{"operation":"document","citation":"CPF 42024043WL","title":"EAGLE LNG PARTNERS JACKSONVILLE II LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-08-26","effective_on":null,"summary":"CLOSED warning letter citing 193.2304(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024043wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024043wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024043wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024043WL","body":"Warning Letter involving EAGLE LNG PARTNERS JACKSONVILLE II LLC. PHMSA's enforcement data identifies the cited regulation as 193.2304(a). The case was opened on 2024-08-26 and is reported as closed as of 2024-08-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024043WL_Warning Letter_08262024_(22-250298).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024043WL/42024043WL_Warning%20Letter_08262024_(22-250298).pdf\n\n42024043WL_Warning Letter_08262024_(22-250298)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024043WL/42024043WL_Warning%20Letter_08262024_(22-250298)_text.pdf\n\n42024043WL_Warning Letter_08262024_(22-250298)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: seanlalani@eaglelng.com\nAugust 26, 2024\nMr. Sean Lalani\nPresident\nEagle LNG Partners\nResearch Forest Lakeside No. 4\n2445 Technology Forest Blvd, Suite 500,\nThe Woodlands, TX 77381\nCPF 4-2024-043-WL\nDear Mr. Lalani:\nFrom March 13 to 15 and from May 9 to May 10 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.) inspected your Maxville LNG Train 2 Project in Jacksonville, FL.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 193.2304 Corrosion control overview.\n(a) Subject to paragraph (b) of this section, components may not be\nconstructed, repaired, replaced, or significantly altered until a person\nqualified under § 193.2707(c) reviews the applicable design drawings\nand materials specifications from a corrosion control viewpoint and\ndetermines that the materials involved will not impair the safety or\nreliability of the component or any associated components.\nEagle LNG failed to have a person qualified under § 193.2707(c) review applicable design\ndrawings and materials specifications from a corrosion control viewpoint and determine that the\nmaterials involved will not impair the safety or reliability of the component or any associated\ncomponents before they were constructed, repaired, replaced, or significantly altered in accordance\nwith § 193.2304(a). Specifically, Eagle LNG failed to provide records indicating the review\nrequired by § 193.2304(a) was conducted.\n\n\n\nDuring the on-site inspection, the inspector reviewed the Eagle LNG Partners Maxville 2nd\nLiquefaction Train Project Process Hazard Analysis (PHA) Report, Rev 1 (Feb. 28, 2023) (PHA\n193.2304(a) corrosion control review, however, the PHA Report failed to demonstrate that the\nReport). PHMSA does not object to the use of the PHA process for the purposes of the §\nPHA Team was made up of at least one person who is deemed by the operator to be qualified under\n§ 193.2707(c).\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.\nAlso, for each violation involving LNG facilities, an additional penalty of not more than $97,179\noccurring on or after December 28, 2023 may be imposed. For each violation involving LNG\nfacilities, an additional penalty of not more than $94,128 occurring on or after January 6, 2023 and\nbefore December 28, 2023 may be imposed. For each violation involving LNG facilities, an\nadditional penalty of not more than $87,362 occurring on or after March 21, 2022 and before\nJanuary 6, 2023 may be imposed. For each violation involving LNG facilities, an additional\npenalty of not more than $82,245 occurring on or after May 3, 2021 and before March 21, 2022\nmay be imposed. For each violation involving LNG facilities, an additional penalty of not more\nthan $81,284 occurring on or after January 11, 2021 and before May 3, 2021 may be imposed. For\neach violation involving LNG facilities, an additional penalty of not more than $79,875 occurring\non or after July 31, 2019 and before January 11, 2021 may be imposed. For each violation\ninvolving LNG facilities, an additional penalty of not more than $77,910 occurring on or after\nNovember 27, 2018 and before July 31,2019 may be imposed.\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\nEagle LNG being subject to additional enforcement action.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2024-043-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).\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Tim Robertson, Director, Operations, timrobertson@eaglelng.com","truncated":false,"body_characters":6892}