{"operation":"document","citation":"CPF 42022033NOA","title":"LAKE CHARLES LNG COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-23","effective_on":null,"summary":"CLOSED notice of amendment citing 191.5(a), 193.2011, 193.2017(a), 193.2605(b)(1), 193.2613, 193.2629(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022033noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022033noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42022033noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42022033NOA","body":"Notice of Amendment involving LAKE CHARLES LNG COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 191.5(a),  193.2011,  193.2017(a),  193.2605(b)(1),  193.2613,  193.2629(a). The case was opened on 2022-02-23 and is reported as closed as of 2022-03-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42022033NOA_Notice of Amendment_02232022_(21-200348).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022033NOA/42022033NOA_Notice%20of%20Amendment_02232022_(21-200348).pdf\n\n42022033NOA_Notice of Amendment_02232022_(21-200348)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022033NOA/42022033NOA_Notice%20of%20Amendment_02232022_(21-200348)_text.pdf\n\n42022033NOA_Notice of Amendment_02232022_(21-200348)_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nFebruary 23, 2022\nJeffrey Brightwell, P.E.\nVice President, LNG Operations\nLake Charles LNG Company, LLC\n8100 Big Lake Road\nLake Charles, Louisiana, 70605\nCPF 4-2022-033-NOA\nDear Ms. Brightwell:\nFrom June 7, 2021 through June 10, 2021, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Lake Charles LNG Company, LLC’s (LCLNG) plans and procedures for its liquefied\nnatural gas (LNG) facility located in Calcasieu Parish, Louisiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nLCLNG’s plans or procedures, as described below:\n1. § 193.2017 Plans and procedures.\n(a) Each operator shall maintain at each LNG plant the plans and procedures\nrequired for that plant by this part. The plans and procedures must be available upon\nrequest for review and inspection by the Administrator or any State Agency that has\nsubmitted a current certification or agreement with respect to the plant under the\npipeline safety laws (49 U.S.C. 60101 et seq.). In addition, each change to the plans or\nprocedures must be available at the LNG plant for review and inspection within 20\ndays after the change is made.\n§ 193.2011 Reporting.\nIncidents, safety-related conditions, and annual pipeline summary data for LNG\nplants or facilities must be reported in accordance with the requirements of Part 191\nof this subchapter.\n\n\n\n§ 191.5 Immediate notice of certain incidents.\n(a) At the earliest practicable moment following discovery, but no later than one hour\nafter confirmed discovery, each operator must give notice in accordance with\nparagraph (b) of this section of each incident as defined in § 191.3.\nLCLNG’s Energy Transfer Emergency Response Manual (Revised: 5/10/2021) is inadequate\nbecause it does not provide a definition for the term “confirmed discovery,” which is defined\nin § 191.3 as “when it can be reasonably determined, based on information available to the\noperator at the time a reportable event has occurred, even if only based on a preliminary\nevaluation.”\nOn November 8, 2021, LCLNG submitted a revised procedure to address the requirements of\n§§ 191.5 and 193.2011. PHMSA reviewed the revised procedure and found it adequate. No\nfurther action is required for this item.\n2. § 193.2605 Maintenance procedures.\n(a)…\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The\nprocedures must include:\n(1) The details of the inspections or tests determined under paragraph (a) of this\nsection and their frequency of performance;\n§ 193.2613 Auxiliary power sources.\nEach auxiliary power source must be tested monthly to check its operational\ncapability and tested annually for capacity. The capacity test must take into account\nthe power needed to start up and simultaneously operate equipment that would have\nto be served by that power source in an emergency.\nLCLNG’s Maintenance Procedures Section 117 Emergency Generator 3203-L (Revision\nDate: 11/19/2018) and Maintenance Procedures Section 122 Uninterrupted Power Supply\nSystem (Revision Date: 3/13/2019) are inadequate because they fail to include adequate details\nfor monthly operational capability checks or an annual capacity test on auxiliary power\nsources.\nDuring the inspection, PHMSA reviewed LCLNG’s procedures pertaining to monthly\noperational capability checks and annual capacity tests on auxiliary power sources. The\nprocedures did not include sufficient details for testing the required capacity of auxiliary power\nsources to start up and simultaneously operate equipment that would be served by that power\nsource in an emergency.\nOn September 10, 2021, LCLNG submitted its revised Technical Procedures Manual, Section\n13 Auxiliary Power Sources, 13.1 Emergency Generator Systems and 13.2 UPS/Battery\nBackup Power Systems (Revision: 09/10/21) to address requirements of § 193.2613. PHMSA\nreviewed the revised procedures and found them adequate. No further action is required for\nthis item.\n2\n\n\n\n3. § 193.2605 Maintenance procedures.\n(a)…\n(b) Each operator shall follow one or more manuals of written procedures for the\nmaintenance of each component, including any required corrosion control. The\nprocedures must include:\n(1) The details of the inspections or tests determined under paragraph (a) of this\nsection and their frequency of performance;\n§ 193.2629 External corrosion control: buried or submerged components.\n(a) Each buried or submerged component that is subject to external corrosive attack\nmust be protected from external corrosion by -\n(1) Material that has been designed and selected to resist the corrosive\nenvironment involved; or\n(2) The following means:\n(i) An external protective coating designed and installed to prevent corrosion\nattack and to meet the requirements of § 192.461 of this chapter; and\n(ii) A cathodic protection system designed to protect components in their\nentirety in accordance with the requirements of § 192.463 of this chapter and\nplaced in operation before October 23, 1981, or within 1 year after the\ncomponent is constructed or installed, whichever is later.\nLCLNG’s Technical Procedures Manual, Section 8 Corrosion Control Procedures, 8.8 CP\nTest Point Survey (Revision Date: 2/26/2020) is inadequate because it does not include\nadequate details to determine the level of cathodic protection in accordance with § 192.463\nand Appendix D to Part 192.\nDuring the inspection, PHMSA reviewed LCLNG’s procedures regarding corrosion control.\nThe procedures did not include a reference to -.850 V cathodic voltage using a saturated\ncopper-copper sulphate half-cell with the protective current applied. The voltage must be\nmeasured considering voltage drops other than those across the structure-electrolyte boundary\nfor valid interpretation of the voltage measurement.\nOn November 8, 2021, LCLNG submitted its revised Technical Procedures Manual, Section\n8 Corrosion Control Procedures, 8.8 CP Test Point Survey (Revision Date: 6/16/2021) to\naddress requirements of §193.2629. PHMSA reviewed the revised procedures and found them\nadequate. No further action is required for this item.\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\n3\n\n\n\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. As mentioned above, Lake Charles LNG\nCompany, LLC previously submitted revised procedures to PHMSA that reflect the amendments\nrequired by this Notice. These submitted procedures were reviewed and found to be adequate by\nPHMSA, therefore, no further action or response is required. If no additional response is received\nwithin 30 days of receipt of this Notice, this enforcement will be automatically closed.\nIt is requested (not mandated) that Lake Charles LNG Company, LLC 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 L. McDaniel, Director,\nSouthwest, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2022-033-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\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Kathie Harryman, Senior Specialist Interstate Regulatory Compliance, Energy Transfer,\nKathryn.Harryman@energytransfer.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections, FERC,\nandrew.kohout@ferc.gov\n4","truncated":false,"body_characters":9447}