CPF 42021037NOA
CPF 42021037NOA
42021037NOA_Closure Letter_05052021_(20-172618)_text.pdf, page 1Official PDFELECTRONIC MAIL - RETURN RECEIPT REQUESTED May 5, 2021 Maas Hinz Vice President and General Manager Sabine Pass LNG, L.P. 700 Milam Street, Suite 1900 Houston, Texas 77002 CPF 4-2021-037-NOA Dear Mr. Hinz: From October 26, 2020 through October 29, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Sabine Pass LNG, L.P.’s (SPLNG) plans and procedures by virtual teleconference. As a result of the inspection, SPLNG was issued a Notice of Amendment on March 29, 2021, which outlined inadequacies in its procedures. SPLNG submitted its amended procedures prior to the issuance of the Notice. PHMSA staff reviewed these procedures and determined them to be adequate; therefore, as indicated in the Notice no further correspondence was required from SPLNG. According to 49 CFR § 190.206, an operator is allowed 30 days following receipt of a notice to submit written comments, revised procedures, or a request for a hearing under § 190.211. This letter is to inform you that this case is now closed. Thank you for your cooperation. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#
42021037NOA_Notice of Amendment_03292021_(20-172618)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT ELECTRONIC MAIL - RETURN RECEIPT REQUESTED March 29, 2021 Maas Hinz Vice President and General Manager Sabine Pass LNG, L.P. 700 Milam Street, Suite 1900 Houston, Texas 77002 CPF 4-2021-037-NOA Dear Mr. Hinz: From October 26, 2020 through October 29, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Sabine Pass LNG, L.P.’s (SPLNG) plans and procedures by virtual teleconference. Based on the inspection, PHMSA has identified the apparent inadequacies found within SPLNG’s plans or procedures, as described below: 1. § 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. § 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.#
42021037NOA_Notice of Amendment_03292021_(20-172618)_text.pdf, page 2SPLNG did not have adequate procedures to address § 193.2011 for reporting requirements of Part 191 applicable to LNG plants or facilities, specifically § 191.22 National Registry of Operators (c)(1)(i), (c)(1)(iii), (c)(2)(ii), (c)(2)(iii), and (c)(2)(v). PHMSA reviewed SPLNG’s plans and procedures and discovered that SPLNG did not include all provisions applicable to LNG facilities under § 191.22. SPLNG submitted to PHMSA a revised procedure that addressed the requirements of § 193.2011 and § 191.22, respectively. SPLNG’s Operational Regulatory Periodic Reporting and Operations Review of FERC Permitting Procedure-CORP-OPS-RGCMPL-ADMPRC- 001642 (Revision Date: 11/06/2020) was reviewed by PHMSA and determined to be adequate. No further correspondence from SPLNG will be required for this item. 2. § 193.2017 Plans and procedures. (a) …. § 193.2515 Investigations of failures. (a) Each operator shall investigate the cause of each explosion, fire, or LNG spill or leak which results in: (1) Death or injury requiring hospitalization; or (2) Property damage exceeding $10,000. SPLNG did not have adequate procedures to address the requirements of § 193.2515 for investigation of failures. PHMSA reviewed SPLNG’s written plans and procedures and observed that SPLNG did not specify that they will investigate the cause of each explosion, fire, LNG spill, or leak, which results in death or injury requiring hospitalization or property damage exceeding $10,000. SPLNG submitted to PHMSA a revised procedure that addressed the requirements of § 193.2515. SPLNG’s Operations Incident Investigation Work Process-CORP-SAF- SAFGEN-ADMPRC-001531 (Revision Date: 11/30/2020) was reviewed by PHMSA and determined to be adequate. No further correspondence from SPLNG will be required for this item. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. 2#
42021037NOA_Notice of Amendment_03292021_(20-172618)_text.pdf, page 3If 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, no further action is required by Sabine Pass LNG, L.P. The procedure amendments required by this notice were submitted to PHMSA by electronic mail. The submitted procedures were reviewed and found to be adequate. It is requested (not mandated) that Sabine Pass LNG, L.P. maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, P.E., Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2021-037-NOA 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 Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Paul Nielson, Manager, Regulatory Compliance, Cheniere LNG O&M Services, LLC, paul.nielson@cheniere.com Michael J. Myers, Lead Coordinator, Compliance, Cheniere, Michael.myers2@cheniere.com 3#
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