# FLORIDA CITY GAS — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 42026023NOPV
- **title:** FLORIDA CITY GAS — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2026-02-12
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 193.2625(b), 193.2627.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42026023nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42026023nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42026023nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42026023NOPV
**body:**

Notice of Probable Violation involving FLORIDA CITY GAS. PHMSA's enforcement data identifies the cited regulations as 193.2625(b),  193.2627. The case was opened on 2026-02-12 and is reported as closed as of 2026-07-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42026023NOPV_Closure Letter_07092026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_Closure%20Letter_07092026_(25-329815).pdf

42026023NOPV_Closure Letter_07092026_(25-329815)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_Closure%20Letter_07092026_(25-329815)_text.pdf

42026023NOPV_Final Order_03262026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_Final%20Order_03262026_(25-329815).pdf

42026023NOPV_Final Order_03262026_(25-329815)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_Final%20Order_03262026_(25-329815)_text.pdf

42026023NOPV_Operator Response to Notice_03132026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_Operator%20Response%20to%20Notice_03132026_(25-329815).pdf

42026023NOPV_PCO_02122026_(25-329815).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_PCO_02122026_(25-329815).pdf

42026023NOPV_PCO_02122026_(25-329815)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42026023NOPV/42026023NOPV_PCO_02122026_(25-329815)_text.pdf

42026023NOPV_Final Order_03262026_(25-329815)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
March 26, 2026
VIA EMAIL TO: jhouseholder@chpk.com
Jeffrey M. Householder
President and Chief Executive Officer
Chesapeake Utilities Corporation
500 Energy Lane
Dover, Delaware 19901
Re: CPF No. 4-2026-023-NOPV
Dear Mr. Householder:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and specifies actions that need to be taken to comply with the pipeline safety
regulations. When the terms of the compliance order are completed, as determined by the
Director, Southwest Region, this enforcement action will be closed. Service of the Final Order
by e-mail is effective upon the date of transmission and acknowledgement of receipt as provided
under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mike McCarty, Manager, Operations Compliance, Florida Public Utilities/Florida City
Gas, mmccarty@chpk.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 )
Florida City Gas, ) CPF No. 4-2026-023-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
On February 12, 2026, pursuant to 49 CFR § 190.207, the Director, Southwest Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation and Proposed Compliance Order
(Notice) to Florida City Gas (Respondent), a subsidiary of Chesapeake Utilities Corporation.
The Notice proposed finding that Respondent violated the pipeline safety regulations in 49 CFR
Part 193. The Notice also proposed certain measures to correct the violation. Respondent did not
contest the allegation of violation or corrective measures.
Based upon a review of all of the evidence, pursuant to section 190.213, I find Respondent
violated the pipeline safety regulation listed below, as more fully described in the enclosed
Notice, which is incorporated by reference:
49 CFR § 193.2625(b)(1) (Item 1) ─ Respondent failed to protect from corrosion
components whose integrity or reliability could be adversely affected by
corrosion.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
Compliance Actions
Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the
actions proposed in the enclosed Notice to correct the violation. The Director may grant an
extension of time to comply with any of the required items upon a written request timely
submitted by the Respondent and demonstrating good cause for an extension. Upon completion
of the ordered actions, Respondent may request that the Director close the case. Failure to
comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223
or in referral to the Attorney General for appropriate relief in a district court of the United States.



2
The terms and conditions of this order are effective upon service in accordance with 49 CFR
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: jhouseholder@chpk.com
February 12, 2026
Jeffry M. Householder
President and Central Executive Officer
Chesapeake Utilities Corporation
500 Energy Lane
Dover, Delaware 19901
CPF 4-2026-023-NOPV
Dear Mr. Householder:
From May 5 to May 8, 2025, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United
States Code (U.S.C.) inspected Florida City Gas’s (FCG) Miami Dade LNG Facility in Homestead,
Florida.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. § 193.2625 Corrosion protection.
(a) . . . .
(b) Components whose integrity or reliability could be adversely
affected by corrosion must be either -
(1) Protected from corrosion in accordance with § 193.2627
through § 193.2635, as applicable; or
(2) Inspected and replaced under a program of scheduled
maintenance in accordance with procedures established under
§ 193.2605.



§ 193.2627 Atmospheric corrosion control.
Each exposed component that is subject to atmospheric corrosive
attack must be protected from atmospheric corrosion by—
(a) Material that has been designed and selected to resist the
corrosive atmosphere involved; or
(b) Suitable coating or jacketing.
FCG failed to protect from corrosion components whose integrity or reliability could be adversely
affected by corrosion in accordance with § 193.2625(b)(1). Specifically, FCG failed to protect the
water glycol piping system at its Miami Dade LNG facility from atmospheric corrosive attack with
suitable coating or jacketing. During the inspection, PHMSA personnel using viewing ports
observed multiple instances of corrosion underneath the insulation on the water glycol system
piping.
The extent and severity of the corrosion observed indicate an aggressive corrosion mechanism
because the degradation present is very unlikely to have developed within the approximately two-
year period between the commissioning of the Miami Dade LNG facility in April 2023 and the on-
site inspection in May 2025 had the system been adequately protected from atmospheric corrosive
attack through appropriate coating or jacketing.
Therefore, FCG failed to protect from corrosion components whose integrity or reliability could
be adversely affected by corrosion in accordance with § 193.2625(b)(1).
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related
series of violations. For violation occurring on or after December 28, 2023 and before December
30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation
persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring
on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed
$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related
series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023,
the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to
a maximum of $2,391,412 for a related series of violations. For violation occurring on or after
May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per
violation per day the violation persists, up to a maximum of $2,251,334 for a related series of
violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the
maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a
maximum of $2,225,034 for a related series of violations. For violation occurring on or after July
31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations.
2



Also, for each violation involving LNG facilities, an additional penalty of not more than $99,704
occurring on or after December 30, 2024 may be imposed. For each violation involving LNG
facilities, an additional penalty of not more than $97,179 occurring on or after December 28, 2023
and before December 30, 2024 may be imposed. For each violation involving LNG facilities, an
additional penalty of not more than $94,128 occurring on or after January 6, 2023 and before
December 28, 2023 may be imposed. For each violation involving LNG facilities, an additional
penalty of not more than $87,362 occurring on or after March 21, 2022 and before January 6, 2023
may be imposed. For each violation involving LNG facilities, an additional penalty of not more
than $82,245 occurring on or after May 3, 2021 and before March 21, 2022 may be imposed. For
each violation involving LNG facilities, an additional penalty of not more than $81,284 occurring
on or after January 11, 2021 and before May 3, 2021 may be imposed. For each violation involving
LNG facilities, an additional penalty of not more than $79,875 occurring on or after July 31, 2019
and before January 11, 2021 may be imposed.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to propose a civil penalty assessment at this time.
Proposed Compliance Order
With respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety
Administration proposes to issue a Compliance Order to Florida City Gas. Please refer to the
Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in
Enforcement Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. §552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment under
5 U.S.C. § 552(b).
Following your receipt of this Notice, you have 30 days to respond as described in the enclosed
Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes
a waiver of your right to contest the allegations in this Notice and authorizes the Associate
Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to
you and to issue a Final Order. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region Director
may extend the period for responding upon a written request timely submitted demonstrating good
cause for an extension.
In your correspondence on this matter, please refer to CPF 4-2026-023-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
2



Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings
cc: Michael McCarty, Director, Operations Compliance, mmccarty@chpk.com
2



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Florida City Gas (FCG) a Compliance Order
incorporating the following remedial requirements to ensure the compliance of FCG with the
pipeline safety regulations:
A. With respect to Item 1 of the Notice concerning FCG’s failure to protect from
corrosion components whose integrity or reliability could be adversely affected by
corrosion in accordance with § 193.2625(b)(1), FCG must:
i. Submit a work plan to the Director, Southwest Region to remove the insulation
from the affected piping and apply a protective coating within 30 days of receipt
of the Final Order. The work plan must address insulation removal, evaluation
and treatment of corroded areas, and application of protective coating. FCG
must implement the work plan upon submittal. Any deviations from the work
plan must be documented and provided to the Director, Southwest Region upon
completion of the work.
ii. Remove the insulation from the affected piping and apply a protective coating
using procedures and work practices consistent with generally accepted
engineering practice within 120 days of receipt of the Final Order.
iii. Provide monthly progress reports on the above corrective actions to the
Director, Southwest Region. The monthly progress reports must include but are
not limited to: progress made during the timeframe covered by that monthly
report, progress anticipated in the timeframe of the next monthly report, any
ongoing or anticipated delays and the justification for those delays. The first
monthly progress report is due to the Director, Southwest Region, within 30
days after receipt of the Final Order.
iv. Submit all records related to the work plan detailed in A(i) and (ii), including
Work Orders and photography documenting the work, to the Director,
Southwest Region within 30 days of the completion of the final work plan.
B. It is requested (not mandated) that Florida City Gas maintain documentation of the
safety improvement costs associated with fulfilling this Compliance Order and
submit the total to Bryan Lethcoe, Director, Southwest Region, Office of Pipeline
Safety, Pipeline and Hazardous Materials Safety Administration. It is requested that
these costs be reported in two categories: 1) total cost associated with
preparation/revision of plans, procedures, studies and analyses, and 2) total cost
associated with replacements, additions and other changes to pipeline
infrastructure.
2

42026023NOPV_Closure Letter_07092026_(25-329815)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: jhouseholder@chpk.com
July 9, 2026
Jeffry M. Householder
President and Chief Executive Officer
Chesapeake Utilities Corporation
500 Energy Lane
Dover, Delaware 19901
CPF 4-2026-023-NOPV
Dear Mr. Householder:
On March 26, 2026, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Florida City Gas (FCG), a Final Order in the above-referenced case. This Order included a
Compliance Order.
Based on our review of the documentation you provided, it has been determined that FCG has
complied with the terms of this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
R. M. Seeley
Acting Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Michael McCarty, Director, Operations Compliance, Chesapeake Utilities Corporation,
mmccarty@chpk.com
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