{"operation":"document","citation":"CPF 420175024W","title":"CAMERON LNG, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-13","effective_on":null,"summary":"CLOSED warning letter citing 193.2301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175024w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175024w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175024w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175024W","body":"Warning Letter involving CAMERON LNG, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2301. The case was opened on 2017-06-13 and is reported as closed as of 2017-06-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175024W_Operator Response to Notice_06302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175024W/420175024W_Operator%20Response%20to%20Notice_06302017.pdf\n\n420175024W_Warning Letter_06132017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175024W/420175024W_Warning%20Letter_06132017.pdf\n\n420175024W_Warning Letter_06132017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175024W/420175024W_Warning%20Letter_06132017_text.pdf\n\n420175024W_Warning Letter_06132017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 13, 2017\nMr. John O’Leary\nCameron LNG, LLC\n2925 Briarpark\nSuite 1000\nHouston, TX 77042\nCPF 4-2017-5024W\nDear Mr. John O’Leary:\nFrom February 21, 2017 to February 24, 2017, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your Cameron liquefaction construction project in Hackberry, LA.\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 B31.3, Process Piping, and 6.3.4.2 of this standard.\n\n\n\nASME B31.3\n328.5 Welding Requirements\n328.5.1 General\n(a) Welds, including addition of weld metal for alignment [paras.\n328.4.2(b)(4) and 328.4.3(c)(3)], shall be made in accordance with a\nqualified procedure and by qualified welders or welding operators.\nQW-409 Electrical Characteristics\nQW-409.1 An increase in heat input, or an increase in volume of weld metal\ndeposited per unit length of weld, over that qualified.\nOn February 22, 2017, Cameron LNG’s welding inspector failed to ensure that welding was done\naccording to the qualified weld procedure, WPS ER70S-3. Specifically, the welding inspector did not\nmonitor variables such as electrical characteristics of weld FW04 including voltage and amperage for\nthe root and the hot pass. These parameters are listed in the qualified WPS, Procedure 17 (document\nnumber CAM0-CN-PR-000017). ASME B31.3 also requires that weld metal alignment shall be made\nin accordance with a qualified procedure and by qualified welders or welding operators.\nDuring the inspection, PHMSA inspectors witnessed the welding process of two field welds (FW02\nand FW04) at the Cameron LNG facility in Hackberry, LA, where the welding inspector failed to verify\nand document the visual inspection of the above mentioned production welds. As a result, on February\n24, 2017, PHMSA requested records that would validate adherence to ASME B31.3 and WPS ER70S-\n3. Specifically, PHMSA requested documents pertaining to the two welds (FW02 and FW04) and the\n“Pipe Weld Visual Inspection” report (document number 18440-CAM0-720-02-CK-60200).\nOn March 10, 2017, PHMSA received records indicating that the electrical parameters and travel speed\nvariables were not documented as having been inspected for the root and hot pass for these two welds.\nFurthermore, no electrical characteristics were recorded on the “Pipe Weld Visual Inspection” record\nfor weld FW02. The operator must complete their visual inspection for all passes of a weld and record\nthe electrical parameters on the “Pipe Weld Visual Inspection” document.\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 identified in this letter. Failure to do so will result in Cameron LNG, LLC being subject to\nadditional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2017-5024W. 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,\nJon Manning\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":5814}