{"operation":"document","citation":"CPF 42020014WL","title":"GOLDEN PASS LNG TERMINAL LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-12-22","effective_on":null,"summary":"CLOSED warning letter citing 192.143(b), 192.463(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020014wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020014wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42020014wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42020014WL","body":"Warning Letter involving GOLDEN PASS LNG TERMINAL LLC. PHMSA's enforcement data identifies the cited regulations as 192.143(b),  192.463(a). The case was opened on 2020-12-22 and is reported as closed as of 2020-12-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42020014WL_Operator Response to Notice_12282020_(20-193347).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020014WL/42020014WL_Operator%20Response%20to%20Notice_12282020_(20-193347).pdf\n\n42020014WL_Warning Letter_12222020_(20-193347).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020014WL/42020014WL_Warning%20Letter_12222020_(20-193347).pdf\n\n42020014WL_Warning Letter_12222020_(20-193347)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42020014WL/42020014WL_Warning%20Letter_12222020_(20-193347)_text.pdf\n\n42020014WL_Warning Letter_12222020_(20-193347)_text.pdf\n\nWARNING LETTER\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nDecember 22, 2020\nSean Ryan\nPresident\nGolden Pass LNG Terminal LLC\n811 Louisiana, Suite 1500\nHouston, Texas 77002\nCPF 4-2020-014-WL\nDear Mr. Ryan:\nFrom July 1, 2020 through October 6, 2020, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nGolden Pass LNG Terminal LLC’s (GPLNG) construction project for a new feed gas pipeline at the\nGolden Pass LNG plant located in Sabine Pass, Texas.\nAs a result of the inspection, it is alleged that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable\nviolations are:\n1. § 192.143 - General requirements.\n(b) The design and installation of pipeline components and facilities must meet applicable\nrequirements for corrosion control found in subpart I of this part.\nGPLNG failed to design and install pipe at levee crossings #1 and #9 at the Golden Pass LNG\nplant in accordance with 49 CFR 192.143(b). Specifically, the zinc plated hardware connected to\nthe ratchet straps used to secure the pipeline to the supports during flowable fill pours was not\nelectrically isolated from the pipeline. Even though a rock shield was applied to the pipeline before\nadding the ratchet straps, electrical isolation of the hardware could not be verified.\n2. § 192.463 - External corrosion control: Cathodic protection.\n(a) Each cathodic protection system required by this subpart must provide a level of\ncathodic protection that complies with one or more of the applicable criteria\ncontained in appendix D of this part. If none of these criteria is applicable, the\ncathodic protection system must provide a level of cathodic protection at least equal\nto that provided by compliance with one or more of these criteria.\nGPLNG failed to design the pipeline at levee crossings #1 and #9 to comply with applicable criteria\ncontained in Appendix D of Part 192. GPLNG installed nylon ratchet straps to restrain the pipeline\nto support pile caps while flow-able fill was poured over the pipeline. The nylon straps that restrain\n\n\n\n2\nthe pipe may electrically shield the cathodic protection from reaching the area of the pipe that is\ncovered.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $218,647\nper violation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum\npenalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed\n$2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the\nmaximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed\n$2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the items identified in this letter. Failure to do so will result in Golden Pass LNG\nTerminal LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-\n2020-014-WL. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document, you must\nprovide a second 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).\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Steven Andrews, HSE Supervisor, Golden Pass LNG Terminal,\nsteven.l.andrews@gpterminal.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections, FERC,\nandrew.kohout@ferc.gov","truncated":false,"body_characters":5398}