5400 westheimer court p.o. box 1642 houston, tx...

5400 Westheimer Court Houston, TX 77056-5310

713.627.5400 main

Mailing Address: P.O. Box 1642 Houston, TX 77251-1642

February 26, 2016 Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington DC, 20426 Re: East Tennessee Natural Gas, LLC, Docket No. CP73-336-000 OEP/DG2E/LNG Status Update - Post-Inspection Recommendations Dear Ms. Bose:

On December 2, 2015, the Federal Energy Regulatory Commission’s (“Commission”) LNG Engineering & Compliance Branch issued a list of post-inspection recommendations resulting from an October 8, 2015 biennial inspection of East Tennessee Natural Gas, LLC’s (“East Tennessee”) Kingsport LNG facility. The list of recommendations included items that were either in the process of being addressed or that needed additional consideration and/or action by East Tennessee. East Tennessee provides herein an update on the status of each of the recommendations.

1. By February 26, 2016, file documentation of the actions taken regarding the recommendations from the February 13, 2015 Tetra Tech report. For any recommendations not implemented, include supporting justification. East Tennessee provides below a table with updates to the recommendations from the February 13, 2015 Tetra Tech report resulting from a request from East Tennessee for consulting services related to plans to upgrade the controls at the Kingsport LNG facility (“Control Upgrade Project”). In the table below, East Tennessee also includes supporting justification for those recommendations provided by Tetra Tech for which East Tennessee does not plan to take action at this time.

Ms. Kimberly D. Bose, Secretary February 26, 2016

Section Recommendation Status Date Comments

Equipment Protective Measures

4.1.1 Add Surge Control Valve on C1 MR compressor Under review TBD Under review.

4.1.2 Replace Turbine Air Inlet Filter on C1 Gas Turbine

To be completed 2016

To be completed in 2016 as part of the Control Upgrade Project.

4.1.3 Add Cold Dead Space vent relief valve (50 psig)



4.1.4 Replace Instrument Air Dryer (using unit already on hand) Under review TBD Under review.

Preventative Repairs

4.2.1 Investigate Coil Condition on regen heater for potential carburization on SS Coil Under review 2016 Under review.

4.2.2 Investigate and remedy reliability issues on vaporizer inlet flow measurement



4.2.3 Add LNG Tank Level System To be completed 2016


4.2.4 Replace Unsupported VFD on Compressor To be completed 2016


4.2.5 Replace Roto-meters on LNG Outlet from Cold Box Under review TBD Under review.

4.2.6 Fix Insulation on distance pieces (3 pieces) Completed 2015

Insulation removed, valves and penetrations inspected, re-insulated.

4.2.7 Rebuild C-5 Tail Gas Compressor To be completed 2016

To be completed during the Fall 2016 maintenance outage.

4.2.8 Replace LNG tank foundation heat components Under review TBD Under review.

Process

4.3.1 Capital maintenance on fin fan condenser (blades, shaft, etc.)



4.3.2 Replace plant inlet filter (S-1) with a high efficiency filter / separator

Review completed TBD

No further action planned at this time; will continue to monitor.

4.3.3 Improve pre-treatment to handle 3% CO2 (pipeline tariff level)

Review completed N/A

No further action needed at this time; will continue to monitor.

Safety

4.4.1 Change pressure for truck loading from 60 psig to 40 psig



4.4.2 Change ESD System to leave ExP lighting on during ESD event




2. Prior to repair activities and no later than February 26, 2016, file a procedure for repairing and placing back in service check valve V-H1A at Vaporizer 1 outlet that includes isolation, depressurization, and purging/venting plan. Please see Attachment A.

3. By June 30, 2016, file documentation that confirms check valve V-H1A at the Vaporizer 1 outlet has been repaired and placed back in service. East Tennessee will file documentation by June 30, 2016 that confirms check valve V-H1A has been repaired and placed back in service.

4. By June 30, 2016, file a schedule and plan to include tag numbers for the hazard

detection equipment in the fire and gas control system and human machine interface. As discussed with Commission Staff during the October 8, 2015 inspection, East Tennessee’s Kingsport LNG control system identifies hazard detection equipment by detector name and not by tag number. Please refer to Attachment B for photographs of East Tennessee’s hazard detection and alarm history screens which show equipment identification by equipment detector name. As requested by Commission Staff, East Tennessee installed equipment tags on the hazard detection equipment. However, these equipment tags are only used to identify the hazard detection equipment on the Hazard Detection drawings. Photographs of the recently installed equipment tags as well as the Hazard Detection drawings are also provided in Attachment B.

5. By June 30, 2016, file the updated piping and instrumentation drawing(s) and

photographs which show the nitrogen purge installation on LNG Pump 3 process seal interface. East Tennessee will file by June 30, 2016 updated piping and instrumentation drawing(s) and photographs which show the nitrogen purge installation on LNG Pump 3 process seal interface.


Should you have any questions regarding this filing, please contact me at (713) 627-4102 or David A. Alonzo, Manager, Certificates and Reporting at (713) 627-4957. Respectfully submitted, /s/ Lisa A. Connolly Lisa A. Connolly, General Manager Rates and Certificates Attachments cc: Andrew Kohout (FERC) Thach Nguyen (FERC) Karla Bathrick (FERC) Tim Ferguson (East Tennessee) John Harris (East Tennessee) Wayne Lemoi (PHMSA) Kenneth Lee (PHMSA)

East Tennessee Natural Gas, LLC, Docket No. CP73-336-000 OEP/DG2E/LNG

Status Update - Post-Inspection Recommendations

Attachment A

V‐H1A check valve replacement procedure

Prior to beginning procedure below, a pre‐job safety meeting will be conducted to review the procedure and a Job Safety Analysis (JSA) completed to identify any site specific hazards. In addition, a hot work permit will be issued in accordance with Spectra EHS procedures.

PROCEDURE

Isolation Isolate check valve V‐H1A (DRW ID‐E80166‐33) check valve by isolating valves listed below. Valves will be locked and tagged out and documented on 7T‐297.

Isolation Valves Plant Inlet DRW ID Vaporization Skid DRW ID Inlet/Outlet Skid DRW ID V‐15C‐Closed 73.6012.4 V‐H1B‐Closed E80166‐33 V‐1A‐Closed 73.6012.4 V‐15A‐Closed 73.6012.4 V‐H2B‐Closed E80166‐32 V‐1B‐Closed 73.6012.4 V‐415‐Closed 73.6012 V‐H3B‐Closed E80166‐31 V‐2‐Closed 73.6012.4 HCV‐8‐Open 73.6012.4 Blowdown

Blowdown Valves

Inlet Separator DRW ID Inlet/Outlet Skid V‐S1E 73‐6012.3 1” BV (Old Odorant Injection) Blowdown will be completed by opening 1” ball valve (Old odorant injection valve) on Inlet/Outlet skid and valve V‐S1E on plant inlet. Blowdown will until continue atmospheric pressure is reached. Work to be completed After blowdown is complete check valve V‐H1A cap will be removed and new check valve parts will be installed. Cap will be torqued to manufactures specifications.

Purge/Pack

Purge/Pack Valves

LNG Fuel Skid DRW ID Inlet/Outlet Skid DRW ID Inlet Separator DRW ID PI‐205 73.6012.4 V‐1A 73.6012.4 V‐S1E 73.6013.3 Isolated sections will be purged in two steps. Piping upstream of check valve H1A will be purged utilizing natural gas from valve PI‐205 on fuel skid. Valve H1B will be opened and natural gas will be introduced from valve PI205 through a high pressure hose to valve H1K and purged until 100% gas is achieved and for an additional 5 minutes. This will monitored from valve S1E. Once 100% gas is achieved Valve H1B will be closed and a solution purge will be used to purge piping downstream of check valve H1A. Purge will be achieved utilizing Valve 1A on inlet/outlet skid. Valve 1A will be cracked opened and purge will begin until 100% gas is achieved with a target pressure of 25 psi is reached. Piping will then be blowdown and process will be repeated two additional times to ensure a proper purge. Purge will be complete after 100% gas is achieved plus an additional 5 minutes on last purge. Process will be monitored from valve 1SE. Valve S1E will then be closed and packing of piping to pipeline pressure will begin. Return to Service Once pipeline pressure is reached, all isolated valves will be returned to normal operating positions and be returned to service with locks and tags removed.

East Tennessee Natural Gas, LLC, Docket No. CP73-336-000 OEP/DG2E/LNG

Status Update - Post-Inspection Recommendations

Attachment B

East Tennessee Natural Gas, LLCDocket No. CP73‐336‐000

Response to Post‐Inspection Recommendations

Photo 1: Hazard detection screen with the Vaporizer Area East (Flame Detector) and the Truck Skid (Gas Detector) circled in red.



Photo 2: Tabular view of hazard detection screen with the Vaporizer Area East (Flame Detector) and the Truck Skid (Gas Detector) circled in red.

Photo 3: Alarm History screen which shows the full tag name when an alarm is generated.



Photo 4: Truck Skid tag (Gas Detector)

Photo 5: Vaporizer Area East tag (Flame Detector)

FIGURE 5

Emergency, Tab AOperations Procedures

N

Storage Tank Pump Skid

Compressors

MRL Cooler

MRL Storage

Impoundment Dike

Building

Boiler

Skid

Isolation

Area

Pretreatment

Vaporizers

Firewater Pump Bldg. II

Firewater Pump Bldg. I

Skid

Meter

Fuel

Process Piping

Truck Skid

Control Building

COMBUSTIBLE GAS DETECTORS

COMPRESSOR BLDG.

GAS DETECTOR DETAILS IN

SEE FIGURE NO.9 FOR COMBUSTIBLE

ETNG

Tank

Water

Fire

FILE NAME: etng_eop_figure5.dgn

*NOTE

1

#32 - #49 NOT IN USE

2

3 4

5

6

7

8

9

10

11

12

13

1415

16

17

18

19

20

21

22

23

242526

27 28

29

30

31

50

51 52 53

54 55 5657

58

R3 - 11 / 2015

FIGURE 7

Emergency, Tab AOperations Procedures

N

Storage Tank Pump Skid

Compressors

MRL Cooler

MRL Storage

Impoundment Dike

Building

Boiler

Skid

Isolation

Area

Pretreatment

Vaporizers

Firewater Pump Bldg. II

Firewater Pump Bldg. I

Skid

Meter

Fuel

Process Piping

Truck Skid

Control Building

V

DETAILS IN COMPRESSOR BLDG.

SEE FIGURE NO.8 FOR UV DETECTOR

V

V

V

V

V

V

V

V

V

VV

V

VV

V

V

ETNG

Tank

Water

Fire

FILE NAME: etng_eop_figure7.dgn

UV/ IR DETECTORS

R4 - 11 / 2015

*NOTE

#15 NOT IN USE

13

16 17

18

19

14

3

4

5

6

7

8

9

10

11

12

1

2

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