{"operation":"document","citation":"CPF 420081016W","title":"GOLDEN PASS LNG TERMINAL LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-22","effective_on":null,"summary":"CLOSED warning letter citing 192.225.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420081016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420081016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420081016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420081016W","body":"Warning Letter involving GOLDEN PASS LNG TERMINAL LLC. PHMSA's enforcement data identifies the cited regulation as 192.225. The case was opened on 2008-09-22 and is reported as closed as of 2008-09-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420081016W_warning_09222008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420081016W/420081016W_warning_09222008.pdf\n\n420081016w_warning_09222008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420081016W/420081016w_warning_09222008_text.pdf\n\n420081016w_warning_09222008_text.pdf\n\nU. S. Department\nof Transportation\nP(pellne antt\nHtsztsrstous Materials Sofefy\nAttmlnietratlon\n87oi SOuth Bsstnsr, Biiirs 1 i i 0\nHouston, TX 7rO'l4\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 22, 2008\nMs. Gina Dickerson\nProject Manager\nGolden Pass Pipeline LP\n17001 Northchase Drive, Suite 686\nHouston, Texas 77060\nCPF 4-2008-1016W\nDear Ms. Dickerson:\nDuring June 2008, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Sheehan Pipe Line\nConstruction portion (MP16. 5 — 69. 0) of your Golden Pass Pipeline in Orangefield, TX.\nAs a result of the inspection, it appears that you have committed probable violations as noted below of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n$192. 225 Welding Procedures\n(a) Welding must be performed by a qualified welder in accordance with welding procedures\nqualified under section 5 of API 1104 (incorporated by reference, see $192. 7) or section IX of the\nASME Boiler and Pressure Vessel Code \"Welding and Brazing Qualifications\" (incorporated by\nreference, see S)192. 7) to produce welds meeting the requirements of this subpart. The quality of\nthe test welds used to qualify welding procedures shall be determined by destructive testing in\naccordance with the applicable welding standard(s).\n(b) Each welding procedure must be recorded in detail, including the results of the qualifying\ntests. This record must be retained and followed whenever the procedure is used.\nThe operator presented Repair Welding Inspection Records (from 02/11/08-05/03/08) showing that a\nmajority of these repair welds had not been completed within the parameters required by the operator's\nwelding procedures. The nonconformities included API 1104 \"essential variables\" (weld travel speeds,\nwelding rod classifications, etc. ) and other non-procedural issues.\nThe operator also presented records that welding inspectors were present during welding repairs. Those\nrecords were incomplete in some areas. A field review of welding inspector performance was also\nconducted, determining that the welding inspectors did not question welding repair procedures.\n\n\n\nIt is understood that Golden Pass Pipe Line has since reviewed its welding repair procedure records and\nits welding procedures and has taken the following actions.\n~ Reviewed its welding procedures for repairs and the related Procedure Qualification Records\n(PQR's). Based on examining the PQR's, welding parameters have been expanded to cover a\nmajority of those factors that had exceeded the original procedures' allowances in order to qualify\nthose repairs.\n~ The nonconforming repairs that could not be qualified under the revised procedures have either\nbeen cut out or re-repaired and successfully non-destructively examined,\nUnder 49 United States Code, 5 60122, you are subject to a civil penalty not to exceed $100, 000 for each\nviolation for each day the violation persists up to a maximum of $1, 000, 000 for any related sedies of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in Golden Pass\nPipeline LP being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-\n2008-1016W. Be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U. S. C. 552(b), along with the complete original document you must provide\na second copy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential treatment under\n5 U. S. C. 552(b).\nR. M. Seeley\nDirector, Southwest\nPipeline and Hazardous\nMaterials Safety Administration","truncated":false,"body_characters":4848}