# SOUTHERN LNG, INC — Warning Letter

- **operation:** document
- **citation:** CPF 220133001W
- **title:** SOUTHERN LNG, INC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-02-06
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 193.2619(e).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220133001W
**body:**

Warning Letter involving SOUTHERN LNG, INC. PHMSA's enforcement data identifies the cited regulation as 193.2619(e). The case was opened on 2013-02-06 and is reported as closed as of 2013-02-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220133001W_Operator Response Notice_12102013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220133001W/220133001W_Operator%20Response%20Notice_12102013.pdf

220133001W_warning letter_02062013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220133001W/220133001W_warning%20letter_02062013.pdf

220133001W_warning letter_02062013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220133001W/220133001W_warning%20letter_02062013_text.pdf

220133001W_warning letter_02062013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 6, 2013
Mr. Dwayne Burton
Vice President Engineering/Operations
Southern LNG, Inc.
c/o Kinder Morgan Inc.
1001 Louisiana Street, Suite 1000
Houston, TX 77002
CPF 2-2013-3001W
Dear Mr. Burton:
From December 4-6, 2012, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety Southern Region inspected the Southern
LNG, Inc. (SLNG) liquefied natural gas (LNG) facilities on Elba Island near Savannah,
Georgia, pursuant to Chapter 601 of 49 United States Code.
As a result of the inspection, it appears that SLNG has committed a probable violation of the
Pipeline Safety Regulations, in Title 49 of the Code of Federal Regulations. The item
inspected and the probable violation is as follows:
1. §193.2619 Control systems.
. . . (e) Relief valves must be inspected and tested for verification of the valve seat
lifting pressure and reseating.
SLNG did not properly inspect and test a relief valve for verification of the valve seat
lifting pressure.
On April 13, 2012, SLNG personnel inspected relief valve PSV-31035 (a control system
in service but not normally in operation) as required by §193.2619(c). However, the valve
seat lifting pressure was not properly verified prior to ending the inspection. According to
SLNG records, the seat lifting pressure for the 12-inch vacuum relief valve for LNG
Storage Tank D-5 was left at - 0.40” H2O instead of - 0.86” H2O as required by SLNG’s
written valve inspection criteria.



Under 49 United States Code, § 60122, Southern LNG, Inc. is subject to a civil penalty not to
exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000
for a related series of violations. For violations occurring prior to January 4, 2012, the
maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty
not to exceed $1,000,000 for a related series of violations. For LNG facilities, an additional
penalty of not more than $50,000 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 identified in this letter. Failure to do so will result in Southern
LNG, Inc. 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 2-2013-3001W. 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,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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