{"operation":"document","citation":"CPF 420133001W","title":"LAKE CHARLES LNG COMPANY, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-01-31","effective_on":null,"summary":"CLOSED warning letter citing 193.2619(c)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420133001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420133001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420133001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420133001W","body":"Warning Letter involving LAKE CHARLES LNG COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2619(c)(2). The case was opened on 2013-01-31 and is reported as closed as of 2013-01-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420133001W_Warning_01312013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420133001W/420133001W_Warning_01312013.pdf\n\n420133001W_Warning_01312013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420133001W/420133001W_Warning_01312013_text.pdf\n\n420133001W_Warning_01312013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 31, 2013\nMr. James Odum\nVice President of Operations, South Division\nTrunkline LNG Co.\n8100 Big Lake Road\nLake Charles, LA 70605\nCPF 4-2013-3001W\nDear Mr. Odum:\nOn October 29-31, 2012, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code was onsite and\ninspected your Trunkline LNG Co.’s (Trunkline) Liquified Natural Gas facility in Lake Charles,\nLA.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. §193.2619 Control systems.\n(c) Control systems in service, but not normally in operation, such as relief valves\nand automatic shutdown devices, and control systems for internal shutoff valves for\nbottom penetration tanks must be inspected and tested once each calendar year, not\nexceeding 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.\n\n\n\nTrunkline’s records for the inspection and testing of UV Detectors (specifically those identified\nunder PM No. 436-52 and PM No. 799-52) reflect that the scheduled activities were not\nperformed in accordance with the not to exceed 6 months limit of the regulations and Trunklines’\nown written procedure (Maintenance Procedures Manual Section 69.0 Instrumentation).\nFor PM No. 799-52, Work Order No. 11-1767 was dated November 4, 2011 and Work Order\nNo. 12-0292 was dated May 7, 2012 indicating that the inspections were not completed within\nthe six month time frame.\nFor PM No. 436-52, Work Order No. 11-1348 was dated August 23, 2011 and Work Order No.\n11-2294 was dated February 24, 2012 indicating that these inspections were not completed\nwithin the required six month time frame.\nInspection and testing of UV detection equipment is critical to the safe operation of a LNG\nfacility. UV/IR detection equipment are first line safety devices used to monitor for unintended\nreleases of product that could eventually lead to an unintended/uncontrolled fire or explosion\nwithin an operator’s facility or system.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2013-3001W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":3673}