{"operation":"document","citation":"CPF 220123004W","title":"SOUTHERN GULF LNG COMPANY LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-11-27","effective_on":null,"summary":"CLOSED warning letter citing 193.2619(c)(2), 193.2629(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220123004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220123004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220123004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220123004W","body":"Warning Letter involving SOUTHERN GULF LNG COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 193.2619(c)(2),  193.2629(a)(2). The case was opened on 2012-11-27 and is reported as closed as of 2012-11-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220123004W_Operator response_06262013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220123004W/220123004W_Operator%20response_06262013.pdf\n\n220123004W_warning letter_11272012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220123004W/220123004W_warning%20letter_11272012.pdf\n\n220123004W_warning letter_11272012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220123004W/220123004W_warning%20letter_11272012_text.pdf\n\n220123004W_warning letter_11272012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 27, 2012\nMr. Dwayne Burton\nVice President Engineering/Operations\nSouthern Gulf LNG Company LLC\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 2-2012-3004W\nDear Mr. Burton:\nFrom October 22-25, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected the Southern Gulf LNG Company LLC (Gulf LNG)\nliquefied natural gas (LNG) facilities in Pascagoula, MS, pursuant to Chapter 601 of 49\nUnited States Code.\nAs a result of the inspection, it appears that Gulf LNG has committed probable violations of\nthe Pipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The items\ninspected and the probable violations are as follows:\n1. §193.2619 Control systems.\n. . . (c) Control systems in service, but not normally in operation, such as relief\nvalves and automatic shutdown devices, and control systems for internal shutoff\nvalves for bottom penetration tanks must be inspected and tested once each\ncalendar year, not exceeding 15 months, with the following exceptions:\n. . . (2) Control systems that are intended for fire protection must be inspected and\ntested at regular intervals not to exceed 6 months.\nGulf LNG did not inspect and test control systems intended for fire protection at intervals\nnot to exceed 6 months.\nThe Gulf LNG plant in-service date was October 1, 2011, yet maintenance records\nindicated that the control systems identified on Fire and Gas Cause and Effect Diagram\npages 5 through 13 were first inspected in August and September 2012.\nSubsequent to the PHMSA inspection, Gulf LNG provided records indicating that all of\nthe above-referenced fire protection control systems have been inspected and tested.\nInspection and test completion dates varied from September 11, 2012 (163 days after the\n\n\n\ninitial required 6-month test) to October 31, 2012 (213 days after the initial required\n2. 6-month test).\n§ 193.2629 External corrosion control: buried or submerged components.\n(a) Each buried or submerged component that is subject to external corrosive\nattack must be protected from external corrosion by—\n. . . (2) The following means:\n. . . (ii) A cathodic protection system designed to protect components in their\nentirety in accordance with the requirements of §192.463 of this chapter and placed\nin operation before October 23, 1981, or within 1 year after the component is\nconstructed or installed, whichever is later.\nGulf LNG did not protect from external corrosion, by a cathodic protection system,\ncertain buried components that were subject to external corrosive attack within one year\nafter the components were installed.\nGulf LNG did not cathodically protect the below-listed fire water system components\nmade of materials that do not resist underground external corrosion. The fire water\nsystem is . . . fire control equipment . . . whose integrity and reliability is necessary to\nmaintain safety in controlling . . . a hazardous fluid (see § 193.2007 Component\ndefinition), and was installed prior to the October 1, 2011 plant in-service date (installed\n390(+) days prior to the PHMSA inspection).\n- 17 short buried and coated 6-inch carbon steel piping segments that connect the\nunderground HDPE fire water distribution system to fire monitors,\n- coated and buried portions of 25 ductile iron fire hydrants, and associated coated and\nburied ductile iron fire hydrant isolation valves.\nSubsequent to the PHMSA inspection Gulf LNG conveyed, via email dated November\n14, 2012, that its contractor will provide cathodic protection to all buried steel and ductile\niron firewater system components that are currently without cathodic protection. The\nwork is currently out for bid and installation is projected to commence by January 2013.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. Also, for LNG facilities, an additional\npenalty of not more than $50,000 for each violation may be imposed. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Failure to do so will result in\nSouthern Gulf LNG Company, LLC being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-3004W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n3","truncated":false,"body_characters":6259}