# EAGLE LNG PARTNERS JACKSONVILLE II LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 42024041NOA
- **title:** EAGLE LNG PARTNERS JACKSONVILLE II LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-08-28
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 193.2441(c), 193.2605(b), 193.2637.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024041noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024041NOA
**body:**

Notice of Amendment involving EAGLE LNG PARTNERS JACKSONVILLE II LLC. PHMSA's enforcement data identifies the cited regulations as 193.2441(c),  193.2605(b),  193.2637. The case was opened on 2024-08-28 and is reported as closed as of 2024-10-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024041NOA_Closure Letter_10042024_(23-267234).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024041NOA/42024041NOA_Closure%20Letter_10042024_(23-267234).pdf

42024041NOA_Closure Letter_10042024_(23-267234)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024041NOA/42024041NOA_Closure%20Letter_10042024_(23-267234)_text.pdf

42024041NOA_Notice of Amendment_08282024_(23-267234).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024041NOA/42024041NOA_Notice%20of%20Amendment_08282024_(23-267234).pdf

42024041NOA_Notice of Amendment_08282024_(23-267234)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024041NOA/42024041NOA_Notice%20of%20Amendment_08282024_(23-267234)_text.pdf

42024041NOA_Operator Response to Notice_09282024_(23-267234).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024041NOA/42024041NOA_Operator%20Response%20to%20Notice_09282024_(23-267234).pdf

42024041NOA_Closure Letter_10042024_(23-267234)_text.pdf

VIA ELECTRONIC MAIL TO: seanlalani@eaglelng.com
October 4, 2024
Mr. Sean Lalani
President
Eagle LNG Partners
Research Forest Lakeside No. 4
2445 Technology Forest Blvd, Suite 500,
The Woodlands, TX 77381
CPF 4-2024-041-NOA
Dear Mr. Lalani:
From April 17 to 19, 2023, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-
site pipeline safety inspection of Eagle LNG Partners (Eagle LNG) procedures for its Maxville
LNG facility in Jacksonville, FL. As a result of the inspection, Eagle LNG was issued a Notice
of Amendment on August 28, 2024, which proposed amendment of your procedures.
Eagle LNG submitted its amended procedures on October 1, 2024. PHMSA reviewed the
amended 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,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Tim Robertson, Director, Operations, timrobertson@eaglelng.com

42024041NOA_Notice of Amendment_08282024_(23-267234)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: seanlalani@eaglelng.com
August 28, 2024
Mr. Sean Lalani
President
Eagle LNG Partners
Research Forest Lakeside No. 4
2445 Technology Forest Blvd, Suite 500,
The Woodlands, TX 77381
CPF 4-2024-041-NOA
Dear Mr. Lalani:
From April 17 to 19, 2023 of the on-site inspection, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected Eagle LNG’s procedures for operating and maintaining the Maxville LNG
facility in Jacksonville, FL.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within Eagle
LNG’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 193.2441 Control center.
Each LNG plant must have a control center from which operations
and warning devices are monitored as required by this part. A control
center must have the following capabilities and characteristics:
(a) . . . .
(c) Each control center must have personnel in continuous
attendance while any of the components under its control are in
operation, unless the control is being performed from another control
center which has personnel in continuous attendance.
Eagle LNG’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 193.2441(c).
Specifically, Eagle LNG’s Operational Procedures Manual, EAG-OPS-001, (Rev. 2; June 22,
2023), section 4.0, failed to explicitly require continuous attendance in the control center. Eagle
LNG must revise its procedure to require continuous attendance in the control center in accordance
with § 193.2441(c).



2. § 193.2605 Maintenance procedures.
(a) . . . .
(b) Each operator shall follow one or more manuals of written
procedures for the maintenance of each component, including any
required corrosion control. The procedures must include:
(1) The details of the inspections or tests determined under
paragraph (a) of this section and their frequency of performance; and
(2) A description of other actions necessary to maintain the LNG
plant according to the requirements of this subpart.
§ 193.2637 Remedial measures.
Prompt corrective or remedial action must be taken whenever an
operator learns by inspection or otherwise that atmospheric, external,
or internal corrosion is not controlled as required by this subpart.
Eagle LNG’s written procedures for conducting operations and maintenance activities were
inadequate to assure safe operation of a pipeline facility in accordance with § 193.2605(b).
Specifically, Eagle LNG’s Maintenance Procedures Manual, EAG-MPM-01, (Rev. 1; Apr. 15,
2023), section 22.0, failed to ensure prompt corrective or remedial action is taken whenever an
operator learns by inspection or otherwise that atmospheric, external, or internal corrosion is not
controlled as required by Part 193, Subpart G in accordance with § 193.2637 because it did not
define “prompt” with a specific time frame for the completion of corrective or remedial actions.
Eagle LNG must revise its procedure to define “prompt” with a specific time frame for the
completion of corrective or remedial actions in accordance with §§ 193.2605(b) and 193.2637.
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 Enforcement
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 Eagle LNG maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 4-2024-041-NOA and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Tim Robertson, Director, Operations, timrobertson@eaglelng.com
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