{"operation":"document","citation":"CPF 42021050NOA","title":"SABINE PASS LNG, L.P. (Cheniere) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-09-24","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2503(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021050noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021050noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021050noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021050NOA","body":"Notice of Amendment involving SABINE PASS LNG, L.P. (Cheniere). PHMSA's enforcement data identifies the cited regulation as 193.2503(a). The case was opened on 2021-09-24 and is reported as closed as of 2021-11-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021050NOA_Closure Letter_11092021_(20-186120).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Closure%20Letter_11092021_(20-186120).pdf\n\n42021050NOA_Closure Letter_11092021_(20-186120)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Closure%20Letter_11092021_(20-186120)_text.pdf\n\n42021050NOA_Notice of Amendment_09242021_(20-186120).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Notice%20of%20Amendment_09242021_(20-186120).pdf\n\n42021050NOA_Notice of Amendment_09242021_(20-186120)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Notice%20of%20Amendment_09242021_(20-186120)_text.pdf\n\n42021050NOA_Operator Response to Notice_10282021_(20-186120).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Operator%20Response%20to%20Notice_10282021_(20-186120).pdf\n\n42021050NOA_Closure Letter_11092021_(20-186120)_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nNovember 9, 2021\nJack A. Fusco\nPresident and Chief Executive Officer\nSabine Pass LNG, L.P. (Cheniere)\n700 Milam Street, Suite 1900\nHouston, Texas 77002\nCPF 4-2021-050-NOA\nDear Mr. Fusco:\nFrom March 9, 2020 through March 12, 2020, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\ninspected Sabine Pass LNG, L.P’s (Cheniere) procedures and records at its terminal in Cameron,\nLouisiana. As a result of the inspection, PHMSA issued a Notice of Amendment to Cheniere dated\nSeptember 24, 2021, which required amendments to its procedures.\nCheniere submitted its amended and supplementary procedures on October 28, 2021. PHMSA\nstaff has reviewed these procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest\nPipeline and Hazardous Materials Safety Administration\nCc: Aaron Stephenson, Senior Vice President, Operations, Cheniere Energy, Inc.,\nAaron.Stephenson@cheniere.com\nMaas Hinz, Vice President and General Manager, Cheniere Energy, Inc.,\nMaas.Hinz@cheniere.com\n\n42021050NOA_Notice of Amendment_09242021_(20-186120)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nSeptember 24, 2021\nJack Fusco\nPresident and Chief Executive Officer\nSabine Pass LNG, L.P. (Cheniere)\n700 Milam Street, Suite 1900\nHouston, Texas 77002\nCPF 4-2021-050-NOA\nDear Mr. Fusco:\nFrom March 9, 2020 through March 12, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected Sabine Pass LNG, L.P’s (Cheniere) procedures and records at its terminal in\nCameron, Louisiana.\nAs a result of the inspection, it is alleged that Cheniere has committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item insepcted and\nthe probable violation is:\n1. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written procedures to provide\nsafety in normal operation and in responding to an abnormal operation that would\naffect safety. The procedures must include provisions for:\n(a) Monitoring components or buildings according to the requirements of § 193.2507.\nCheniere’s written Operation and Maintenance Procedures do not contain adequate procedures\nfor monitoring components of the LNG facility as required by § 193.2503(a). Specifically, at\nthe time of the inspection, Cheniere did not reference a company procedure that provided\nrequirements for the implementation of the supervisory lock function of the control system.\nCheneiere presented several written processes and procedures during the inspection that are\nspecific to monitoring the facility during normal and abnormal operations, including startup\nand shutdown. However, when requested, Cheniere did not produce an adequate procedure\nfor using the operation mark, a feature within the distributed control system that controls the\nimplementation of the supervisory lock or disablement.\nThe written response to PHMSA included a “how-to” explanation of the feature but failed to\nprovide the level of detail necessary to direct personnel in the appropriate use and\n\n\n\nauthorizations for such use. Cheniere must revise its procedures to include requirements for\npersonnel to implement operation marks, including the supervisory lock or disablement during\noperations.\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 Sabine Pass LNG, L.P (Cheniere) maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary McDaniel, Director,\nSouthwest, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2021-050-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Aaron Stephenson, Senior Vice President, Operations, Cheniere Energy, Inc.\nMaas Hinz, Vice President and Generation Manager Operations and Maintenance\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n2","truncated":false,"body_characters":7632}