# VENTURE GLOBAL CALCASIEU PASS, LLC — Notice of Probable Violation

- **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:** Not available
- **summary:** CLOSED notice of probable violation citing 191.5(a), 193.2503(b), 193.2605(b), 193.2635(a).
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- **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.

Official case documents:

42024047NOPV_Final Order_10232025_(23-267237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_Final%20Order_10232025_(23-267237).pdf

42024047NOPV_Final Order_10232025_(23-267237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_Final%20Order_10232025_(23-267237)_text.pdf

42024047NOPV_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

42024047NOPV_PCO_10222024_(23-267237).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_PCO_10222024_(23-267237).pdf

42024047NOPV_PCO_10222024_(23-267237)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024047NOPV/42024047NOPV_PCO_10222024_(23-267237)_text.pdf

42024047NOPV_Final Order_10232025_(23-267237)_text.pdf

October 23, 2025
VIA ELECTRONIC MAIL TO: bcothran@venturegloballng.com
Brian Cothran
Chief Operating Officer
Venture Global Calcasieu Pass, LLC
1001 19th Street North, Suite 1500
Arlington, Virginia 22209
Re: CPF No. 4-2024-047-NOPV
Dear Mr. Cothran:
Enclosed please find the Final Order issued in the above-referenced case. It withdraws the
allegation of violation in the Notice of Probable Violation issued on October 22, 2024.
Accordingly, this case is now closed. Service of the Final Order by e-mail is effective upon the
date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Cassie Harrison, Director, Regulatory Compliance, Venture Global,
cassie.harrison@venturegloballng.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Venture Global Calcasieu Pass, LLC, ) CPF No. 4-2024-047-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From July 24 through September 1, 2023, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Venture
Global Calcasieu Pass, LLC’s (Venture Global or Respondent) liquefied natural gas facility
located in Calcasieu Pass, Louisiana.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated October 22, 2024, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding
that Venture Global had violated 49 CFR § 193.2503 and proposed ordering Respondent to take
certain measures to correct the alleged violation. The Notice also included an additional three
warning items pursuant to 49 CFR § 190.205, which warned Respondent to correct the probable
violations or face possible future enforcement action.
Venture Global responded to the Notice by letter dated November 21, 2024 (Response). Venture
Global also provided a Supplemental Response via a letter dated May 8, 2025 after it requested
and received a copy of the case file. Venture Global contested the allegation and offered
additional information in response to the Notice. Respondent did not request a hearing and
therefore has waived its right to one.
WITHDRAWAL OF ALLEGATION
The Notice alleged that Respondent violated 49 CFR Part 193, as follows:
Item 4: The Notice alleged that Respondent violated 49 CFR § 193.2503(b), which states:



§ 193.2503 Operating procedures.
Each operator shall follow one or more manuals of written procedures
to provide safety in normal operation and in responding to an abnormal
operation that would affect safety. The procedures must include provisions
for:
(a) …
(b) Startup and shutdown, including for initial startup, performance
testing to demonstrate that components will operate satisfactory in service.
The Notice alleged that Respondent violated 49 CFR § 193.2503(b) by failing to include in its
manual of written procedures provisions for performance testing to demonstrate that components
will operate satisfactorily in service. Specifically, the Notice alleged Venture Global’s manual
was missing procedures for performance testing whenever a startup or shutdown was necessary,
such as when the facility’s components were taken out of service for repairs or maintenance.
In its Response, Venture Global contested the Notice allegation and stated that it was in
compliance with the pipeline safety regulations through its Standard Operating Procedures
(SOPs) and Pre-Startup Safety Reviews (PSSRs). Specifically, Venture Global pointed to a
section of its SOPs called Performance Testing, highlighting a requirement in the procedure that
required performance testing before putting the terminal into service from initial startup, to
demonstrate that pipeline terminal components would operate safely while in service. Venture
Global further argued that its PSSRs ensured that no components were placed into service until
they passed all tests and applicable inspections. Venture Global included the purpose statement
of its PSSR in its Response which included a requirement that no component could be placed
into service until it passed all applicable test and inspections required by section 193.23031 and
NFPA 59A-2001. The PSSR further stated that all new or modified equipment must be built,
installed, and tested in accordance with its design requirements.
Venture Global stated in its Supplemental Response that after the inspection it had instituted a
new procedure, LTS Initial/Turnaround Startup, to increase effectiveness and that this new
procedure, effective November 11, 2024, incorporated the requirements of its prior SOP that
PHMSA reviewed at the time of the inspection. Venture Global provided PHMSA a copy of this
procedure with its Supplemental Response. The stated purpose of the new procedure is to
provide instructions for safe startup from outage or turnaround and to demonstrate components
will operate satisfactorily in service within their design limits.
After considering all of the evidence and circumstances of this case, I hereby withdraw the
alleged violation 49 CFR § 193.2503(b) without prejudice, as a matter of administrative
discretion. The decision to exercise enforcement discretion in this matter is specific to the facts
of this specific enforcement matter and circumstances.
COMPLIANCE ORDER
1 49 CFR § 193.2303 states “No person may place in service any component until it passes all applicable inspections
and tests prescribed by this subpart and NFPA-59A-2001 (incorporated by reference, see § 193.2013).”



The Notice proposed a compliance order with respect to Item 4 in the Notice for the violation of
49 CFR § 193.2503(b). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of liquefied natural gas or who owns or operates a pipeline facility is required to
comply with the applicable safety standards established under chapter 601. As discussed above,
Item 4 has been withdrawn. Therefore, the compliance terms proposed in the Notice for that Item
are not included in this Order.
WARNING ITEMS
With respect to Items 1, 2, and 3, the Notice alleged probable violations of Parts 191 and 193 but
identified them as warning items pursuant to section 190.205. The warnings were for:
49 CFR § 191.5(a) (Item 1) ─ Respondent’s alleged failure to report an
unintentional gas loss of three million cubic feet or more at the earliest practicable
moment following discovery, but no later than one hour after confirmed
discovery;
49 CFR § 193.2605(b) (Item 2) ─ Respondent’s alleged failure to follow its
written procedures for cathodic protection maintenance and conduct a close
interval survey within 35 days after a cathodic protection system was installed,
energized, and properly adjusted; and
49 CFR § 193.2635(a) (Item 3) ─ Respondent’s alleged failure to test its cathodic
protection systems for three underground storage/mix 50 tanks once each calendar
year, but with intervals not exceeding 15 months to determine if the system meets
the requirements of section 192.463.
Venture Global presented information in its Response showing that it had taken certain actions to
address the cited items. Further, with regard to Item 1, Venture Global explained that the multi-
day venting operation resulting in the release, and the steps taken to calculate and verify the
quantity of the release, were complex. Venture Global contended that it met the incident
reporting obligations by timely reporting the incident upon confirmed discovery that the
reporting threshold had been exceeded. Under section 190.205, PHMSA does not adjudicate
warning items to determine whether a probable violation occurred. If OPS finds a violation of
any of these items in a subsequent inspection, Respondent may be subject to future
enforcement action.
The terms and conditions of this Final Order are effective upon service in accordance with 49
CFR § 190.5.
___________________________________ __________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety
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