{"operation":"document","citation":"CPF 42024039WL","title":"GOLDEN PASS LNG TERMINAL LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-08-16","effective_on":null,"summary":"CLOSED warning letter citing 193.2301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024039wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024039wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024039wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024039WL","body":"Warning Letter involving GOLDEN PASS LNG TERMINAL LLC. PHMSA's enforcement data identifies the cited regulation as 193.2301. The case was opened on 2024-08-16 and is reported as closed as of 2024-08-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024039WL_Operator Response to Notice_09162024_(20-171958).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024039WL/42024039WL_Operator%20Response%20to%20Notice_09162024_(20-171958).pdf\n\n42024039WL_Warning Letter_08162024_(20-171958).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024039WL/42024039WL_Warning%20Letter_08162024_(20-171958).pdf\n\n42024039WL_Warning Letter_08162024_(20-171958)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024039WL/42024039WL_Warning%20Letter_08162024_(20-171958)_text.pdf\n\n42024039WL_Warning Letter_08162024_(20-171958)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: jeremy.horn@goldenpasslng.com\nAugust 16, 2024\nJeremy Horn\nVice President of Operations\nGolden Pass LNG Terminal, LLC\n350 Pine Street Suite 1500\nBeaumont, Texas 77701\nCPF 4-2024-039-WL\nDear Mr. Horn:\nFrom December 7-8, 2023, and April 10-11, 2024 of the on-site inspection, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) conducted an on-site inspection of Golden Pass LNG Terminal,\nLLC’s (Golden Pass LNG) LNG export facility construction project in Sabine Pass, Port Arthur,\nTexas.\nAs a result of the inspection, it is alleged that Golden Pass LNG has committed a probable violation\nof the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item\ninspected and the probable violation is:\n1. § 193.2301 Scope.\nEach LNG facility constructed after March 31, 2000 must comply\nwith requirements of this part and of NFPA 59A (incorporated by\nreference, see § 193.2013). In the event of a conflict between this part\nand NFPA-59A-2001, this part prevails.\nGolden Pass LNG failed to construct its facility in accordance with the requirements of 49 C.F.R.\nPart 193 and NFPA-59A-2001 as required by § 193.2301. Specifically, Golden Pass LNG failed\nto install spring washers or similar devices on bolted flanges that are designed to compensate for\ncontraction and expansion during operating cycles in accordance with sections 6.1 and 6.3.1 of\n\n\n\nNFPA-59A-2001). Chapter 6 of NFPA-59A-2001 contains requirements for piping systems and\ncomponents for flammable liquids and flammable gases with service temperatures below -20ºF (-\n29ºC). Section 6.3.1. requires the use of spring washers or similar devices designed to compensate\nfor the contraction and expansion of bolted components during operating cycles.\nGolden Pass personnel stated that no washers were being used because during the design phase,\nany such bolted connection that indicated from the stress analysis and evaluations that it would\nleak was subjected to amending the size and wall thicknesses for the supports and other\ncomponents. Golden Pass LNG personnel stated this was done to ensure the connections would\nnot leak from the contraction and expansion of these connections. Records to demonstrate this\nevaluation and mitigation process was carried out and could not be provided. Therefore, Golden\nPass LNG failed to construct its facility in accordance with the requirements of 49 C.F.R. Part 193\nand NFPA-59A-2001 as required by § 193.2301.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related\nseries of violations. For violation occurring on or after January 6, 2023 and before December 28,\n2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,\nup to a maximum of $2,576,627 for a related series of violations. For violation occurring on or\nafter March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142\nper violation per day the violation persists, up to a maximum of $2,391,142 for a related series of\nviolations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the\nmaximum penalty may not exceed $225,134 per violation per day the violation persists, up to a\nmaximum of $2,251,334 for a related series of violations. For violation occurring on or after\nJanuary 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of\nviolations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the\nmaximum penalty may not exceed $218,647 per violation per day the violation persists, up to a\nmaximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679.\nWe 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\ntime. We advise you to correct the item identified in this letter. Failure to do so may result in\nGolden Pass LNG, 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\nCPF 4-2024-039-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\n\n\n\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Steven Andrews, Sr. Regulatory Advisor, steven.andrews@goldenpasslng.com","truncated":false,"body_characters":6282}