# SABINE PASS LNG, L.P. (Cheniere) — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 193.2503(a).
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- **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.

Official case documents:

42021050NOA_Closure Letter_11092021_(20-186120).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Closure%20Letter_11092021_(20-186120).pdf

42021050NOA_Closure Letter_11092021_(20-186120)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Closure%20Letter_11092021_(20-186120)_text.pdf

42021050NOA_Notice of Amendment_09242021_(20-186120).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021050NOA/42021050NOA_Notice%20of%20Amendment_09242021_(20-186120).pdf

42021050NOA_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

42021050NOA_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

42021050NOA_Closure Letter_11092021_(20-186120)_text.pdf

ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
November 9, 2021
Jack A. Fusco
President and Chief Executive Officer
Sabine Pass LNG, L.P. (Cheniere)
700 Milam Street, Suite 1900
Houston, Texas 77002
CPF 4-2021-050-NOA
Dear Mr. Fusco:
From March 9, 2020 through March 12, 2020, representatives from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
inspected Sabine Pass LNG, L.P’s (Cheniere) procedures and records at its terminal in Cameron,
Louisiana. As a result of the inspection, PHMSA issued a Notice of Amendment to Cheniere dated
September 24, 2021, which required amendments to its procedures.
Cheniere submitted its amended and supplementary procedures on October 28, 2021. PHMSA
staff has reviewed these procedures, and it appears that the inadequacies outlined in this Notice of
Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest
Pipeline and Hazardous Materials Safety Administration
Cc: Aaron Stephenson, Senior Vice President, Operations, Cheniere Energy, Inc.,
Aaron.Stephenson@cheniere.com
Maas Hinz, Vice President and General Manager, Cheniere Energy, Inc.,
Maas.Hinz@cheniere.com

42021050NOA_Notice of Amendment_09242021_(20-186120)_text.pdf

NOTICE OF AMENDMENT
ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
September 24, 2021
Jack Fusco
President and Chief Executive Officer
Sabine Pass LNG, L.P. (Cheniere)
700 Milam Street, Suite 1900
Houston, Texas 77002
CPF 4-2021-050-NOA
Dear Mr. Fusco:
From March 9, 2020 through March 12, 2020, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected Sabine Pass LNG, L.P’s (Cheniere) procedures and records at its terminal in
Cameron, Louisiana.
As a result of the inspection, it is alleged that Cheniere has committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item insepcted and
the probable violation is:
1. § 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written procedures to provide
safety in normal operation and in responding to an abnormal operation that would
affect safety. The procedures must include provisions for:
(a) Monitoring components or buildings according to the requirements of § 193.2507.
Cheniere’s written Operation and Maintenance Procedures do not contain adequate procedures
for monitoring components of the LNG facility as required by § 193.2503(a). Specifically, at
the time of the inspection, Cheniere did not reference a company procedure that provided
requirements for the implementation of the supervisory lock function of the control system.
Cheneiere presented several written processes and procedures during the inspection that are
specific to monitoring the facility during normal and abnormal operations, including startup
and shutdown. However, when requested, Cheniere did not produce an adequate procedure
for using the operation mark, a feature within the distributed control system that controls the
implementation of the supervisory lock or disablement.
The written response to PHMSA included a “how-to” explanation of the feature but failed to
provide the level of detail necessary to direct personnel in the appropriate use and



authorizations for such use. Cheniere must revise its procedures to include requirements for
personnel to implement operation marks, including the supervisory lock or disablement during
operations.
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. 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, revised
procedures, or a request for a hearing under § 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 an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Sabine Pass LNG, L.P (Cheniere) 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 McDaniel, Director,
Southwest, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 4-2021-050-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
cc: Aaron Stephenson, Senior Vice President, Operations, Cheniere Energy, Inc.
Maas Hinz, Vice President and Generation Manager Operations and Maintenance
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
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