{"operation":"document","citation":"CPF 420183004M","title":"LAKE CHARLES LNG COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-06-11","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2505(b), 193.2605(b)(1), 193.2619(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420183004m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420183004m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420183004m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420183004M","body":"Notice of Amendment involving LAKE CHARLES LNG COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 193.2505(b),  193.2605(b)(1),  193.2619(b). The case was opened on 2018-06-11 and is reported as closed as of 2018-06-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420183004M_Notice of Amendment_06112018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183004M/420183004M_Notice%20of%20Amendment_06112018.pdf\n\n420183004M_Notice of Amendment_06112018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183004M/420183004M_Notice%20of%20Amendment_06112018_text.pdf\n\n420183004M_Operator Response to Notice_06282018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183004M/420183004M_Operator%20Response%20to%20Notice_06282018.pdf\n\n420183004M_Notice of Amendment_06112018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 11, 2018\nJeffrey Brightwell, P.E.\nVice President, LNG Operations\nLake Charles LNG Company, LLC\n8100 Big Lake Road\nLake Charles, Louisiana 70605-0300\nCPF 4-2018-3004M\nDear Mr. Brightwell:\nFrom January 23 through January 27, 2018, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Lake Charles LNG Company (LCLNG) procedures for maintenance and operations in\nLake Charles, LA.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nLCLNG’s plans or procedures, as described below:\n1. § 193.2505 Cooldown.\n(b) After cooldown stabilization is reached, cryogenic piping systems must be checked for\nleaks in areas of flanges, valves, and seals.\nThe LCLNG Standard Operating Procedures (SOP), Volume III-Section J, Cooldown of\nComponents was inadequate because it did not reflect the requirements of performing a leak survey\nin area of flanges, valves, and seals before, during and after cooldown stabilization for each\ncryogenic piping system.\n\n\n\nDuring the inspection, PHMSA identified this issue and noted it missing from LCLNG’s\nprocedures. On March 26, 2018, LCLNG submitted the revised procedure (Standard Operating\nProcedures, Volume III- Section J- Cooldown of Components) to PHMSA reflecting compliance\nwith § 193.2505 (a)(b).\nPHMSA reviewed the revised procedure and found the revisions acceptable.\n2. §193.2605 Maintenance procedures\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component , including any required corrosion control. The\nprocedure must include:\n(1) The details of the inspections or tests determined under paragraph (a) of this\nsection and their frequency of performance; and\nThe LCLNG Technical Procedures Manual, Section 8.4 Internal Corrosion Control: Corrosion\nCoupons was inadequate and did not reflect the detail criteria of the inspections or tests of the\ninternal corrosion monitoring devices under §193.2605 (b)(1).\nDuring the inspection, PHMSA reviewed several corrosion coupons results. The results show the\nweight loss of the coupons such as 0.50 mils/year, 0.42mils/year, etc., but the procedure does not\nmention any threshold limit of the weight loss that could lead to further investigation and/or\ncorrective action. PHMSA addressed the lack procedure detail to LCLNG. On March 26, 2018,\nLCLNG submitted the revised procedure (Technical Procedures Manual, Section 8, Corrosion\nControl Procedures) to PHMSA reflecting the action level criteria for corrective action and further\nevaluation when two consecutive corrosion rates exceed 2.5 mils per year.\nPHMSA reviewed the revised procedure and found the revisions acceptable.\n3. §193.2619 Control systems\n(b) If a control system is out of service for 30 days or more, it must be inspected and tested\nfor operational capability before returning it to service.\nThe LCLNG Maintenance Procedures Manual, Section 69.0, Instrumentation was inadequate and\ndid not reflect the requirements of inspection and testing of the control system if the control system\nis out of service for 30 days or more.\nDuring the inspection, PHMSA identified this issue and noted it missing from the LCLNG\nprocedure. On March 26, 2018, LCLNG submitted the revised procedure (Maintenance Procedures\nManual, Section 69.0 Instrumentation) to PHMSA reflecting compliance with §193.2619(b).\nPHMSA reviewed the revised procedure and found the revisions acceptable.\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 LCLNG maintains documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Mary L. McDaniel P.E., Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2018-3004M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nIn regard to Items 1, 2 and 3 listed above, LCLNG updated their manual and submitted verification\nvia email to PHMSA on March 26, 2018. After considering the material provided the\nmodifications appear to be adequate.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":7187}