# CHENIERE CORPUS CHRISTI PIPELINE — Notice of Amendment

**Citation:** CPF 420175026M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-06-20

CLOSED notice of amendment citing 192.163, 192.303.

## Document text

Notice of Amendment involving CHENIERE CORPUS CHRISTI PIPELINE. PHMSA's enforcement data identifies the cited regulations as 192.163,  192.303. The case was opened on 2017-06-20 and is reported as closed as of 2017-10-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420175026M_Closure Letter_10272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Closure%20Letter_10272017.pdf

420175026M_Closure Letter_10272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Closure%20Letter_10272017_text.pdf

420175026M_Notice of Amendment_06202017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Notice%20of%20Amendment_06202017.pdf

420175026M_Notice of Amendment_06202017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Notice%20of%20Amendment_06202017_text.pdf

420175026M_Operator Response to Notice_07172017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Operator%20Response%20to%20Notice_07172017.pdf

420175026M_Notice of Amendment_06202017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 20, 2017
Mr. Chad Zamarin
Vice President, Pipeline
Cheniere Corpus Christi Pipeline
700 Milam St, Suite 1900
Houston, TX 77002
CPF 4-2017-5026M
Dear Mr. Zamarin:
Between January 24 and February 24, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Cheniere’s procedures for constructing the Corpus Christi Pipeline in San Patricio County, TX.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Cheniere’s procedures, as described below:
1. §192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance with
comprehensive written specifications or standards that are consistent with this part.
The Cheniere Field Bending and Alignment of Pipe Specification document number ES-
PPL-7712-CU-0305 (Revision 0.1, 11/15/2016) does not provide adequate requirements
for performing field bends of spiral seam pipe. Cheniere was found to be constructing the
Corpus Christi Pipeline using spiral seam pipe but the specifications for bending did not
address this type of pipe. Cheniere’s procedure provides detailed specifications for
bending longitudinal seam pipe but is silent on requirements for spiral seam pipe actually
being used to construct the Corpus Christi Pipeline.
Some of the specifications that should be addressed in the Cheniere’s procedure include



but no limited to: position of bending shoes, whether the bending shoes are permitted to
press on the spiral weld-seam, the requirement for test bends, use of a mandrel, maintain
the minimum wall thickness requirements after bending, presentation of the cross sectional
shape, and no buckling, cracks or mechanical damage. Cheniere must amend its procedure
to include the written specifications for bending spiral weld-seam pipe as required in
§192.303.
2. §192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance with
comprehensive written specifications or standards that are consistent with this part.
The Cheniere Field Bending and Alignment of Pipe Specification document number ES-
PPL-7712-CU-0305 (Revision 0.1, 11/15/2016) does not provide adequate requirements
for offsetting the weld-seam for spiral weld-seam pipe. Cheniere was found to be
constructing the Corpus Christi Pipeline using spiral seam pipe but the specifications for
positioning the seams, when connecting, only addressed longitudinal strait seam pipe.
Cheniere’s procedure provides detailed specifications for offsetting longitudinal strait
seam pipe but is silent on requirements for longitudinal spiral seam pipe being used to
construct the Corpus Christi Pipeline. Cheniere must amend its procedure to include
comprehensive specifications for offsetting the weld seams on spiral weld pipe as required
by §192.303.
3. §192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance with
comprehensive written specifications or standards that are consistent with this part.
§192.163 Compressor stations: Design and construction.
(b) Building construction. Each building on a compressor station site must be
made of noncombustible materials if it contains either—
(1) Pipe more than 2 inches (51 millimeters) in diameter that is carrying gas
under pressure; or
(2) Gas handling equipment other than gas utilization equipment used for
domestic purposes.
The Cheniere Compressor Building Specification document number ES-PPL-7718
does not state that buildings, on a compressor station site, must be made of
noncombustible material. Cheniere must amend its procedure to require that all
buildings on a compressor station site are made of noncombustible material as
required by §192.163.
2



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 Compliance
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).
Following 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 30 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 Cheniere maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to the Terri J. Binns, Acting Director, Southwest, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 4-2017-5026M and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Jon Manning
Acting Director, Southwest
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
3

420175026M_Closure Letter_10272017_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 27, 2017
Jim Privett
Vice President, Project Management
Cheniere Corpus Christi Pipeline
700 Milam St, Suite 1900
Houston, TX, 77002
CPF 4-2017-5026M
Dear Mr. Privett:
Between January 24 and February 24, 2017, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of Cheniere Corpus Christi Pipeline procedures in
Houston, TX. As a result of the inspection, Cheniere Corpus Christi Pipeline was issued a Notice
of Amendment on June 20, 2017.
Cheniere Corpus Christi Pipeline submitted its amended procedures on July 17, 2017. The
amended procedures were reviewed and found acceptable.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Terri J. Binns
Acting Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420175026M>
- Source ID: `phmsa-enforcement`
- SHA-256: `07136f40419c29ac874bed2d577d7a84d1451ad7cc20ee764d8c69da5017cc4c`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T19:56:55.015Z
- Document slug: `phmsa-enforcement-420175026m`

### Source metadata

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  "jurisdiction": "US",
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}
```
