{"operation":"document","citation":"CPF 42026022NOA","title":"FLORIDA CITY GAS — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-02-12","effective_on":null,"summary":"CLOSED notice of amendment citing 193.2503(c), 193.2503(g), 193.2605(a), 193.2605(b), 193.2605(b)(1), 193.2605(b)(2), 193.2605(c), 193.2713(a)(1), 193.2713(a)(2), 193.2713(b), 193.2715(a), 193.2715(b), 193.2717(a), 193.2717(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42026022noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42026022noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42026022noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42026022NOA","body":"Notice of Amendment involving FLORIDA CITY GAS. PHMSA's enforcement data identifies the cited regulations as 193.2503(c),  193.2503(g),  193.2605(a),  193.2605(b),  193.2605(b)(1),  193.2605(b)(2),  193.2605(c),  193.2713(a)(1),  193.2713(a)(2),  193.2713(b),  193.2715(a),  193.2715(b),  193.2717(a),  193.2717(b). The case was opened on 2026-02-12 and is reported as closed as of 2026-07-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42026022NOA_Closure Letter_07082026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026022NOA/42026022NOA_Closure%20Letter_07082026_(25-329815).pdf\n\n42026022NOA_Closure Letter_07082026_(25-329815)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026022NOA/42026022NOA_Closure%20Letter_07082026_(25-329815)_text.pdf\n\n42026022NOA_Notice of Amendment_02122026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026022NOA/42026022NOA_Notice%20of%20Amendment_02122026_(25-329815).pdf\n\n42026022NOA_Notice of Amendment_02122026_(25-329815)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026022NOA/42026022NOA_Notice%20of%20Amendment_02122026_(25-329815)_text.pdf\n\n42026022NOA_Operator Response to Notice_03132026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026022NOA/42026022NOA_Operator%20Response%20to%20Notice_03132026_(25-329815).pdf\n\n42026022NOA_Closure Letter_07082026_(25-329815)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n8701 S. Gessner, Suite 630\nHouston TX 77074\nVIA ELECTRONIC MAIL TO: jhouseholder@chpk.com\nJuly 8, 2026\nJeffry M. Householder\nPresident and Chief Executive Officer\nChesapeake Utilities Corporation\n500 Energy Lane\nDover, Delaware 19901\nCPF 4-2026-022-NOA\nDear Mr. Householder:\nFrom May 5 through May 8, 2025, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of Title 49, United States Code (49\nU.S.C.), conducted an on-site inspection of Florida City Gas' (FCG) procedures for its Miami-\nDade LNG facility in Homestead, Florida. As a result of the inspection, PHMSA issued FCG a\nNotice of Amendment on February 12, 2026, proposing amendments to its procedures.\nFCG submitted its amended procedures on May 12, 2026. On June 6, 2026, PHMSA requested\nthat FCG revise certain procedures submitted on May 12, 2026, because they lacked the\nspecificity identified in the Notice of Amendment. On July 6, 2026, FCG resubmitted the\nprocedures in response to PHMSA's June 6, 2026, request.\nMy staff has reviewed the revised procedures and determined that the recommendations provided\nduring the consultation regarding this Notice of Amendment have been adequately addressed.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved. Thank you for your cooperation in this matter.\nSincerely,\nR. M. Seeley\nActing Director, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n\n\ncc: Michael McCarty, Director, Operations Compliance, Chesapeake Utilities Corporation,\nmccarty@chpk.com\n2\n\n42026022NOA_Notice of Amendment_02122026_(25-329815)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: jhouseholder@chpk.com\nFebruary 12, 2026\nJeffry M. Householder\nPresident and Central Executive Officer\nChesapeake Utilities Corporation\n500 Energy Lane\nDover, Delaware 19901\nCPF 4-2026-022-NOA\nDear Mr. Householder:\nFrom May 5, 2025 to May 8, 2025 of the on-site inspection, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.) inspected Florida City Gas’ (FCG) procedures for its Miami Dade LNG\nfacility in Homestead Florida.\nAs a result of the inspection, PHMSA has identified apparent inadequacies found within FCG’s\nplans or procedures. The items inspected and the inadequacies alleged are described below:\n1. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written\nprocedures to provide safety in normal operation and in responding\nto an abnormal operation that would affect safety. The procedures\nmust include provisions for:\n(a) . . . .\n(c) Recognizing abnormal operating conditions.\nFCG’s manuals of written procedures for operations were inadequate to ensure the safe operation\nof a liquefied natural gas (LNG) facility in accordance with § 193.2503(c). Specifically, FCG’s\noperating procedures failed to include adequate provisions for recognizing abnormal operating\nconditions.\nFCG’s procedures, including Operating Manual, Miami-Dade LNG Storage Facility, B&V Project\nNo. 410546, LNG Trailer Unloading with Pressure, MD-1000-O03, (rev. 2, 4/2025), and the\nCause and Effect Diagrams, 410546-000-P3001, p. 1-4, (rev. 1, 10/27/2022), fail to provide\noperators with facility-specific instructions for recognizing abnormal operating conditions.\n\n\n\nTherefore, PHMSA proposes that FCG must revise its operating procedures to include facility-\nspecific instructions for recognizing abnormal operating conditions.\n2. § 193.2503 Operating procedures.\nEach operator shall follow one or more manuals of written\nprocedures to provide safety in normal operation and in responding\nto an abnormal operation that would affect safety. The procedures\nmust include provisions for:\n(a) . . . .\n(g) Cooldown of components according to the requirements of §\n193.2505.\nFCG’s manuals of written procedures for operations were inadequate to ensure the safe operation\nof an LNG facility in accordance with § 193.2503(g). Specifically, FCG’s cooldown procedures\nfailed to provide adequate instructions for cooling down components in accordance with the\nrequirements of § 193.2505.\nFCG’s procedures, including Tank Cooldown Procedure: Florida City Gas, HS-90000SS-50\n(01/05/2023) and Florida City Gas LNG Facility Storage Tanks - User Manual (rev. A,\n05/07/2019), fail to provide operator- and facility-specific instructions for cooldown which limit\nthe cooldown of components that are subject to cryogenic conditions to a rate and distribution\npattern that keeps thermal stresses within design limits, and fail to require that cryogenic piping\nsystems be checked for leaks in the areas of flanges, valves, and seals after cooldown stabilization\nis reached.\nTherefore, PHMSA proposes that FCG must revise its procedures to include operator and facility\nspecific instructions for the cooldown of components in accordance with the requirements of §\n193.2505.\n3. § 193.2605 Maintenance procedures.\n(a) . . . .\n(c) Each operator shall include in the manual required by\nparagraph (b) of this section instructions enabling personnel who\nperform operation and maintenance activities to recognize conditions\nthat potentially may be safety-related conditions that are subject to\nthe reporting requirements of § 191.23 of this subchapter.\nFCG’s manuals of written procedures for maintenance were inadequate to ensure the safe operation\nof an LNG facility in accordance with § 193.2605(c). Specifically, FCG’s procedures failed to\nprovide facility-specific instructions that enable personnel performing operation and maintenance\nactivities, including periodic inspections or tests, to recognize conditions that may constitute\nsafety-related conditions (SRCs) subject to the reporting requirements of § 191.23.\n2\n\n\n\nDuring the on-site inspection, FCG failed to produce maintenance procedures fulfilling the\nrequirements of § 193.2605(c). On September 25, 2025, in response to a request for information\nissued by Southwest Region in accordance with § 190.203(c), FCG stated that it would revise its\nEmergency Response Plan for the Miami-Dade LNG Storage Facility to include steps to recognize\nand report safety-related conditions.\nTherefore, PHMSA proposes that FCG must revise its maintenance procedures to provide facility\nspecific written instructions which enable personnel who perform operation and maintenance\nactivities to recognize conditions that potentially may be safety-related conditions (SRCs) that are\nsubject to the reporting requirements of § 191.23, including when those personnel are performing\nperiodic inspections or tests.\n4. § 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 procedures must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance; and\nFCG’s manuals of written procedures for maintenance were inadequate to ensure the safe operation\nof an LNG facility in accordance with § 193.2605(b)(1). Specifically, FCG’s written procedures\nfailed to ensure that maintenance activities on fire control equipment are scheduled so that a\nminimum of equipment is taken out of service at any one time and is returned to service in a\nreasonable period of time in accordance with § 193.2611(a).\nFCG’s procedure Operating Manual, Miami-Dade LNG Storage Facility, B&V Project No.\n410546 failed to require scheduling maintenance of fire control equipment that minimizes the\namount of time that the equipment is taken out of service and ensures the equipment is returned to\nservice in a reasonable amount of time.\nTherefore, PHMSA proposes that FCG must revise its procedures to provide operator and facility\nspecific written instructions, consistent with generally accepted engineering practice, specifying\nprocesses for scheduling maintenance of fire control equipment that minimizes the amount of time\nthat the equipment is taken out of service and ensures the equipment is returned to service in a\nreasonable period of time.\n3\n\n\n\n5. § 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 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.\nFCG’s manuals of written procedures for maintenance were inadequate to ensure the safe operation\nof an LNG facility in accordance with § 193.2605(b)(2). Specifically, FCG’s procedures failed to\nprovide instructions for the use of positive isolation methods beyond isolation valves to ensure the\nwork area is free of flammable fluids when a component or maintenance activity provides an\nignition source in accordance with § 193.2615(b).\nFCG’s procedure GP-05: Isolation and Purging (rev. 1, 04/2025) fails to provide for techniques\nin addition to isolation to ensure that a work area is free of flammable fluids when a component or\nmaintenance activity provides an ignition source.\nTherefore, PHMSA proposes that FCG must revise its procedures to provide operator- and facility-\nspecific written instructions consistent with generally accepted engineering practice processes\nwhich are in accordance with § 193.2615(b).\n6. § 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 procedures must include:\n(1) The details of the inspections or tests determined under\nparagraph (a) of this section and their frequency of performance; and\nFCG’s manuals of written procedures for maintenance were inadequate to ensure the safe operation\nof an LNG facility in accordance with § 193.2605(b)(1). Specifically, FCG’s written procedures\nfailed to ensure that the maintenance and inspection of its control systems is performed in\naccordance with § 193.2619.\n4\n\n\n\nFCG’s procedure Operating Manual, Miami-Dade LNG Storage Facility, B&V Project No.\n410546, Sections 8.17 through 8.21, specified the use of device manufacturer’s maintenance\nprocedures for scheduling and performing maintenance on components, including control systems.\nFCG’s procedure failed to include multiple required details of inspections or tests on control\nsystems for FCG’s facility specifically. First, FCG’s procedures failed to require control system\ncomponents which are out of service for 30 days or more be inspected and tested for operational\ncapability before returning it to service in accordance with § 193.2619(b). Second, FCG’s\nprocedures failed to identify or categorize control systems by function for the purposes of applying\nthe differing inspection and testing intervals in accordance with § 193.2619(c), § 193.2619(c)(1),\n§ 193.2619(c)(2), and § 193.2619(d) as applicable, nor do the procedures implement those\nintervals. Third, FCG’s procedures failed to require that relief valve inspection and testing include\nthe verification of the valve seat lifting pressure and reseating in accordance with § 193.2619(e).\nTherefore, PHMSA proposes that FCG must revise its procedures to ensure that the maintenance\nand inspection of its control systems is performed in accordance with § 193.2619.\n7. § 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 procedures 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.\nFCG’s manuals of written procedures for maintenance were inadequate to ensure the safe operation\nof an LNG facility in accordance with § 193.2605(b)(1) and (2). Specifically, FCG’s procedures\nfail to provide operator- and facility-specific written instructions, consistent with generally\naccepted engineering practice, which ensure that FCG’s corrosion control program is performed\nin accordance with § 193.2625, §193.2627, §193.2631, and § 193.2637.\nFCG’s Annual Atmospheric Corrosion Monitoring Procedure, MD-9200-M01 (Rev A; April 2025)\nfailed to provide adequate instructions in several areas. First, the procedure failed to provide for\nthe identification of metallic components which could have their integrity or reliability adversely\naffected by external, internal, or atmospheric corrosion during their intended service life, and failed\nto provide that such components be protected from corrosion or inspected and replaced in\naccordance with § 193.2625. Second, the procedure failed to require that components subject to\natmospheric corrosive attack be protected with corrosion-resistant material or appropriate coating\nor jacketing in accordance with §193.2627. Third, the procedure failed to require that components\nsubject to internal corrosive attack be protected with corrosion-resistant material or appropriate5\n\n\n\ncoating, inhibitor, or other means in accordance with §193.2631. Fourth, the procedure failed to\nprovide specific instructions for prompt remedial action whenever an inspection or other method\ndiscovers that atmospheric, external, or internal corrosion is not controlled, in accordance with §\n193.2637.\nTherefore, PHMSA proposes that FCG must revise its procedures to provide operator- and facility-\nspecific written instructions, consistent with generally accepted engineering practice, which ensure\nthat FCG’s corrosion control program is performed in accordance with § 193.2625, §193.2627,\n§193.2631, and § 193.2637.\n8. § 193.2713 Training: operations and maintenance.\n(a) Each operator shall provide and implement a written plan of\ninitial training to instruct—\n(1) All permanent maintenance, operating, and supervisory\npersonnel—\n(i) About the characteristics and hazards of LNG and other\nflammable fluids used or handled at the facility, including, with\nregard to LNG, low temperatures, flammability of mixtures with air,\nodorless vapor, boiloff characteristics, and reaction to water and\nwater spray;\n(ii) About the potential hazards involved in operating and\nmaintenance activities; and\n(iii) To carry out aspects of the operating and maintenance\nprocedures under §§ 193.2503 and 193.2605 that relate to their\nassigned functions; and\n(2) All personnel—\n(i) To carry out the emergency procedures under § 193.2509 that\nrelate to their assigned functions; and\n(ii) To give first-aid; and\n(3) . . . .\n(b) A written plan of continuing instruction must be conducted at\nintervals of not more than two years to keep all personnel current on\nthe knowledge and skills they gained in the program of initial\ninstruction.\n§ 193.2715 Training: security.\n(a) Personnel responsible for security at an LNG plant must be\ntrained in accordance with a written plan of initial instruction to:\n(1) . . . .\n(b) A written plan of continuing instruction must be conducted at\nintervals of not more than two years to keep all personnel having\nsecurity duties current on the knowledge and skills they gained in the\nprogram of initial instruction.\n6\n\n\n\n§ 193.2717 Training: fire protection.\n(a) All personnel involved in maintenance and operations of an\nLNG plant, including their immediate supervisors, must be trained\naccording to a written plan of initial instruction, including plant fire\ndrills, to:\n(1) . . . .\n(b) A written plan of continuing instruction, including plant fire\ndrills, must be conducted at intervals of not more than two years to\nkeep personnel current on the knowledge and skills they gained in the\ninstruction under paragraph (a) of the section.\nFCG’s manuals of written procedures for training were inadequate to ensure the safe operation of\nan LNG facility in accordance with § 193.2713, § 193.2715, and § 193.2717(a) and (b).\nSpecifically, FCG’s training procedures failed to provide specific instructions for the\nimplementation of a training program in accordance with the applicable requirements of §\n193.2707, § 193.2709, § 193.2711, § 193.2713, § 193.2715, and § 193.2717.\nRegarding Section 1, General Orientation, the training modules including S1M1 Introduction,\nS1M2 LNG Fundamentals, S1M3 Codes and Standards, S1M4 Safety Basics, S1M5 LNG Hazards,\nand S1M6 Safety Equipment and Procedures, failed to include all topics required by §\n193.2713(a)(1)(i), such as LNG vapor flammability limits, LNG boil off characteristics, odorless\nvapor, and LNG reaction to water and water spray. In addition, S1M3 Codes and Standards\nconsisted primarily of paraphrased recitations of incorporated-by-reference industry standards\nwithout further explanation or instruction. As such, it does not provide sufficient operator- or\nfacility-specific instruction or training to meaningfully train facility personnel.\nRegarding Section 2, Site Safety, FCG was unable to locate for PHMSA’s review any of the\ntraining modules identified in S1M1 Introduction as belonging to this section, either on-site or\notherwise. The topics assigned to Section 2 Site Safety include: Scope Safety; Hazards & Physical\nProperties; Lock and Tag Procedure; Work Permit System; Fire Watch Requirements;\nEnvironmental; LNG Physical Health Plan; Protective Clothing (PPE); Cool Down Program; Plant\nEmergency Plan; Codes, Standards, and Regulations; Reporting Unsafe Conditions; Abnormal\nOperating Conditions; First Aid; Confined Space Entry; Logbook Entry; General Policies; and Fall\nProtection & Ladder Usage. Without these materials, FCG’s training program fails to ensure the\nsafe operation of an LNG facility in accordance with § 193.2711, § 193.2713(a)(1)(ii),\n193.2713(a)(2)(i), and § 193.2713(a)(2)(ii).\nRegarding Section 3, Operations, and Section 4, Maintenance, many training modules lacked any\nform of written or practical assessment that could constitute a proficiency test relevant to the\nassigned material. Without meaningful proficiency testing, FCG’s procedures are unable to ensure\nthe safe operation of an LNG facility in accordance with § 193.2707(a)(3). The modules lacking\nassessments include: S3M4 Truck Station System (rev. 0), S3M5 LNG Sendout Pump (rev. 0),\nS3M6 Vaporization System (rev. 0), S3M7 Instrument Air/Gas System (rev. 0), S3M8 Nitrogen\nSystem (rev. 0), S3M9 Fuel Gas System (rev. 0), S4M2 Maintenance Procedures (rev. 0), S4M3\nIsolating and Purging (rev. 0), S4M4 Foreign Material (rev. 0), S4M5 Corrosion Protection (rev.7\n\n\n\n0), S4M6 Relief Valves Program (rev. 0), S4M7 Maintenance Records (rev. 0), and S4M8 Control\nSystems (rev. 0).\nRegarding Section 5, Emergency Procedures, FCG’s training modules failed to require ongoing\ntraining on a biennial basis in accordance with 193.2717(b). In addition, the training materials\nfailed to provide for plant fire drills that give personnel hands-on experience in carrying out their\nemergency duties in accordance with § 193.2717(c). FCG was also unable to locate two modules:\nS5M4 Responding to an Emergency and S5M5 Recognizing an Emergency. Without the emergency\nresponse training contained in the modules, FCG’s procedures are unable to ensure the safe\noperation of an LNG facility in accordance with § 193.2713(a)(2)(i).\nRegarding Section 6, Fire Protection, and Section 8, Operations: Emergency and Fire Equipment,\nmany training modules lacked any form of written or practical assessment that could constitute a\nproficiency test relevant to the assigned material. Without meaningful proficiency testing, FCG’s\nprocedures are unable to ensure the safe operation of an LNG facility in accordance with §\n193.2707(a)(3). The modules lacking assessments include S6M2 Fire Prevention Duties (rev. 0)\nand S6M3 Plant Fire and Leak Survey (rev. 0).\nRegarding the training module in Section 7, Security, S7M1 Security Procedures (rev. 0), FCG’s\nprocedure primarily refers to and relies upon corporate security policies from FCG’s previous\ncorporate owner. FCG was unable to locate these referenced policies. Without such security\ntraining, FCG’s procedures are unable to ensure the safe operation of an LNG facility in\naccordance with § 193.2715.\nBased on the foregoing, PHMSA proposes that FCG revise its training procedures to provide\nspecific instructions for the implementation of a training program in accordance with the\napplicable requirements of § 193.2707, § 193.2709, § 193.2711, § 193.2713, § 193.2715, and §\n193.2717.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof 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).\n8\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 CFR § 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 FCG maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-\n2026-022-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever 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: Michael McCarty, Director, Operations Compliance, mmccarty@chpk.com\n9","truncated":false,"body_characters":26079}