# GOLDEN PASS LNG TERMINAL LLC — Warning Letter

**Citation:** CPF 420081016W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2008-09-22

CLOSED warning letter citing 192.225.

## Document text

Warning Letter involving GOLDEN PASS LNG TERMINAL LLC. PHMSA's enforcement data identifies the cited regulation as 192.225. The case was opened on 2008-09-22 and is reported as closed as of 2008-09-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420081016W_warning_09222008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420081016W/420081016W_warning_09222008.pdf

420081016w_warning_09222008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420081016W/420081016w_warning_09222008_text.pdf

420081016w_warning_09222008_text.pdf

U. S. Department
of Transportation
P(pellne antt
Htsztsrstous Materials Sofefy
Attmlnietratlon
87oi SOuth Bsstnsr, Biiirs 1 i i 0
Houston, TX 7rO'l4
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 22, 2008
Ms. Gina Dickerson
Project Manager
Golden Pass Pipeline LP
17001 Northchase Drive, Suite 686
Houston, Texas 77060
CPF 4-2008-1016W
Dear Ms. Dickerson:
During June 2008, a representative of the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Sheehan Pipe Line
Construction portion (MP16. 5 — 69. 0) of your Golden Pass Pipeline in Orangefield, TX.
As a result of the inspection, it appears that you have committed probable violations as noted below of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
$192. 225 Welding Procedures
(a) Welding must be performed by a qualified welder in accordance with welding procedures
qualified under section 5 of API 1104 (incorporated by reference, see $192. 7) or section IX of the
ASME Boiler and Pressure Vessel Code "Welding and Brazing Qualifications" (incorporated by
reference, see S)192. 7) to produce welds meeting the requirements of this subpart. The quality of
the test welds used to qualify welding procedures shall be determined by destructive testing in
accordance with the applicable welding standard(s).
(b) Each welding procedure must be recorded in detail, including the results of the qualifying
tests. This record must be retained and followed whenever the procedure is used.
The operator presented Repair Welding Inspection Records (from 02/11/08-05/03/08) showing that a
majority of these repair welds had not been completed within the parameters required by the operator's
welding procedures. The nonconformities included API 1104 "essential variables" (weld travel speeds,
welding rod classifications, etc. ) and other non-procedural issues.
The operator also presented records that welding inspectors were present during welding repairs. Those
records were incomplete in some areas. A field review of welding inspector performance was also
conducted, determining that the welding inspectors did not question welding repair procedures.



It is understood that Golden Pass Pipe Line has since reviewed its welding repair procedure records and
its welding procedures and has taken the following actions.
~ Reviewed its welding procedures for repairs and the related Procedure Qualification Records
(PQR's). Based on examining the PQR's, welding parameters have been expanded to cover a
majority of those factors that had exceeded the original procedures' allowances in order to qualify
those repairs.
~ The nonconforming repairs that could not be qualified under the revised procedures have either
been cut out or re-repaired and successfully non-destructively examined,
Under 49 United States Code, 5 60122, you are subject to a civil penalty not to exceed $100, 000 for each
violation for each day the violation persists up to a maximum of $1, 000, 000 for any related sedies of
violations. We have reviewed the circumstances and supporting documents involved in this case, and
have decided not to conduct additional enforcement action or penalty assessment proceedings at this
time. We advise you to correct the item identified in this letter. Failure to do so will result in Golden Pass
Pipeline LP being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-
2008-1016W. 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).
R. M. Seeley
Director, Southwest
Pipeline and Hazardous
Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420081016W>
- Source ID: `phmsa-enforcement`
- SHA-256: `0736915740a21047bf079b8d0a925e5665e45a20b1ef7c3fc13e6fc5fc5d6b89`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T16:16:48.529Z
- Document slug: `phmsa-enforcement-420081016w`

### Source metadata

```json
{
  "cpf": "420081016W",
  "operator": "GOLDEN PASS LNG TERMINAL LLC",
  "region": "Southwest",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.225"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "name": "420081016W_warning_09222008.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420081016W/420081016W_warning_09222008.pdf",
      "bytes": 215329,
      "category": "agency_document"
    },
    {
      "name": "420081016w_warning_09222008_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420081016W/420081016w_warning_09222008_text.pdf",
      "bytes": 836895,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "GOLDEN PASS LNG TERMINAL LLC"
}
```
