{"operation":"document","citation":"CPF 42025055NOA","title":"SABINE PASS LNG, L.P. (Cheniere) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-10-16","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2605(a), 193.2605(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025055noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025055noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025055noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025055NOA","body":"Notice of Amendment involving SABINE PASS LNG, L.P. (Cheniere). PHMSA's enforcement data identifies the cited regulations as 193.2605(a),  193.2605(b). The case was opened on 2025-10-16 and is reported as closed as of 2026-02-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025055NOA_Closure Letter_02122026_(24-308459).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025055NOA/42025055NOA_Closure%20Letter_02122026_(24-308459).pdf\n\n42025055NOA_Closure Letter_02122026_(24-308459)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025055NOA/42025055NOA_Closure%20Letter_02122026_(24-308459)_text.pdf\n\n42025055NOA_Notice of Amendment_10162025_(24-308459).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025055NOA/42025055NOA_Notice%20of%20Amendment_10162025_(24-308459).pdf\n\n42025055NOA_Notice of Amendment_10162025_(24-308459)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025055NOA/42025055NOA_Notice%20of%20Amendment_10162025_(24-308459)_text.pdf\n\n42025055NOA_Operator Response to Notice and Request for Hearing and Request for Informal Meeting and Preliminary Statement of Issues_11142025_(24-308459).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025055NOA/42025055NOA_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20and%20Request%20for%20Informal%20Meeting%20and%20Preliminary%20Statement%20of%20Issues_11142025_(24-308459).pdf\n\n42025055NOA_Operator Withdrawal of Hearing Request_02122026_(24-308459).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025055NOA/42025055NOA_Operator%20Withdrawal%20of%20Hearing%20Request_02122026_(24-308459).pdf\n\n42025055NOA_Closure Letter_02122026_(24-308459)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nVIA ELECTRONIC MAIL TO: maas.hinz@cheniere.com\nFebruary 12, 2026\nMaas Hinz\nSenior Vice President Operations\nSabine Pass LNG, L.P.\n845 Texas Avenue, Suite 1250\nHouston, TX 77002\nCPF 4-2025-055-NOA\nDear Mr. Hinz:\nFrom July 9 to July 25, 2024, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, inspected Sabine\nPass LNG, L.P.’s1 (Sabine Pass LNG) procedures for atmospheric corrosion inspection, grading\nand remediation in Sabine Pass, Texas. As a result of the inspection, Sabine Pass LNG was issued\na Notice of Amendment on October 16, 2025, which proposed amendment of its procedures.\nSabine Pass LNG submitted its amended procedures on February 2, 2026. My staff has reviewed\nthe amended procedures, and it appears that the recommendations provided during the consultation\non this Notice of Amendment have been corrected.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Michael Weller, Vice President, Environmental, Regulatory Projects, and Managing\nCounsel, Cheniere Energy Inc., michael.weller@cheniere.com\nJack Holden, Director, LNG Operations, Cheniere LNG O&M Services, LLC.,\njack.holden@cheniere.com\n1 Sabine Pass LNG, L.P. is a subsidiary of Cheniere Energy, Inc.\n\n\n\nPatty Kusek, Supervisor, Operations Compliance, Sabine Pass Liquefaction, LLC,\nPatty.Kusek@cheniere.com\nLindsay Klacko, Manager, Regulatory Compliance, Cheniere Energy, Inc.,\nLindsay.klacko@cheniere.com\nMeagan Masten, Senior Counsel, Environmental, Health, and Safety, Cheniere Energy,\nInc., Meagan.Masten@cheniere.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections, FERC,\nAndrew.kohout@ferc.gov\n\n42025055NOA_Notice of Amendment_10162025_(24-308459)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: maas.hinz@cheniere.com\nOctober 16, 2025\nMaas Hinz\nSenior Vice President Operations\nSabine Pass LNG, L.P.\n845 Texas Avenue, Suite 1250\nHouston, TX 77002\nCPF 4-2025-055-NOA\nDear Mr. Hinz:\nFrom July 9 to July 25, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nSabine Pass LNG, L.P.’s1 (Sabine Pass) procedures for atmospheric corrosion inspection, grading\nand remediation in Sabine Pass, Texas.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within Sabine\nPass’s plans or procedures. The item inspected and the inadequacy is described below:\n1. §193.2605 Maintenance procedures.\n(a) Each operator shall determine and perform, consistent with\ngenerally accepted engineering practice, the periodic inspections or\ntests needed to meet the applicable requirements of this subpart and\nto verify that components meet the maintenance standards prescribed\nby this subpart.\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 procedure must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance; and\n(2) A description of other actions necessary to maintain the LNG\nplant according to the requirements of this subpart.\n1 Sabine Pass LNG, L.P. is a subsidiary of Cheniere Energy, Inc.\n\n\n\nSabine Pass’s written maintenance procedures are inadequate to ensure the safe operation of an\nLNG facility in accordance with § 193.2605(b). Specifically, Sabine Pass’s procedure External\nCorrosion Grading Guidelines, Rev. 1 (9/25/2023), is inadequate and requires revision in four\nareas.\nFirst, in Section 3.2, the procedure’s severity criteria do not reference or align with any generally\naccepted engineering practices or standards. Although the procedure references standards such as\nISO 4628-3, API RP 583, API 510, API 570, and API 653 in Section 6.2, none of these are\nincorporated by reference in § 193.2013 or § 192.7, and none include severity categorizations\nsimilar to those defined in Sabine Pass’s procedure. For instance, ISO 4628-3 categorizes rusting\ninto six levels, with four categories addressing corrosion on less than 1% of the surface area, and\nthe most severe ISO classification applying to surfaces with 40%–50% rust, whereas Sabine Pass’s\nprocedure includes examples of cases with 100% corrosion and visible cracking.\nSecond, in Sections 8.0-8.20, the photographic examples provided to illustrate severity conditions\nare inconsistent with the accompanying written descriptions and, in some instances, are overly\nvague. For example, Condition A15 includes cracking and heavy corrosion, but the corresponding\nvisual representation illustrates a condition worse than stated. Similarly, Condition A8, which\nshows a pipe wall fully covered with corrosion pits, is classified only as moderate corrosion.\nMisalignment between these visual examples and the severity categories worsens the ability of\npersonnel to correctly grade and prioritize corrosion features for repair.\nThird, the procedure assumes that all severity conditions involve total coating failure and exposed\nsteel surfaces actively undergoing corrosion, and lacks a grading category for pipelines with\ndisbonded, damaged, or otherwise failed coatings. This omission fails to account for the necessity\nof addressing coating defects, even though such issues are reported during inspections and are\ncritical for corrosion prevention.\nFourth, the procedure is inconsistent in its prioritization of repairs according to corrosion severity.\nWhile Section 3.2 categorizes conditions A13 through A20 as severe or heavy corrosion, Section\n3.3 excludes A13 and A14 from P1 priority repairs. This contradiction weakens the credibility of\nthe repair prioritization process and may delay necessary corrective actions for severe conditions.\nOverall, the procedure requires significant revision to ensure clarity, consistency, and technical\naccuracy. Therefore, PHMSA proposes that Sabine Pass revise its procedures to address the\nconcerns described above.\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.\n\n\n\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).\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 Sabine Pass 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\nrefer to CPF 4-2025-055-NOA and, for each document you submit, please provide a copy in\nelectronic format 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: Lindsay Klacko, Manager, Regulatory Compliance, Cheniere Energy, Inc.,\nLindsay.klacko@cheniere.com\nAndrew Kohout, Director, Division of LNG Facility Reviews and Inspections, FERC,\nAndrew.kohout@ferc.gov","truncated":false,"body_characters":10927}