{"operation":"document","citation":"CPF 420175026M","title":"CHENIERE CORPUS CHRISTI PIPELINE — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.163, 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175026m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175026m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175026m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175026M","body":"Notice of Amendment involving CHENIERE CORPUS CHRISTI PIPELINE. PHMSA's enforcement data identifies the cited regulations as 192.163,  192.303. The case was opened on 2017-06-20 and is reported as closed as of 2017-10-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175026M_Closure Letter_10272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Closure%20Letter_10272017.pdf\n\n420175026M_Closure Letter_10272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Closure%20Letter_10272017_text.pdf\n\n420175026M_Notice of Amendment_06202017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Notice%20of%20Amendment_06202017.pdf\n\n420175026M_Notice of Amendment_06202017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Notice%20of%20Amendment_06202017_text.pdf\n\n420175026M_Operator Response to Notice_07172017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175026M/420175026M_Operator%20Response%20to%20Notice_07172017.pdf\n\n420175026M_Notice of Amendment_06202017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 20, 2017\nMr. Chad Zamarin\nVice President, Pipeline\nCheniere Corpus Christi Pipeline\n700 Milam St, Suite 1900\nHouston, TX 77002\nCPF 4-2017-5026M\nDear Mr. Zamarin:\nBetween January 24 and February 24, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nCheniere’s procedures for constructing the Corpus Christi Pipeline in San Patricio County, TX.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nCheniere’s procedures, as described below:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nThe Cheniere Field Bending and Alignment of Pipe Specification document number ES-\nPPL-7712-CU-0305 (Revision 0.1, 11/15/2016) does not provide adequate requirements\nfor performing field bends of spiral seam pipe. Cheniere was found to be constructing the\nCorpus Christi Pipeline using spiral seam pipe but the specifications for bending did not\naddress this type of pipe. Cheniere’s procedure provides detailed specifications for\nbending longitudinal seam pipe but is silent on requirements for spiral seam pipe actually\nbeing used to construct the Corpus Christi Pipeline.\nSome of the specifications that should be addressed in the Cheniere’s procedure include\n\n\n\nbut no limited to: position of bending shoes, whether the bending shoes are permitted to\npress on the spiral weld-seam, the requirement for test bends, use of a mandrel, maintain\nthe minimum wall thickness requirements after bending, presentation of the cross sectional\nshape, and no buckling, cracks or mechanical damage. Cheniere must amend its procedure\nto include the written specifications for bending spiral weld-seam pipe as required in\n§192.303.\n2. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nThe Cheniere Field Bending and Alignment of Pipe Specification document number ES-\nPPL-7712-CU-0305 (Revision 0.1, 11/15/2016) does not provide adequate requirements\nfor offsetting the weld-seam for spiral weld-seam pipe. Cheniere was found to be\nconstructing the Corpus Christi Pipeline using spiral seam pipe but the specifications for\npositioning the seams, when connecting, only addressed longitudinal strait seam pipe.\nCheniere’s procedure provides detailed specifications for offsetting longitudinal strait\nseam pipe but is silent on requirements for longitudinal spiral seam pipe being used to\nconstruct the Corpus Christi Pipeline. Cheniere must amend its procedure to include\ncomprehensive specifications for offsetting the weld seams on spiral weld pipe as required\nby §192.303.\n3. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\n§192.163 Compressor stations: Design and construction.\n(b) Building construction. Each building on a compressor station site must be\nmade of noncombustible materials if it contains either—\n(1) Pipe more than 2 inches (51 millimeters) in diameter that is carrying gas\nunder pressure; or\n(2) Gas handling equipment other than gas utilization equipment used for\ndomestic purposes.\nThe Cheniere Compressor Building Specification document number ES-PPL-7718\ndoes not state that buildings, on a compressor station site, must be made of\nnoncombustible material. Cheniere must amend its procedure to require that all\nbuildings on a compressor station site are made of noncombustible material as\nrequired by §192.163.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Cheniere maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to the Terri J. Binns, Acting Director, Southwest, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2017-5026M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nJon Manning\nActing Director, Southwest\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3\n\n420175026M_Closure Letter_10272017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 27, 2017\nJim Privett\nVice President, Project Management\nCheniere Corpus Christi Pipeline\n700 Milam St, Suite 1900\nHouston, TX, 77002\nCPF 4-2017-5026M\nDear Mr. Privett:\nBetween January 24 and February 24, 2017, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Cheniere Corpus Christi Pipeline procedures in\nHouston, TX. As a result of the inspection, Cheniere Corpus Christi Pipeline was issued a Notice\nof Amendment on June 20, 2017.\nCheniere Corpus Christi Pipeline submitted its amended procedures on July 17, 2017. The\namended procedures were reviewed and found acceptable.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nTerri J. Binns\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8614}