# CAMERON LNG, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420193001
- **title:** CAMERON LNG, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-07-30
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2011, 193.2017(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420193001.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420193001.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420193001
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420193001
**body:**

Notice of Probable Violation involving CAMERON LNG, LLC. PHMSA's enforcement data identifies the cited regulations as 193.2011,  193.2017(a). The case was opened on 2019-07-30 and is reported as closed as of 2021-02-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420193001_Closure Letter_02192021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Closure%20Letter_02192021.pdf

420193001_Closure Letter_02192021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Closure%20Letter_02192021_text.pdf

420193001_Consent Agreement and Order_09282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Consent%20Agreement%20and%20Order_09282020.pdf

420193001_Consent Agreement and Order_09282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Consent%20Agreement%20and%20Order_09282020_text.pdf

420193001_NOPV PCP PCO_07302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_NOPV%20PCP%20PCO_07302019.pdf

420193001_NOPV PCP PCO_07302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_NOPV%20PCP%20PCO_07302019_text.pdf

420193001_Operator Hearing Request Withdrawn_11212019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Operator%20Hearing%20Request%20Withdrawn_11212019.pdf

420193001_Operator Response to Notice and Request for Hearing Redacted_08162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20Redacted_08162019.pdf

420193001_PHC Hearing Scheduled_09032019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_PHC%20Hearing%20Scheduled_09032019.pdf

420193001_PHC Hearing Scheduled_09032019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420193001/420193001_PHC%20Hearing%20Scheduled_09032019_text.pdf

420193001_Consent Agreement and Order_09282020_text.pdf

September 28, 2020
VIA ELECTRONIC MAIL TO: dcallens@cameronlng.com
Mr. Daniel Callens, Jr.
Chief Operating Officer
Cameron LNG, LLC
2925 Briarpark Drive, Suite 1000
Houston, Texas 77042
CPF No. 4-2019-3001
Dear Mr. Callens:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Cameron LNG, LLC,
which was executed on September 25, 2020. Service of the Consent Order and Consent Agreement
by electronic mail is deemed effective upon the date of transmission as provided under 49 C.F.R.
§ 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: Order and Consent Agreement
cc: Ms. Mary McDaniel, Director, Southwestern Region, OPS, PHMSA
Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS, PHMSA
Mr. Blair Woodward, General Counsel, Cameron LNG, LLC, bwoodward@cameronlng.com
Mr. Brett A. Snyder, Counsel for Cameron LNG, LLC, Blank Rome, LLP,
bsnyder@blankrome.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Cameron LNG, LLC, ) CPF No. 4-2019-3001
)
Respondent. )
____________________________________)
CONSENT AGREEMENT AND ORDER
WHEREAS, on July 30, 2019, the Director, Southwest Region (Director), Office of Pipeline
Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S. Department of
Transpo1tation, issued to Cameron LNG, LLC (CLNG or Respondent), a Notice of Probable
Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), pursuant to Chapter
60l of 49 U.S. Code, for alleged violations of 49 C.F.R. §§ 193.2011 (Item 1) and 193.2017 (Item
2). The Notice proposed assessing an administrative civil penalty of $41,600 for Item 1 and
ordering Respondent to take ce1tain measures to correct Item 2; and
WHEREAS, on August 16, 2019, CLNG submitted a written response to the Notice, in which the
Respondent contested both alleged violations, the proposed civil penalty, and the proposed
compliance order and requested a-hearing pursuant to 49 C.F.R. § 190.211. CLNG also requested
a meeting with Southwest Region, which took place on or about September 4, 2019, to discuss
resolution of this enforcement proceeding;
WHEREAS, subsequent settlement discussions occurred via email and teleconferences; and
WHEREAS, as result of these good-faith discussions, the Parties have reached agreement on the
terms and conditions of a settlement, as set forth herein, and agree that this Consent Agreement
and Order (Agreement) will avoid further administrative proceedings or litigation, that it is the
most appropriate means of resolving the issues raised in the Notice, and that it will promote the
public interest by advancing the enforcement and safety goals of PHMSA.
NOW, THEREFORE, upon consent and agreement of the Parties, it is Ordered and Adjudged as
follows:
1



CPF No. 4-2019-3001
A. General Provisions.
1. CLNG acknowledges that, for purposes of this Agreement, the CLNG facility
located in Hackberry, Louisiana, is subject to the jurisdiction of the Federal pipeline safety laws,
49 U.S.C. 60101, et seq., and the regulations and administrative orders issued thereunder.
2. CLNG further acknowledges that it received proper notice of PHMSA's action in
this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49
U .S.C. § 60101, et seq., and the regulations and orders issued thereunder.
3. CLNG agrees to the terms of this Agreement and hereby waives any further
procedural requirements with respect to its issuance. CLNG also waives all rights to contest the
validity of this Agreement, including all rights to administrative or judicial hearings or appeals.
4. For Item I of the Notice, PHMSA re-issues Item I as a Warning Item pursuant to
49 C.F.R. § 190.205 and withdraws the associated proposed administrative civil penalty. PHMSA
also agrees that Item 1 does not constitute a finding of violation and may not be considered by the
agency as a prior offense in any future enforcement action against Respondent. However, if
PHMSA finds a violation of this Paragraph 4 in a subsequent inspection or investigation, CLNG
may be subject to future enforcement action.
5. For Item 2 of the Notice, CLNG does not contest this Item or the associated
proposed compliance order, which is adopted as set forth in Section B herein.
B. Compliance Measures.
6. Within 60 days following the Effective Date of this Agreement, as specified below,
Respondent agrees that it will modify its Emergency Response Procedures to ensure that all events
required to be reported under 49 C.F.R. § 191.5 are adequately defined. The.revised procedure
must include guidance for personnel whose responsibilities include gathering appropriate
information and/or reporting on what significant events meet the definition of an incident. In
revising the procedures, CLNG must ensure that all appropriate training to the revised procedures
is completed and documented.
7. It is requested (not mandated) that CLNG maintain documentation of the safety
improvement costs associated with fulfilling this Agreement and submit the total to the Director.
PHMSA requests that these costs be reported in two categories: (I) total cost associated with the
preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
8. The Director may grant an extension of time to comply with any portion of
Paragraph 6 above upon a written request timely submitted by the Respondent and demonstrating
good cause for an extension. Upon completion of all actions required under Paragraph 6, CLNG
may request that the Director close the case.
2



CPF No. 4-2019-3001
C. Dispute Resolution
9. The Director and CLNG will informally attempt to resolve any disputes arising
under this Agreement. If Respondent and the Director are unable to informally resolve the dispute
within 10 calendar days of submittal of Respondent's invoking dispute resolution, CLNG may
request in writing, within 10 calendar days thereafter, a written determination resolving the dispute
from the Associate Administrator for Pipeline Safety by providing all information that Respondent
believes is relevant to the dispute. If the request is submitted as provided herein, the Associate
Administrator will issue a final determination in writing. The existence of a dispute and PHMSA's
consideration of the matters placed in dispute will not excuse, toll, or suspend any term or
timeframe for completion of any work to be performed under this Agreement during the pendency
of the dispute resolution process, except as agreed by the Director or the Associate Administrator
in writing.
D. Miscellaneous.
10. Nothing in this Agreement affects or relieves CLNG of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,
et seq., and the regulations and orders issued thereunder. Furthermore, nothing in this
Agreement alters PHMSA's right of access, entry, inspection, and information gathering, or its
authority to bring any enforcement action against CLNG pursuant to the Federal pipeline safety
laws, the regulations and orders issued thereunder, or any other provision of Federal or state law.
11. This Agreement does not waive or modify any Federal, state, or local laws or
regulations applicable to CLNG's pipeline system. This Agreement is not a permit or a
modification of a permit under any Federal, state, or local laws or regulations. CLNG remains
responsible for achieving and maintaining compliance with all applicable Federal, state, and local
laws, regulations and permits.
12. This Agreement constitutes the final, complete, and exclusive agreement and
understanding between the Parties with respect to this proceeding and the issues embodied in this
Agreement. The Parties acknowledge that there are no representations, agreements, or
understandings relating to the amount or collection of any civil penalties other than those expressly
contained in this Agreement.
13. This Agreement does not create rights in, or grant any cause of action to, any person
not a patty to this Agreement. PHMSA, its officers, employees, agents, and representatives are not
liable for any injuries, damages or any other cause of action arising from any acts or omissions of
CLNG or its contractors in carrying out any work required by this Agreement.
14. This Agreement shall apply to and be binding on PHMSA and CLNG, its officers,
directors, employees, successors and assigns, including, but not limited to, subsequent purchasers.
15. Respondent's obligations pursuant to this Agreement may be enforced by PHMSA
pursuant to its general enforcement authorities under 49 U.S.C. § 60101, et seq., and 49 C.F.R.
Part 190.
3



CPF No. 4-2019-3001
E. Effective Date.
16. CLNG and PHMSA
The "Effective Date" is the date on which this Agreement has been signed by both
F. Ratification.
17. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Agreement and to execute and legally bind such party
to this document.
For Cameron LNG, LLC (Respondent):
___________________________________
Daniel Callens
Chief Operating Officer
September 16, 2020
___________________________________
Date
For PHMSA:
___________________________________
Alan K. Mayberry
Associate Administrator for Pipeline Safety
September 25, 2020
___________________________________
Date
4

420193001_NOPV PCP PCO_07302019_text.pdf

CERTIFIED MAIL- RETURN RECEIPT REQUESTED
July 30, 2019
Dan Callens
Senior Vice President, Terminal Operations
Cameron LNG, LLC
2925 Briarpark, Suite 1000
Houston, Texas 77042
Dear Mr. Callens:
Our office submitted a NOPV PCP PCO Letter, CPF 4-2019-3001, DATED, July 22, 2019.
Please discard the letter that was submitted previously, and use this letter that is enclosed in the
place of it.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure



NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 22, 2019
Dan Callens
Senior Vice President, Terminal Operations
Cameron LNG, LLC
2925 Briarpark, Suite 1000
Houston, Texas 77042
CPF 4-2019-3001
Dear Mr. Callens:
On May 20, 2019, representatives of the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected your Cameron LNG facility in Hackberry, Louisiana.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
2



1. §193.2011 Reporting.
Incidents, safety-related conditions, and annual pipeline summary data for LNG
plants or facilities must be reported in accordance with the requirements of Part 191
of this subchapter.
§191.5 Immediate notice of certain incidents.
(a) At the earliest practicable moment following discovery, but no later than one hour
after confirmed discovery, each operator must give notice in accordance with
paragraph (b) of this section of each incident as defined in §191.3.
(b) Each notice required by paragraph (a) of this section must be made to the National
Response Center either by telephone to 800-424-8802 (in Washington, DC, 202 267-
2675) or electronically at http://www.nrc.uscg.mil and must include the following
information:
(1) Names of operator and person making report and their telephone numbers.
(2) The location of the incident.
(3) The time of the incident.
(4) The number of fatalities and personal injuries, if any.
(5) All other significant facts that are known by the operator that are relevant to the
cause of the incident or extent of the damages.
(c) Within 48 hours after the confirmed discovery of an incident, to the extent
practicable, an operator must revise or confirm its initial telephonic notice required
in paragraph (b) of this section with an estimate of the amount of product released,
an estimate of the number of fatalities and injuries, and all other significant facts that
are known by the operator that are relevant to the cause of the incident or extent of
the damages. If there are no changes or revisions to the initial report, the operator
must confirm the estimates in its initial report.
Cameron LNG, LLC (CLNG), failed to notify the National Response Center of two
incidents that occurred at its liquefied natural gas (LNG) facility in accordance with
§191.5, Immediate notice of certain incidents. CLNG experienced an unintentional release
of LNG during initial startup operations on January 9, 2019 and again on May 15, 2019.
The January 9, 2019, and the May 15, 2019 incidents both involved the release of LNG
from a flanged joint connection, and were not reported through the NRC.
On January 9, 2019, during commissioning activities of the BOG compressors, CLNG
Operations observed an intermittent LNG leak originating at XV-60001, BOG inlet to D-
6003 BOG Compressor Suction Drum (see CAM-60-PID-0186. A temperature variance in
the pipe consequently caused LNG to leak from the XV-60001 outlet flange.
3



On May 15, 2019, CLNG personnel observed LNG dripping near the isolation valve of
the low pressure dry flare header at the battery limits between ISBL Train 1 and OSBL in
WA-110, at the south-east corner of Train 1. At the time of the discovery, both CCJV and
CLNG did not consider the LNG release an incident or a significant event and therefore
failed to make the required NRC notification.
2. §193.2017 Plans and procedures.
(a) Each operator shall maintain at each LNG plant the plans and procedures
required for that plant by this part. The plans and procedures must be available upon
request for review and inspection by the Administrator or any State Agency that has
submitted a current certification or agreement with respect to the plant under the
pipeline safety laws (49 U.S.C. 60101 et seq.). In addition, each change to the plans
or procedures must be available at the LNG plant for review and inspection within
20 days after the change is made.
The CLNG procedure Emergency Response Plan CAM-MN-HS-001, Appendix 5 does not
provide sufficient detail for reporting incidents in accordance with §191.5. The procedure
does not outline the required events for reporting, includes unclear direction for the
reporting of incidents, and does not provide personnel with basic description of company
defined events that meet the definition of an incident.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related
series of violations. For violation occurring on or after November 2, 2015, and before November
27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum
penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the
maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to
exceed $2,000,000 for a related series of violations. Also, for each violation involving LNG
facilities, an additional penalty of not more than $77,910 occurring on or after November 27, 2018
may be imposed. For each violation involving LNG facilities occurring on or after November 2,
2018, and before November 27, 2018, an additional penalty of not more than $76,352 may be
imposed. For each violation involving LNG facilities occurring prior to November 2, 2015, an
additional penalty of not more than $75,000 may be imposed. The Compliance Officer has
reviewed the circumstances and supporting documentation involved in the above probable
violation(s) and has recommended that you be preliminarily assessed a civil penalty of $41,600 as
follows:
Item number PENALTY
1 $41,600
4



Proposed Compliance Order
With respect to items 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials
Safety Administration proposes to issue a Compliance Order to Cameron LNG, LLC. Please refer
to the Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. 552(b), along with the complete original document you must provide a second copy of the
document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, or request a
hearing under 49 CFR § 190.211. If you do not respond within 30 days of receipt of this Notice,
this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the
Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further
notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you
submit your correspondence to my office within 30 days from receipt of this Notice. This period
may be extended by written request for good cause.
In your correspondence on this matter, please refer to CPF 4-2019-3001 and, for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
5



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Cameron LNG, LLC a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Cameron LNG,
LLC with the pipeline safety regulations:
1. 2. 3. In regard to Item Number 2 of the Notice pertaining to the operator’s inadequate
procedure for reporting incidents, Cameron LNG LLC shall modify its Emergency
Response Procedures to ensure that all events required to be reported under §191.5
are adequately defined. The revised procedure must include guidance for personnel
whose responsibilities include gathering appropriate information and/or reporting
on what significant events meet the definition of an incident. In revising the
procedures, Cameron LNG LLC must ensure that all appropriate training to the
revised procedures is completed and documented.
Cameron LNG, LLC must complete and submit all documentation for the revisions
under Item 1 of this Compliance Order within 60 days of issuance of the Final
Order.
It is requested (not mandated) that Cameron LNG, LLC maintain documentation of
the safety improvement costs associated with fulfilling this Compliance Order and
submit the total to Mary McDaniel, Director, Southwest Region, Pipeline and
Hazardous Materials Safety Administration. It is requested that these costs be
reported in two categories: 1) total cost associated with preparation/revision of
plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
6

420193001_Closure Letter_02192021_text.pdf

ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
February 19, 2021
Dan Callens
Chief Operating Officer
Cameron LNG, LLC
2925 Briarpark Drive, Suite 1000
Houston, Texas 77042
CPF 4-2019-3001
Dear Mr. Callens:
On July 30, 2019, the Pipeline and Hazardous Material Safety Administration (PHMSA) issued
Cameron LNG a Notice of Probable Violation, Proposed Penalty, and Proposed Compliance Order
for alleged violations for §193.2011 and §193.2017. On September 20, 2020, PHMSA and
Cameron LNG entered into a Consent Agreement for the items included in the Notice. In the terms
of the agreement, Cameron LNG agreed to modify its Emergency Response Procedures to ensure
all events required to be reported under §191.5 were incorporated.
Cameron LNG submitted its revised Emergency Response Procedures on November 20, 2020. The
revised procedures included the reporting requirements required under §191.5. Based on our
review of the documentation provided, it has been determined that you have fundamentally
complied with the terms of the Consent Agreement and that this case is now considered closed.
Should you have questions, please do not hesitate to contact me.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Michael Wolf, Manager, Regulatory & Compliance, Cameron LNG,
mwolf@cameronlng.com

420193001_PHC Hearing Scheduled_09032019_text.pdf

September 3, 2019
VIA CERTIFIED MAIL AND EMAIL TO: dcallens@cameronlng.com and
mary.mcdaniel@dot.gov
Mr. Dan Callens
Chief Operating Officer
Cameron LNG, LLC
2925 Briarpark Drive, Suite 1000
Houston, Texas 77042
Ms. Mary McDaniel
Director, Southwest Region, PHMSA
8701 South Gessner, Suite 630
Houston, Texas 77074
Re: Notice of Hearing, Cameron LNG, LLC
CPF No. 4-2019-3001
Dear Mr. Callens and Ms. McDaniel:
In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the Office
of Pipeline Safety in the above-referenced case. The hearing has been scheduled and will take place
on December 3, 2019, beginning at 9:00 a.m. Central Time.
The hearing will be at the PHMSA Southwest Region office, 8701 South Gessner, Suite 630,
Houston, TX 77074. Upon arrival at the building, attendees will be required to present photo
identification to security personnel. A contact phone number for the day of the hearing is
(713) 272-2859.
Both parties must submit and exchange any additional written materials they intend to present at
least 10 calendar days prior to the hearing (November 23, 2019), along with a list of attendees, and
the names of any witnesses who may testify. You may provide this information electronically. If
you have any questions, please contact me at (202) 366-6139 or at kristin.baldwin@dot.gov.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Kristin Baldwin
Presiding Official
cc (email): Ms. Ahuva Battams, Counsel, Southwest Region, Office of Pipeline Safety, PHMSA
PHMSA Compliance Registry
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