{"operation":"document","citation":"CPF 420183006W","title":"CORPUS CHRISTI LIQUEFACTION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-12-14","effective_on":null,"summary":"CLOSED warning letter citing 193.2017(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420183006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420183006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420183006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420183006W","body":"Warning Letter involving CORPUS CHRISTI LIQUEFACTION, LLC. PHMSA's enforcement data identifies the cited regulation as 193.2017(a). The case was opened on 2018-12-14 and is reported as closed as of 2018-12-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420183006W_Warning Letter_12142018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183006W/420183006W_Warning%20Letter_12142018.pdf\n\n420183006W_Warning Letter_12142018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420183006W/420183006W_Warning%20Letter_12142018_text.pdf\n\n420183006W_Warning Letter_12142018_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 14, 2018\nDoug Shanda\nSenior Vice President, Terminal Operations\nCorpus Christi Liquefaction, LLC\n700 Milam Street\nHouston, Texas 77002\nCPF 4-2018-3006W\nDear Mr. Shanda:\nOn July 17-20, 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nyour LNG Liquefaction Facility in Corpus Christi, Texas.\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 (CFR). The item inspected\nand the probable violations is:\n1. §193.2017 Plans and procedures\n(a) Each operator shall maintain at each LNG plant the plans and procedures\nrequired for that plant by this part. The plans and procedures must be available upon\nrequest for review and inspection by the Administrator or any State Agency that has\nsubmitted a current certification or agreement with respect to the plant under the\npipeline safety laws (49 U.S.C. 60101 et seq.). In addition, each change to the plans\nor procedures must be available at the LNG plant for review and inspection within\n20 days after the change is made.\n\n\n\nCorpus Christi Liquefaction, LLC failed to develop plans and procedures for the inspection\nof portable fire extinguishers. During the inspection, PHMSA requested to review the\nprocedure for the inspection of portable fire extinguishers. The Operator stated that they\ndid not have a procedure at the time of the inspection.\nOn August 21, 2017, an email was received from the Operator with a Fire Extinguisher\nInspection Procedure Document Number GPP-GHX-00013 Revision 000 dated August 18,\n2017 attached. The procedure was reviewed by the PHMSA inspectors and was found\nacceptable.\nFailure to have a procedure resulted in portable fire extinguishers missing inspection tags,\nas well as tags indicating either no inspection had been done, or not done at the required\nfrequency per NFPA-10-1998.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. Also, for LNG facilities, an additional penalty of not more than\n$76,352 for each violation may be imposed. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified in\nthis letter. Failure to do so will result in Corpus Christi Liquefaction, LLC being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2018-3006W. 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,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n2","truncated":false,"body_characters":4377}