{"operation":"document","citation":"CPF 42024047NOPV","title":"VENTURE GLOBAL CALCASIEU PASS, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-10-22","effective_on":null,"summary":"CLOSED notice of probable violation citing 191.5(a), 193.2503(b), 193.2605(b), 193.2635(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024047nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024047nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024047nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024047NOPV","body":"Notice of Probable Violation involving VENTURE GLOBAL CALCASIEU PASS, LLC. PHMSA's enforcement data identifies the cited regulations as 191.5(a),  193.2503(b),  193.2605(b),  193.2635(a). The case was opened on 2024-10-22 and is reported as closed as of 2025-10-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024047NOPV_Final Order_10232025_(23-267237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_Final%20Order_10232025_(23-267237).pdf\n\n42024047NOPV_Final Order_10232025_(23-267237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_Final%20Order_10232025_(23-267237)_text.pdf\n\n42024047NOPV_Operator Response to Notice_11212024_(23-267237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_Operator%20Response%20to%20Notice_11212024_(23-267237).pdf\n\n42024047NOPV_PCO_10222024_(23-267237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_PCO_10222024_(23-267237).pdf\n\n42024047NOPV_PCO_10222024_(23-267237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_PCO_10222024_(23-267237)_text.pdf\n\n42024047NOPV_Final Order_10232025_(23-267237)_text.pdf\n\nOctober 23, 2025\nVIA ELECTRONIC MAIL TO: bcothran@venturegloballng.com\nBrian Cothran\nChief Operating Officer\nVenture Global Calcasieu Pass, LLC\n1001 19th Street North, Suite 1500\nArlington, Virginia 22209\nRe: CPF No. 4-2024-047-NOPV\nDear Mr. Cothran:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws the\nallegation of violation in the Notice of Probable Violation issued on October 22, 2024.\nAccordingly, this case is now closed. Service of the Final Order by e-mail is effective upon the\ndate of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA\nCassie Harrison, Director, Regulatory Compliance, Venture Global,\ncassie.harrison@venturegloballng.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nVenture Global Calcasieu Pass, LLC, ) CPF No. 4-2024-047-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom July 24 through September 1, 2023, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Venture\nGlobal Calcasieu Pass, LLC’s (Venture Global or Respondent) liquefied natural gas facility\nlocated in Calcasieu Pass, Louisiana.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated October 22, 2024, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding\nthat Venture Global had violated 49 CFR § 193.2503 and proposed ordering Respondent to take\ncertain measures to correct the alleged violation. The Notice also included an additional three\nwarning items pursuant to 49 CFR § 190.205, which warned Respondent to correct the probable\nviolations or face possible future enforcement action.\nVenture Global responded to the Notice by letter dated November 21, 2024 (Response). Venture\nGlobal also provided a Supplemental Response via a letter dated May 8, 2025 after it requested\nand received a copy of the case file. Venture Global contested the allegation and offered\nadditional information in response to the Notice. Respondent did not request a hearing and\ntherefore has waived its right to one.\nWITHDRAWAL OF ALLEGATION\nThe Notice alleged that Respondent violated 49 CFR Part 193, as follows:\nItem 4: The Notice alleged that Respondent violated 49 CFR § 193.2503(b), which states:\n\n\n\n§ 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written procedures\nto provide safety in normal operation and in responding to an abnormal\noperation that would affect safety. The procedures must include provisions\nfor:\n(a) …\n(b) Startup and shutdown, including for initial startup, performance\ntesting to demonstrate that components will operate satisfactory in service.\nThe Notice alleged that Respondent violated 49 CFR § 193.2503(b) by failing to include in its\nmanual of written procedures provisions for performance testing to demonstrate that components\nwill operate satisfactorily in service. Specifically, the Notice alleged Venture Global’s manual\nwas missing procedures for performance testing whenever a startup or shutdown was necessary,\nsuch as when the facility’s components were taken out of service for repairs or maintenance.\nIn its Response, Venture Global contested the Notice allegation and stated that it was in\ncompliance with the pipeline safety regulations through its Standard Operating Procedures\n(SOPs) and Pre-Startup Safety Reviews (PSSRs). Specifically, Venture Global pointed to a\nsection of its SOPs called Performance Testing, highlighting a requirement in the procedure that\nrequired performance testing before putting the terminal into service from initial startup, to\ndemonstrate that pipeline terminal components would operate safely while in service. Venture\nGlobal further argued that its PSSRs ensured that no components were placed into service until\nthey passed all tests and applicable inspections. Venture Global included the purpose statement\nof its PSSR in its Response which included a requirement that no component could be placed\ninto service until it passed all applicable test and inspections required by section 193.23031 and\nNFPA 59A-2001. The PSSR further stated that all new or modified equipment must be built,\ninstalled, and tested in accordance with its design requirements.\nVenture Global stated in its Supplemental Response that after the inspection it had instituted a\nnew procedure, LTS Initial/Turnaround Startup, to increase effectiveness and that this new\nprocedure, effective November 11, 2024, incorporated the requirements of its prior SOP that\nPHMSA reviewed at the time of the inspection. Venture Global provided PHMSA a copy of this\nprocedure with its Supplemental Response. The stated purpose of the new procedure is to\nprovide instructions for safe startup from outage or turnaround and to demonstrate components\nwill operate satisfactorily in service within their design limits.\nAfter considering all of the evidence and circumstances of this case, I hereby withdraw the\nalleged violation 49 CFR § 193.2503(b) without prejudice, as a matter of administrative\ndiscretion. The decision to exercise enforcement discretion in this matter is specific to the facts\nof this specific enforcement matter and circumstances.\nCOMPLIANCE ORDER\n1 49 CFR § 193.2303 states “No person may place in service any component until it passes all applicable inspections\nand tests prescribed by this subpart and NFPA-59A-2001 (incorporated by reference, see § 193.2013).”\n\n\n\nThe Notice proposed a compliance order with respect to Item 4 in the Notice for the violation of\n49 CFR § 193.2503(b). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of liquefied natural gas or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. As discussed above,\nItem 4 has been withdrawn. Therefore, the compliance terms proposed in the Notice for that Item\nare not included in this Order.\nWARNING ITEMS\nWith respect to Items 1, 2, and 3, the Notice alleged probable violations of Parts 191 and 193 but\nidentified them as warning items pursuant to section 190.205. The warnings were for:\n49 CFR § 191.5(a) (Item 1) ─ Respondent’s alleged failure to report an\nunintentional gas loss of three million cubic feet or more at the earliest practicable\nmoment following discovery, but no later than one hour after confirmed\ndiscovery;\n49 CFR § 193.2605(b) (Item 2) ─ Respondent’s alleged failure to follow its\nwritten procedures for cathodic protection maintenance and conduct a close\ninterval survey within 35 days after a cathodic protection system was installed,\nenergized, and properly adjusted; and\n49 CFR § 193.2635(a) (Item 3) ─ Respondent’s alleged failure to test its cathodic\nprotection systems for three underground storage/mix 50 tanks once each calendar\nyear, but with intervals not exceeding 15 months to determine if the system meets\nthe requirements of section 192.463.\nVenture Global presented information in its Response showing that it had taken certain actions to\naddress the cited items. Further, with regard to Item 1, Venture Global explained that the multi-\nday venting operation resulting in the release, and the steps taken to calculate and verify the\nquantity of the release, were complex. Venture Global contended that it met the incident\nreporting obligations by timely reporting the incident upon confirmed discovery that the\nreporting threshold had been exceeded. Under section 190.205, PHMSA does not adjudicate\nwarning items to determine whether a probable violation occurred. If OPS finds a violation of\nany of these items in a subsequent inspection, Respondent may be subject to future\nenforcement action.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nCFR § 190.5.\n___________________________________ __________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":9852}