{"operation":"document","citation":"CPF 420151011W","title":"FREEPORT LNG DEVELOPMENT, L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-11-04","effective_on":null,"summary":"CLOSED warning letter citing 192.303, 192.55(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420151011w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420151011w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420151011w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420151011W","body":"Warning Letter involving FREEPORT LNG DEVELOPMENT, L.P.. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.55(a)(1). The case was opened on 2015-11-04 and is reported as closed as of 2015-11-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420151011W_Warning Letter_11042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151011W/420151011W_Warning%20Letter_11042015.pdf\n\n420151011W_Warning Letter_11042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151011W/420151011W_Warning%20Letter_11042015_text.pdf\n\n420151011W_Warning Letter_11042015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 4, 2015\nMr. Bill Henry\nVice President\nFreeport LNG Development, L.P.\n333 Clay Street, Suite 5050,\nHouston, TX 77002\nCPF 4-2015-1011W\nDear Mr. Henry:\nOn August 5-6, 2015, two representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the construction\nof your Freeport LNG (FLNG) expansion project in Freeport, Texas.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation(s) is:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with this part.\n§192.55 Steel pipe.\n(a) New steel pipe is qualified for use under this part if:\n(1) It was manufactured in accordance with a listed specification;\nAPI 5L Annex A.\nA.1.2 welding procedures, welders and welding machine operators (hereafter called\noperators) shall be qualified in accordance with a standard approved by the\npurchaser.\n\n\n\nFLNG failed to follow their written specification for the manufacturing of line-pipe standards used in\nthe construction of their Freeport, Texas pipeline facility. Specifically, FLNG failed to approve the\nstandard used to qualify the welding procedures and welders for the manufacturing of 7,664 ft. coated\nand 450 ft. bare 42-inch API 5L X-65 Grade natural gas pipeline that was manufactured at the JSW\nSteel Mill.\nAccording to initial documentation and information provided during and after PHMSA’s meeting with\nFLNG personnel, it seemed plausible that a manufacturing procedure and specification that encompasses\nwelding and related processes in which the 42-inch steel pipe should have been fabricated in contingent\nto acceptable terms outlined and agreed on by both FLNG and JSW was not developed. As a result, the\n42-inch API 5L, X65 grade line pipe was manufactured without an approved manufacturing agreement\nof a qualified procedure as required by their written specification and the provisions outlined in API 5L\nA.1.2 specification.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nAlso, for LNG facilities, an additional penalty of not more than $50,000 for each violation may be\nimposed. 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(s) identified in this letter. Failure to do so will result in\nFreeport LNG Development, L.P. 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-\n2015-1011W. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment 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":4591}