# CORPUS CHRISTI LIQUEFACTION, LLC — Warning Letter

**Citation:** CPF 420183006W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-12-14

CLOSED warning letter citing 193.2017(a).

## Document text

Warning Letter involving CORPUS CHRISTI LIQUEFACTION, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2017(a). The case was opened on 2018-12-14 and is reported as closed as of 2018-12-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420183006W_Warning Letter_12142018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183006W/420183006W_Warning%20Letter_12142018.pdf

420183006W_Warning Letter_12142018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183006W/420183006W_Warning%20Letter_12142018_text.pdf

420183006W_Warning Letter_12142018_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 14, 2018
Doug Shanda
Senior Vice President, Terminal Operations
Corpus Christi Liquefaction, LLC
700 Milam Street
Houston, Texas 77002
CPF 4-2018-3006W
Dear Mr. Shanda:
On July 17-20, 2017, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected
your LNG Liquefaction Facility in Corpus Christi, Texas.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected
and the probable violations is:
1. §193.2017 Plans and procedures
(a) Each operator shall maintain at each LNG plant the plans and procedures
required for that plant by this part. The plans and procedures must be available upon
request for review and inspection by the Administrator or any State Agency that has
submitted a current certification or agreement with respect to the plant under the
pipeline safety laws (49 U.S.C. 60101 et seq.). In addition, each change to the plans
or procedures must be available at the LNG plant for review and inspection within
20 days after the change is made.



Corpus Christi Liquefaction, LLC failed to develop plans and procedures for the inspection
of portable fire extinguishers. During the inspection, PHMSA requested to review the
procedure for the inspection of portable fire extinguishers. The Operator stated that they
did not have a procedure at the time of the inspection.
On August 21, 2017, an email was received from the Operator with a Fire Extinguisher
Inspection Procedure Document Number GPP-GHX-00013 Revision 000 dated August 18,
2017 attached. The procedure was reviewed by the PHMSA inspectors and was found
acceptable.
Failure to have a procedure resulted in portable fire extinguishers missing inspection tags,
as well as tags indicating either no inspection had been done, or not done at the required
frequency per NFPA-10-1998.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related
series of violations. For violations occurring prior to November 2, 2015, the maximum penalty
may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000
for a related series of violations. Also, for LNG facilities, an additional penalty of not more than
$76,352 for each violation may be imposed. 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(s) identified in
this letter. Failure to do so will result in Corpus Christi Liquefaction, LLC 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 4-2018-3006W. 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).
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420183006W>
- Source ID: `phmsa-enforcement`
- SHA-256: `8f5eb6c79f98b861f99ea2bbfc87c15a1a890c5c00c57acb047d4bedbb0e4c6d`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T23:15:04.288Z
- Document slug: `phmsa-enforcement-420183006w`

### Source metadata

```json
{
  "cpf": "420183006W",
  "operator": "CORPUS CHRISTI LIQUEFACTION, LLC",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LNG ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "193.2017(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "420183006W_Warning Letter_12142018.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420183006W/420183006W_Warning%20Letter_12142018.pdf",
      "bytes": 39513,
      "category": "agency_document"
    },
    {
      "name": "420183006W_Warning Letter_12142018_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420183006W/420183006W_Warning%20Letter_12142018_text.pdf",
      "bytes": 91173,
      "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": "CORPUS CHRISTI LIQUEFACTION, LLC"
}
```
