{"operation":"document","citation":"CPF 420173004W","title":"CORPUS CHRISTI LIQUEFACTION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-10","effective_on":null,"summary":"CLOSED warning letter citing 193.2301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420173004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420173004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420173004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420173004W","body":"Warning Letter involving CORPUS CHRISTI LIQUEFACTION, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2301. The case was opened on 2017-04-10 and is reported as closed as of 2017-04-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420173004W_Operator Response to Notice_06012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420173004W/420173004W_Operator%20Response%20to%20Notice_06012017.pdf\n\n420173004W_Warning Letter_04102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420173004W/420173004W_Warning%20Letter_04102017.pdf\n\n420173004W_Warning Letter_04102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420173004W/420173004W_Warning%20Letter_04102017_text.pdf\n\n420173004W_Warning Letter_04102017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 10, 2017\nMr. Doug Shanda\nSenior Vice President, Terminal Operations\nCorpus Christi Liquefaction, LLC\n700 Milam Street\nHouston, TX 77002\nCPF 4-2017-3004W\nDear Mr. Doug Shanda:\nFrom January 3, 2017 to January 5, 2017, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nCorpus Christi Liquefaction (CCL) construction project in Corpus Christi, TX.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §193.2301 Scope.\nEach LNG facility constructed after March 31, 2000 must comply with requirements\nof this part and of NFPA-59A-2001 (incorporated by reference see §193.2013). In the\nevent of a conflict between this part and NFPA 59A, this part prevails.\nNFPA-59A-2001\n6.3.4 Welding.\n6.3.4.1 Qualification and performance of welders shall be in accordance with\nSection 328.2 of ASME B 31.3, Process Piping, and 6.3.4.2 of this standard.\nASME B 31.3 Section 328.2\n\n\n\n328.2 Welding and Brazing Qualification\nWelding and brazing procedure specifications (WPSs and BPSs) to be\nfollowed in production welding shall be prepared and qualified, and\nwelders, brazers, and operators shall be qualified as required by the ASME\nBPV Code, Section IX except as modified by para. 333 for brazing of\nCategory D Fluid Service piping and by the following subparagraphs.\nASME BPV Code, Section IX\nQW-301.2 Qualification Tests.\nEach manufacturer or contractor shall qualify each welder or\nwelding operator for each welding process to be used in production\nwelding. The performance qualification test shall be welded in\naccordance with qualified Welding Procedure Specification1\n(WPS), or Standard Welding Procedure Specifications (SWPS)\nlisted in Appendix E, except that when performance qualification is\ndone in accordance with a WPS or SWPS that requires a preheat or\npostweld heat treatment, these may be omitted.\nQW-401.3 Supplementary Essential Variable2 (Procedure).\nA change in a welding condition which will affect the notch-\ntoughness properties of a weldment (for example,\nchange in welding process, uphill or down vertical welding,\nheat input, preheat or PWHT, etc.). Supplementary essential\nvariables are in addition to the essential variables for\neach welding process.\nQW-409 Electrical Characteristics\nQW-409.1 An increase in heat input, or an increase in\nvolume of weld metal deposited per unit length of weld,\nover that qualified. The increase may be determined by\neither of the following:\n(a) Heat input [J/in. (J/mm)]\n= Voltage x Amperage x 60\nTravel Speed [in./min (mm/min)]\n1ASME BPV Code, Section IX Article QW200.1(a) defines a WPS to be a written qualified welding procedure\nprepared to provide making production welds.\n2ASME BPV Code, Section IX Article QW200.1(b) a completed WPS shall contain all of the essential, nonessential,\nand, when required, supplementary essential variables for each welding process used in the WPS.\n2\n\n\n\nCCL failed to adequately conduct welder qualifications as required by ASME BPV Code, Section\nIX, Article QW-301.2 Qualification Tests, incorporated by reference. The essential and\nsupplementary essential welding variables for gas tungsten arc welding are specified in Article\nQW-256 of ASME BPV Code, Section IX3. Heat Input is a supplementary essential variable\nspecified by the WPS and described in paragraph QW-409.1 for the Operator to ensure that the\nwelder qualification tests were welding to the WPS heat input requirements, as mentioned. This\nis accomplished using voltage, amperage, and the travel speed formula.\nIn order to confirm the welds had the correct heat input per the welding procedures, voltage and\ntravel speed must be taken during the welder testing process. On January 4, 2017, PHMSA\ninspectors observed the inadequate inspection of the voltage and travel speed and requested a copy\nof the testing records to confirm that heat input paramters were not inspected to ensure compliance.\nOn February 13, 2017, PHMSA received these records including the “Welder Qualification\nRequest” along with “Welder Performance Qualification Test Record (WR-1)” which confirmed\nthat supplementary essential variables were not inspected.\nCCL failed to adequately conduct welder qualifications as required by ASME BPV Code, Section\nIX, incorporated by reference. CCL did not ensure that the supplementary essential variable of\nheat input was followed during the welder qualification process.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty 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 penalty\nof not more than $50,000 for each violation may be imposed. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Corpus Christi Liquefaction, LLC\nbeing subject to additional enforcement action.\n3 Article QW-256 of ASME BPV Code, Section IX describes the welding variables procedure specificaitons for gas\ntungsten arc welding. Heat input is a supplementary essential variable required in the welding procedure.3\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2017-3004W. 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 the\nredacted 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\n4","truncated":false,"body_characters":7573}