{"operation":"document","citation":"CPF 42024061NOA","title":"SOUTHERN GULF LNG COMPANY LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-11-19","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2509(b)(3), 193.2605(b)(2), 193.2637.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024061noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024061noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024061noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024061NOA","body":"Notice of Amendment involving SOUTHERN GULF LNG COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 193.2509(b)(3),  193.2605(b)(2),  193.2637. The case was opened on 2024-11-19 and is reported as closed as of 2025-03-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024061NOA_Closure Letter_03212025_(24-297302).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024061NOA/42024061NOA_Closure%20Letter_03212025_(24-297302).pdf\n\n42024061NOA_Closure Letter_03212025_(24-297302)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024061NOA/42024061NOA_Closure%20Letter_03212025_(24-297302)_text.pdf\n\n42024061NOA_Notice of Amendment_11192024_(24-297302).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024061NOA/42024061NOA_Notice%20of%20Amendment_11192024_(24-297302).pdf\n\n42024061NOA_Notice of Amendment_11192024_(24-297302)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024061NOA/42024061NOA_Notice%20of%20Amendment_11192024_(24-297302)_text.pdf\n\n42024061NOA_Operator Response to Notice_12132024_(24-297302).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024061NOA/42024061NOA_Operator%20Response%20to%20Notice_12132024_(24-297302).pdf\n\n42024061NOA_Notice of Amendment_11192024_(24-297302)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: kim dang@kindermorgan.com\nNovember 19, 2024\nKimberly Dang\nChief Executive Officer\nKinder Morgan\n1001 Louisiana St, STE 1000\nHouston, TX 77002\nCPF 4-2024-061-NOA\nDear Ms. Dang:\nFrom February 26 to 29, 2024, of the on-site inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected Southern Gulf LNG Company LLC’s (Gulf LNG) procedures for\noperating and maintaining its liquefied natural gas (LNG) facility in Pascagoula, Mississippi.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within Gulf\nLNG’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 193.2509 Emergency procedures.\n(a) . . . .\n(b) To adequately handle each type of emergency identified under\nparagraph (a) of this section and each fire emergency, each operator\nmust follow one or more manuals of written procedures. The\nprocedures must provide for the following:\n(1) . . . .\n(3) Coordinating with appropriate local officials in preparation of\nan emergency evacuation plan, which sets forth the steps required to\nprotect the public in the event of an emergency, including catastrophic\nfailure of an LNG storage tank.\nGulf LNG’s written emergency response plan was inadequate to handle each type of emergency\nin accordance with § 193.2509(b)(3). Specifically, Gulf LNG’s Emergency Response Plan, EHS-\nPLA-001, (Rev. 13; January 10, 2024) failed to include operator- and facility-specific procedures\nfor coordinating with appropriate local officials in the emergency evacuation plan that sets forth\nthe steps required to protect the public in the event of an emergency, including catastrophic failure\nof an LNG storage tank.\n\n\n\nAfter the issuance of the preliminary written findings report, Gulf LNG submitted preliminary\nrevised procedures, Emergency Response Plan, EHS-PLA-001, (Rev. 13; January 10, 2024). The\nproposed revisions corrected the inadequacy. Once the procedure is published, no further revisions\nare required.\n2. § 193.2605 Maintenance procedures.\n(a) . . . .\n(b) Each operator shall follow one or more manuals of written\nprocedures for the maintenance of each component, including any\nrequired corrosion control. The procedures must include:\n(1) . . . .\n(2) A description of other actions necessary to maintain the LNG\nplant according to the requirements of this subpart.\n§ 193.2637 Remedial measures.\nPrompt corrective or remedial action must be taken whenever an\noperator learns by inspection or otherwise that atmospheric, external,\nor internal corrosion is not controlled as required by this subpart.\nGulf LNG’s written procedures for conducting maintenance activities were inadequate to assure\nsafe operation of a pipeline facility in accordance with § 193.2605(b)(2). Specifically, Gulf LNG’s\nprocedures, Internal Corrosion Control, LNG O&M 906, (October 1, 2017) and Inspecting for\nAtmospheric Corrosion, LNG O&M 918, (November 1, 2021), failed to provide a timeframe for\n“prompt” remediation of all types of corrosion in accordance with § 193.2637.\nAfter the issuance of the preliminary written findings report, Gulf LNG submitted revised\nprocedures. Gulf LNG added a timeframe for prompt remediation in Inspecting for Atmospheric\nCorrosion, LNG O&M 918, (April 4, 2024). However, Gulf LNG failed to add a similar definition\nto Internal Corrosion Control, LNG O&M 906, (October 1, 2017).\nGulf LNG must revise its procedures to define a “prompt” timeframe for the remediation of\ninternal corrosion.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\n\n\n\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Gulf LNG maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2024-061-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Darwin Stillson, PM / FSO / Compliance / Environmental, Gulf LNG,\ndarwin_stillson@kindermorgan.com\n\n42024061NOA_Closure Letter_03212025_(24-297302)_text.pdf\n\nVIA ELECTRONIC MAIL TO: kim dang@kindermorgan.com\nMarch 21, 2025\nKimberly Dang\nChief Executive Officer\nKinder Morgan\n1001 Louisiana St, Suite 1000\nHouston, TX 77002\nRE: CPF 4-2024-061-NOA\nDear Ms. Dang:\nFrom February 26 to 29, 2024, of the on-site inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), reviewed Southern Gulf LNG Company, LLC’s (Gulf LNG) procedures for\noperating and maintaining its liquefied natural gas (LNG) facility in Pascagoula, Mississippi. As\na result of the inspection, Gulf LNG was issued a Notice of Amendment on November 19, 2024,\nwhich proposed amendment of your procedures.\nGulf LNG submitted advanced copies of the amended procedures in response to the Notice of\nAmendment on December 12, 2024, and submitted its final amended procedures on February 3,\n2025. My staff has reviewed the amended procedures, and it appears that the inadequacies outlined\nin this Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Darwin Stillson, PM / FSO / Compliance / Environmental, Gulf LNG,\ndarwin_stillson@kindermorgan.com\nZach Ragain, Director – Engineering Compliance Codes and Standards, Gulf LNG,\nzach_ragain@kindermorgan.com","truncated":false,"body_characters":9145}