# VENTURE GLOBAL CP EXPRESS, LLC — Warning Letter

**Citation:** CPF 42026035WL  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2026-04-01

CLOSED warning letter citing 192.303.

## Document text

Warning Letter involving VENTURE GLOBAL CP EXPRESS, LLC. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2026-04-01 and is reported as closed as of 2026-04-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42026035WL_Operator Response to Notice_04072026_(24-297440).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026035WL/42026035WL_Operator%20Response%20to%20Notice_04072026_(24-297440).pdf

42026035WL_Warning Letter_04012026_(24-297440).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026035WL/42026035WL_Warning%20Letter_04012026_(24-297440).pdf

42026035WL_Warning Letter_04012026_(24-297440)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026035WL/42026035WL_Warning%20Letter_04012026_(24-297440)_text.pdf

42026035WL_Warning Letter_04012026_(24-297440)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
WARNING LETTER
VIA ELECTRONIC MAIL TO: bcothran@venturegloballng.com
April 1, 2026
Brian Cothran
Chief Operating Officer
Venture Global CP Express, LLC
1001 19th Street North, Ste 1500
Arlington, VA 22209
CPF 4-2026-035-WL
Dear Mr. Cothran:
From March 10, 2026 through 12, 2026 of the on-site inspection, a representative of the Pipeline
and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United
States Code (U.S.C.) inspected Venture Global CP Express LLC’s (Venture Global) CP Express
pipeline construction project in Jasper and Newton counties in Texas and Calcasieu and Cameron
Parishes in Louisiana.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
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.
Venture Global failed to construct its pipeline system in accordance with written comprehensive
specifications or standards consistent with Part 192 in accordance with § 192.303. Specifically,
Venture Global failed to follow the requirements in its written procedure, EPCM Roles &
Responsibilities Plan (CX-500600-CNS-PLN-GIE-00002) (Rev. 0, 05/06/2024) to ensure safety
onsite during construction. Section 7.9.3 of the procedure states that each “Construction
Contractor is required to develop a Job Safety Analysis (JSA) each day and will be based on the
scope of work for each crew. In addition, a separate JSA will be needed if conditions, scope of
work, or crew location changes. The JSA can be reviewed at tailgate meeting. The Inspector should



be present and ensure the JSA report is properly completed by the Construction Contractor and
signed by attendees.”
On March 10, 2026, PHMSA personnel at MP 41.700 (Spread 1) observed a gauge plate run being
performed after a horizontal directional drilling (HDD) installation. However, there was no JSA
form available onsite at the time of PHMSA’s inspection. A completed JSA was required in order
to satisfy the requirements of Section 7.9.3 of Venture Global’s EPCM Roles & Responsibilities
Plan (CX-500600-CNS-PLN-GIE-00002) (Rev. 0, 05/06/2024) procedure.
Therefore, Venture Global failed to construct its pipeline system in accordance with written
comprehensive specifications or standards consistent with Part 192 in accordance with § 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.
Venture Global failed to construct its pipeline system in accordance with written comprehensive
specifications or standards consistent with Part 192 in accordance with § 192.303. Specifically,
Venture Global failed to follow its written procedures, Welding and Fabrication Specification
(VG-000000-PPL-SPC-VGL-00009) (Rev. 10, 01/22/2025) and EPCM Roles & Responsibilities
Plan (CX-500600-CNS-PLN-GIE-00002) (Rev. 0, 05/06/2024).
Venture Global’s Welding and Fabrication Specification, Section 8.6 requires the welding
inspector to monitor and document that all weld parameters are in compliance with the approved
WPS. Section 8.6 requires that the welding inspector must monitor and document welding
parameters for each welder a minimum of twice per day. Venture Global’s EPCM Roles &
Responsibilities Plan, Section 8.19.2.2 requires that the welding inspector must ensure throughout
the project that only properly qualified welding procedures are being used. In addition, Section
8.19.2.7 includes a specific list of equipment, tools and calibration certificates that must be
provided by the welding inspector.
On March 11, 2026, PHMSA personnel at the CP2 Meter Station (Spread 4) observed that the
welding inspector failed to document the weld parameters as required by Venture Global’s written
procedures. In addition, the inspector failed to maintain proper calibration records for the
equipment used to verify the weld parameter during the production weld activities at the CP2 Meter
Station.
Therefore, Venture Global failed to construct its pipeline system in accordance with written
comprehensive specifications or standards consistent with Part 192 in accordance with § 192.303.
2



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.
Venture Global failed to construct its pipeline system in accordance with written comprehensive
specifications or standards consistent with Part 192 in accordance with § 192.303. Specifically,
Venture Global failed to follow its written procedure, Horizontal Directional Drill Plan (CX-
500600-CNS-PLN-SUN-00003) (Rev. 2, 03/04/2026).
Section 9 of the Horizontal Directional Drill Plan states that its contractor “maintains fluid
performance through the daily sampling, testing and recording of fluid properties throughout
drilling operations.” The contractor’s field report requires documentation of fluid performance
data including density (lbs/gal), viscosity (secs/qty), solids/sand content (% by vol) and pH.
On March 10, 2026, PHMSA personnel at MP 50.46 Mud Lake HDD (Spread 2) observed a mud
technician performing a viscosity test. When asked for a copy of the test documentation, the
technician responded that he does not record those readings. In addition, no pH testing was
observed during PHMSA’s inspection onsite. When PHMSA requested that Venture Global
provide test documentation, Venture Global provided several Drilling Fluid Reports. However,
the Drilling Fluid Reports did not document who conducted the testing. In addition, there was no
Drilling Fluid Field Testing Report for March 10, 2026.
Therefore, Venture Global failed to construct its pipeline system in accordance with written
comprehensive specifications or standards consistent with Part 192 in accordance with § 192.303.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related
series of violations. For violation occurring on or after December 28, 2023 and before December
30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation
persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring
on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed
$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related
series of violations. For violation occurring on or after March 21, 2022 and before January 6,
2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,
up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or
after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134
per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of
violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the
maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a
maximum of $2,225,034 for a related series of violations. For violation occurring on or after July
31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations.
3



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 items identified in this letter. Failure to do so may result in
Venture Global 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 4-2026-035-WL. 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,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Cc: Cole Sterling, Manager, Pipeline Regulatory Compliance,
csterling1@venturegloballng.com
James Palacios, Manager, Pipeline Regulatory Compliance,
jpalacios@venturegloballng.com
4

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/42026035WL>
- Source ID: `phmsa-enforcement`
- SHA-256: `b32735fdc8c39ce8a88846b068238fbadbb662ebd5f51f1b9de972cc68ed7cc7`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T13:58:39.774Z
- Document slug: `phmsa-enforcement-42026035wl`

### Source metadata

```json
{
  "cpf": "42026035WL",
  "operator": "VENTURE GLOBAL CP EXPRESS, LLC",
  "region": "Southwest",
  "pipelineType": "INTERSTATE GAS TRANSMISSION",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.303"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
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    },
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  ],
  "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": "VENTURE GLOBAL CP EXPRESS, LLC"
}
```
