposes ETNG revise its written procedures to include detailed instructions\non components requiring inspections and tests, including any required corrosion control,\ninstructions to personnel on performing required maintenance, a schedule of the frequency of\nmaintenance performance, and a detailed description of any other actions necessary to maintain\nthe LNG plant in accordance with the maintenance requirements in Subpart G in accordance with\n§ 193.2509(b).\n\n\n\n4. § 193.2605 Maintenance procedures.\n(a) . . . .\n(c) Each operator shall include in the manual required by\nparagraph (b) of this section instructions enabling personnel who\nperform operation and maintenance activities to recognize conditions\nthat potentially may be safety-related conditions that are subject to\nthe reporting requirements of § 191.23 of this subchapter.\nETNG’s written procedures for conducting maintenance activities were inadequate to provide for\nsafe operation of a LNG facility in accordance with § 193.2605(c). are insufficient to adequately\nenable personnel who perform operation and maintenance activities to recognize conditions that\npotentially may be safety-related conditions that are subject to the reporting requirements of\n§ 191.23 of this subchapter, in accordance with § 193.2605(c). Specifically, ETNG’s procedure,\nSafety-Related Condition Reporting Procedure, SOP 5-2040 (Version 2.5; Dec. 1, 2023) failed to\nprovide adequate guidance for personnel to recognize safety-related conditions (SRCs).\nSection 6.1 Potential Reportable Conditions lists SRCs that repeat the list in 49 CFR § 191.23 and\nincludes conditions that are specific to transmission pipelines and underground natural gas storage\nfacilities, but does not include any instructions to personnel on recognizing potential SRCs at its\nKingsport LNG facility.\nTherefore, PHMSA proposes that ETNG revise its written procedures to enable personnel who\nperform operation and maintenance activities to recognize conditions that potentially may be\nsafety-related conditions that are subject to the reporting requires of § 191.23, in accordance with\n§ 193.2605(c).\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 procedure must include:\n(1) . . . .\n(2) A descriptions of other actions necessary to maintain the LNG\nplant according to the requirements of this subpart.\n§ 193.2617 Repairs.\n(a) Repair work on components must be performed and tested in a\nmanner which:\n(1) As far as practicable, complies with the applicable\nrequirements of Subpart D of this part; and\n(2) Assures the integrity and operational safety of the component\nbeing repaired.\n\n\n\nETNG’s written procedures for conducting maintenance activities were inadequate to provide for\nsafe operation of a LNG facility in accordance with § 193.2605(b)(2). ETNG’s written procedures\nare insufficient to adequately ensure that repair work on components must be performed and tested\nin a manner which as far as practicable, complies with the applicable requirements of Subpart D\nof Part 193 and assures the integrity and operational safety of the component being repaired, in\naccordance with § 193.2617(a). Specifically, ETNG’s procedures, LNG Maintenance Manual M-\n1 Maintenance Procedures Tab A (Rev. 8, August 8, 2018), and Hazardous Energy Control\nLockout/Tagout Procedure SAF-58.300 (Version 1.1, April 2, 2024) do not require that repair work\non components is performed and tested in a manner that complies with the construction\nrequirements in Subpart D, to the extent practicable, and fails to provide instructions on performing\nrepairs that assures the integrity and operational safety of the component being repaired in\naccordance with § 193.2617(a)(1) and (2).\nTherefore, PHMSA proposes ETNG revise its written procedures to include specific instructions\nfor performing repair work on components in a manner which, as far as practicable, complies with\nthe applicable requirements of Subpart D of Part 193 and assures the integrity and operational\nsafety of the component being repaired, in accordance with § 193.2617(a).\n6. § 193.2017 Plans and procedures.\n(a) . . . .\n(c) Each operator must review and update the plans and\nprocedures required by this part --\n(1) When a component is changed significantly or a new\ncomponent is installed; and\n(2) At intervals not exceeding 27 months, but at least once every 2\ncalendar years.\nETNG’s written procedures failed to require ETNG to review and update the plans and procedures\nrequired by Part 193 when a component is changed significantly or a new component is installed,\nand at intervals not exceeding 27 months, but at least once every 2 calendar years, in accordance\nwith § 193.2017(c). Specifically, ETNG did not provide specific written procedures or instructions\nin its procedures requiring that all written procedures and plans be reviewed and updated when a\ncomponent is changed significantly or a new component is installed and at intervals not exceeding\n27months, but at least once every 2 calendar years.\nTherefore, PHMSA proposes that ETNG updates its plans and procedures so that each is reviewed\nand updated as required by Part 193 when a component is changed significantly or a new\ncomponent is install and at intervals not exceeding 27 months, but at least once every 2 calendar\nyears, in accordance with § 193.2017(c).\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.\n\n\n\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 ETNG maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Bryan Lethcoe, Director, Southwest, Pipeline and Hazardous Materials\nSafety Administration. In correspondence concerning this matter, please refer to CPF 4-2025-\n038-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Peter Seydewitz, Director, Operational Excellence, Enbridge, Inc.,\npeter.seydewitz@enbridge.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":18313}