# OASIS PETROLEUM NORTH AMERICA — Notice of Probable Violation

**Citation:** CPF 320195020  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2019-06-17

CLOSED notice of probable violation citing 194.107(c)(1)(ix), 195.402(a), 195.402(d)(1), 195.403(a)(1), 195.403(a)(5), 195.420(b), 195.446(h)(4), 195.446(j)(1), 195.505(b), 195.563(a), 195.591.

## Document text

Notice of Probable Violation involving OASIS PETROLEUM NORTH AMERICA. PHMSA's enforcement data identifies the cited regulations as 194.107(c)(1)(ix),  195.402(a),  195.402(d)(1),  195.403(a)(1),  195.403(a)(5),  195.420(b),  195.446(h)(4),  195.446(j)(1),  195.505(b),  195.563(a),  195.591. The case was opened on 2019-06-17 and is reported as closed as of 2021-02-26. Proposed civil penalty: $207,800. Assessed civil penalty: $177,700. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320195020_Closure Letter_02262021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_Closure%20Letter_02262021.pdf

320195020_Closure Letter_02262021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_Closure%20Letter_02262021_text.pdf

320195020_Final Order_08192020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_Final%20Order_08192020.pdf

320195020_Final Order_08192020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_Final%20Order_08192020_text.pdf

320195020_NOPV PCP PCO_06172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_NOPV%20PCP%20PCO_06172019.pdf

320195020_NOPV PCP PCO_06172019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_NOPV%20PCP%20PCO_06172019_text.pdf

320195020_Operator Response to Notice_09112019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320195020/320195020_Operator%20Response%20to%20Notice_09112019.pdf

320195020_NOPV PCP PCO_06172019_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 17, 2019
Jason Swaren
Vice President, Operations
Oasis Midstream Partners
1001 Fannin St. Suite 1500
Houston, TX 77002
CPF 3-2019-5020
Dear Mr. Swaren:
On January 8 - 12, January 29 – February 2, February 12 – 16 and April 16 – 20, 2018,
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 your Oasis Petroleum North America, formerly Oasis Midstream Partners, (Oasis)
pipeline near Johnsons Corner (JC) and City of Williston (COW) units in Watford City and
Williston, ND.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:



1. §194.107 General response plan requirements
(a)….
(c) Each response plan must include:
(1) A core plan consisting of-
(ix) Drill program-an operator will satisfy the requirement for a drill program
by following the National Preparedness for Response Exercise Program (PREP)
guidelines. An operator choosing not to follow PREP guidelines must have a drill
program that is equivalent to PREP. The operator must describe the drill
program in the response plan and OPS will determine if the program is
equivalent to PREP.
Oasis failed to follow the National Preparedness for Response Exercise Program (PREP)
guidelines. Specifically, Oasis did not perform all required PREP drills within a 3-year
period as required by the PREP guidelines or a drill program that is equivalent to PREP.
Johnson’s Corner Unit had five missing PREP drill activities. Oasis personnel indicated
that they had not performed all the required PREP drills shown in the table below.
Johnson's Corner - Start-Up on 10/10/2016.
Type Required in 3
Years.
Oct. 2016 2017 2018
QI 12 Missing 1 Mar. 2017,
Missing 3
Tabletop 3 Mar. 2017
Unannounced 3 Missing 1
Equipment 3 Jan. 2017
Mar. 2017
Triennial 1
2. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline system
commence, and appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
2



(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits
have been exceeded:
(1) Responding to, investigating, and correcting the cause of:
(i) Unintended closure of valves or shutdowns;
(ii) Increase or decrease in pressure or flow rate outside normal operating limits;
(iii) Loss of communications;
(iv) Operation of any safety device;
(v) Any other malfunction of a component, deviation from normal operation, or
personnel error which could cause a hazard to persons or property.
Oasis failed to follow for each pipeline system a manual of written procedures for
conducting normal operations and maintenance activities and handling abnormal
operations and emergencies. Specifically, Oasis procedure P-195.402(d) states, “[t]he
control center supervisor should gather all information concerning the abnormal operation,
including the cause, effects, response, corrections, follow-up, monitoring, and any
resulting procedure reviews, and maintain these records in the control center files.”
During the inspection, Oasis could not produce records that indicated operator's personnel
responded to, investigated or gathered information concerning their indications of
abnormal operations, as required by the written procedures. Based on the inspectors
review of records, there were 19 abnormal operations in 2017 and 13 in 2018 that did not
receive a documented response or investigation by the control center supervisor.
3. §195.403 Emergency Response Training.
(a) Each operator shall establish and conduct a continuing training program to
instruct emergency response personnel to:
(1) Carry out the emergency procedures established under 195.402 that relate to
their assignments;
(5) Learn the potential causes, types, sizes, and consequences of fire and the
appropriate use of portable fire extinguishers and other on-site fire control
equipment, involving, where feasible, a simulated pipeline emergency condition.
Oasis failed to establish and conduct a continuing training program to instruct emergency
response personnel to carry out the emergency procedures established under 195.402 that
3



relate to their assignments. Specifically, Oasis records indicated that 39 individuals had
training from 2016 to 2018, but the training did not comply with § 195.403(a)(1) and
(a)(5).
Paragraph 195.402(e)(1), as provided by § 195.403(a)(1), requires that an operator’s
manual of written procedures for handling emergencies must include procedures for
“[r]eceiving, identifying, and classifying notices of events which need immediate response
by the operator or notice to fire, police, or other appropriate public officials and
communicating this information to appropriate operator personnel for corrective action.”
Additionally, Oasis’ training program failed to instruct, as provided by § 195.403(a)(5),
emergency response personnel to learn the potential causes, types, sizes, and consequences
of fire and the appropriate use of portable fire extinguishers and other on-site fire control
equipment, involving, where feasible, a simulated pipeline emergency condition.
In reviewing Oasis’ McKenzie County Emergency Response Program (ERP), the PHMSA
inspector noted the training did not: 1) Address the receiving, identifying, and classifying
notices of events which need immediate response by the operator. 2) Address the potential
causes, types, sizes and consequences of fire and the appropriate use of portable fire
extinguishers.
4. §195.420 Valve maintenance.
(a) . . . .
(b) Each operator shall, at intervals not exceeding 71∕2 months, but at least twice
each calendar year, inspect each mainline valve to determine that it is functioning
properly.
Oasis failed to inspect each mainline valve to determine that it functioned properly at
intervals not exceeding 7-1∕2 months, but at least twice each calendar year. The Johnson's
Corner line went into service on 10/10/2016 and the first valve inspection was completed
on 3/3/2018. Oasis stated to PHMSA that no valve inspections occurred during that
period. There were 2 inspection cycles missed for 4 valves for a total of 8 valve
inspections that were not performed.
5. §195.446 Control room management.
(a) . . . .
(h) Training. Each operator must establish a controller training program and review
the training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 months. An operator's program must
4



provide for training each controller to carry out the roles and responsibilities defined
by the operator. In addition, the training program must include the following
elements:
(4) Training that will provide a controller a working knowledge of the pipeline
system, especially during the development of abnormal operating conditions;
Oasis failed to establish a controller training program that provides its controllers a
working knowledge of the pipeline system, especially during the development of abnormal
operating conditions. An essential part of the working knowledge of the pipeline system
includes knowledge of the safety related data points. Oasis had not developed a list of
safety related data points. Five controllers attended the operator’s control room
management training. During the inspection, PHMSA interviewed a controller who stated
that he had not seen a list of safety related points and was unaware of which points were
safety related beyond MOP and high pressure.
6. §195.446 Control room management.
(a) . . . .
(j) Compliance and deviations. An operator must maintain for review during
inspection:
(1) Records that demonstrate compliance with the requirements of this section;
Oasis failed to maintain records as required by §195.446(j)(1) to demonstrate compliance
with §195.446(c)(2). During the inspection, Oasis could not produce records for the point-
to-point verifications required by §195.446(c)(2). An email from the Oasis Pipeline
Control Center Supervisor states that they had performed the verifications but had no
documentation. A total of 14 points did not have verification documentation.
7. §195.505 Qualification program.
Each operator shall have and follow a written qualification program. The program
shall include provisions to:
(a) . . . .
(b) Ensure through evaluation that individuals performing covered tasks are
qualified;
The operator did not follow its written qualification program. Oasis’ Operator
Qualification (OQ) plan required written (knowledge) and performance evaluations for all
covered tasks as listed in Appendix C “Qualification Requirements Column – Knowledge
and Performance” . Although written evaluations were completed before pipeline
5



operation, there were no performance evaluations conducted until after the Johnson’s
Corner (JC) pipeline began operations on October 10, 2016. A submittal was received
from Oasis detailing tasks performed by nine unqualified personnel. Based on
documentation the PHMSA inspector reviewed, the JC pipeline was operated from
October 10, 2016 through May 1, 2017 by four unqualified North Dakota controllers. On
April 4, 2017, the first Houston controller received adequate operator qualification
training. That person began controlling the pipeline on May 2, 2017. Additionally, this
submittal showed that five other OQ covered tasks (patrolling, launching / receiving pigs,
operating valves, and line locating) were performed on the pipeline by six unqualified
field personnel in North Dakota.
8. §195.563 Which pipelines must have cathodic protection?
(a) Each buried or submerged pipeline that is constructed, relocated, replaced, or
otherwise changed after the applicable date in §195.401(c) must have cathodic
protection. The cathodic protection must be in operation not later than 1 year after
the pipeline is constructed, relocated, replaced, or otherwise changed, as applicable.
Oasis failed to have its cathodic protection system in operation no later than 1 year after its
pipeline was constructed. The JC pipeline was hydrostatically tested on August 29, 2016,
which means the pipeline had already been constructed by that date. Cathodic protection
on the pipeline was complete and in operation on October 4, 2017. This exceeded the 1
year requirement by 36 days.
9. §195.591 In-Line inspection of pipelines.
When conducting in-line inspection of pipelines required by this part, each operator
must comply with the requirements and recommendations of API Std 1163, Inline
Inspection Systems Qualification Standard; ANSI/ASNT ILI-PQ, Inline Inspection
Personnel Qualification and Certification; and NACE SP0102-2010, Inline Inspection
of Pipelines (incorporated by reference, see §195.3). An in-line inspection may also be
conducted using tethered or remote control tools provided they generally comply
with those sections of NACE SP0102-2010 that are applicable.
Oasis did not comply with the requirements and recommendations of NACE SP0102-2010
when conducting in-line inspection of pipelines required by Part 195. Specifically, Oasis
did not correlate ILI results after the Rosen Combo MFL tool run that took place in
November of 2017 as required by Section 8.1.1.4. NACE SP0102-2010. Section 8.1.1.4
states, “[c]orrelations should be made between field assessment information and ILI data.
All accuracy errors associated with field measurement and ILI data must be taken into
account in integrity assessment and planning.” As part of the Oasis’ response to
PHMSA’s inspection, Oasis hired a contractor named TEAM to provide ultrasonic testing
(UT) readings which took place on 6/20/2018 for the purpose of validating the tool run.
6



Additionally, Oasis decided to complete 2 digs which took place on 9/8/2018 and 9/9/2018
to further validate the tool run. Oasis was unable to provide records showing any
correlations made between the field assessment information and ILI data prior to the
inspection. Oasis has submitted updated procedures to correct this going forward.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679
for a related series of violations. For violations occurring on or after November 2, 2015 and
before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per
day, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to
November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day,
with a maximum penalty not to exceed $2,000,000 for a related series of violations. The
Compliance Officer has reviewed the circumstances and supporting documentation involved
in the above probable violation(s) and has recommended that you be preliminarily assessed a
civil penalty of $207,800 as follows:
Item number
1
PENALTY
$ 20,300
4
$ 21,400
5
$46,600
6
$ 20,000
7
$ 99,500
Warning Items
With respect to items 2, 8 and 9, we have reviewed the circumstances and supporting
documents involved in this case and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to promptly correct
these items. Failure to do so may result in additional enforcement action.
Proposed Compliance Order
With respect to items 3 and 5 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Oasis Midstream
Partners. 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 Compliance 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
7



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 the receipt of this Notice, you have 30 days to submit written comments, or request
a hearing under 49 CFR § 190.211. 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. This period may be extended by written request for good cause.
In your correspondence on this matter, please refer to CPF 3-2019-5020 and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
8



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Oasis Midstream Partners (Oasis) a
Compliance Order incorporating the following remedial requirements to ensure the
compliance of Oasis with the pipeline safety regulations:
1. 2. 3. 4. In regard to Item Number 3 of the Notice pertaining to establishing and
conducting a continuing training program, Oasis must establish a program and
train its personnel that includes the following elements: 1) Address the
receiving, identifying, and classifying notices of events which need immediate
response by the operator. 2) Address the potential causes, types, sizes and
consequences of fire and the appropriate use of portable fire extinguishers.
Oasis must provide PHMSA with the revised program and documentation of
training provide to its staff.
In regard to Item Number 5 of the Notice pertaining to establishing a controller
training program that provides its controllers a working knowledge of the
pipeline system especially during abnormal operating conditions. Oasis must
amend its program to include a list of safety related data points and include this
information in its controller training program. Oasis must must provided this
revised program and documentation of training provided to its controllers.
Oasis must provide the documents listed above withing 90 days after receipt of
a Final Order.
It is requested (not mandated) that Oasis maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit
the total to Allan C. Beshore, Director, Central Region, OPS, 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.
9

320195020_Final Order_08192020_text.pdf

August 19, 2020
VIA ELECTRONIC MAIL TO: jswaren@oasispetroleum.com
Mr. Jason Swaren
Vice President – Operations
Oasis Midstream Partners, LP
1001 Fannin Street, Suite 1500
Houston, Texas 77002
Re: CPF No. 3-2019-5020
Dear Mr. Swaren:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a reduced civil penalty of $177,700, and specifies actions that need to be
taken by Oasis Midstream Partners LP, to comply with the pipeline safety regulations. The
penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and
the terms of the compliance order completed, as determined by the Director, Central Region, this
enforcement action will be closed. Service of the Final Order by electronic mail is effective
upon the date of transmission as provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Allan Beshore, Director, Central Region, Office of Pipeline Safety, PHMSA
Mr. David Copeland, Senior Regulatory Specialist, Oasis Midstream Partners, LP,
dcopeland@oasispetroleum.com
Mr. Thomas B. Nusz, Chairman and Chief Executive Officer, Oasis Petroleum, Inc.,
tnusz@oasispetroleum.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
Oasis Midstream Partners, LP,
a general partner of Oasis Petroleum, Inc.,
Respondent.
)
)
)
)
)
)
__________________________________________)
CPF No. 3-2019-5020
FINAL ORDER
On multiple occasions between January 8, 2019, and April 20, 2019, pursuant to 49 U.S.C.
§ 60117, representatives 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 Oasis Midstream Partners, LP’s (Oasis or Respondent) Johnson
Corner (JC) and City of Williston (COW) pipelines in Watford City and Williston, North
Dakota, respectively. The JC pipeline consists of 19 miles of 10.75” steel crude-oil pipeline
transporting crude oil between Oasis’s Wild Basin Crude Handling Facility to two separate
interconnects at Johnson’s Corner, North Dakota, for further transportation to other pipelines and
depots. The COW pipeline is an approximately 1.4-mile, steel X52, 6” gathering pipeline
transporting crude oil from Oasis’ COW drilling space unit (DSU) to a central tank battery where
the product is trucked out for delivery.1 Oasis is a master limited partnership formed by Oasis
Petroleum., Inc.2
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated June 17, 2019, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice), which also included warning items pursuant to 49 C.F.R.
§ 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Oasis had
violated 49 C.F.R. § 194.107, and committed eight other probable violations of 49 C.F.R. Part
195 and proposed assessing a civil penalty of $207,800 for the alleged violations. The Notice
also proposed ordering Respondent to take certain measures to correct the alleged violations.
The warning items required no further action but warned the operator to correct the probable
violations or face possible future enforcement action.
1 See Pipeline Safety Violation Report, dated June 17, 2019 (Violation Report) (on file with PHMSA), at 1.
2 See https://www.oasismidstream.com/about/ (last accessed August 7, 2020). The Operator ID (OPID) on file with
PHMSA identifies the operator as “Oasis Petroleum North America”, but there is no reference to any such entity on
Oasis’ website. For purposes of this Final Order, Oasis Midstream Partners, LP, and Oasis Petroleum North
America are the same.



CPF No. 3-2019-5020
Page 2
After requesting and receiving an extension of time to respond, Oasis responded to the Notice by
letter dated September 11, 2019 (Response), and again on September 30, 2019 (Supplemental
Response). The company contested some of the allegations, offered additional information in
response to the Notice, and requested that the proposed civil penalty be reduced or eliminated.
Respondent did not request a hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Parts 194 and 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 194.107(c)(1)(ix), which states:
§ 194.107 General response plan requirements.
(a) ….
(c) Each response plan must include:
(1) A core plan consisting of— . . .
(ix) Drill program—an operator will satisfy the requirement for a drill
program by following the National Preparedness for Response Exercise
Program (PREP) guidelines. An operator choosing not to follow PREP
guidelines must have a drill program that is equivalent to PREP. The
operator must describe the drill program in the response plan and OPS will
determine if the program is equivalent to PREP.
The Notice alleged that Respondent violated 49 C.F.R. § 194.107(c)(1)(ix) by failing to follow
the PREP guidelines. Specifically, the Notice alleged that Oasis did not perform all required
PREP drills within a three-year period, as required by the PREP guidelines, or a drill program
that is equivalent to PREP. The JC pipeline had five missing PREP drill activities between 2016
and 2017.
On the one hand, Respondent did not contest this allegation of violation, acknowledging “that it
did not meet all of its PREP Drill requirements at the start of Johnson’s corner (JC) pipeline
facility.” One the other hand, it asserted that the allegation in the Notice that it failed to conduct
all required PREP drills in 2016 and 2017 was “inaccurate.”3 However, this statement is
unsupported by the record and must be weighed against certain unchallenged allegations in the
Notice. Specifically, the Notice identified a document titled “Johnson’s Corner Start-up on
10/10/2016,” which identified five missing PREP drills for the JC pipeline between 2016 and
2017. Further, the Notice alleged that an Oasis employee stated to the PHMSA inspector that not
all required PREP drills had been completed for the JC pipeline during that same time period.
Based on the totality of the evidence, I find that PHMSA has met its burden of proving this
allegation of violation. Accordingly, based upon a review of all of the evidence, I find that
Respondent violated 49 C.F.R. § 194.107(c)(1)(ix) by failing to follow the PREP guidelines for
the JC pipeline on five occasions between 2016-2017.
3 Response, at 2 (on file with PHMSA).



CPF No. 3-2019-5020
Page 3
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.403(a), which states, in
relevant part:
§ 195.403 Emergency response training.
(a) Each operator shall establish and conduct a continuing training
program to instruct emergency response personnel to:
(1) Carry out the emergency procedures established under 195.402 that
relate to their assignments; . . .
(5) Learn the potential causes, types, sizes, and consequences of fire
and the appropriate use of portable fire extinguishers and other on-site fire
control equipment, involving, where feasible, a simulated pipeline
emergency condition.
The Notice alleged that Respondent violated 49 C.F.R. § 195.403(a) by failing to establish and
conduct a continuing training program to instruct emergency response personnel to carry out the
emergency procedures established under § 195.402 that relate to their assignments. Specifically,
the Notice alleged that Oasis records indicated 39 individuals had undergone emergency
response training from 2016 to 2018, but that the training failed to comply with§ 195.403(a)(l)
and (a)(5). Under § 195.402(e)(l), an operator's manual of written procedures for handling
emergencies must include procedures for "[r]eceiving, identifying, and classifying notices of
events which need immediate response by the operator or notice to fire, police, or other
appropriate public officials and communicating this information to appropriate operator
personnel for corrective action."
The Notice alleged that Oasis’ training program failed to address the receiving, identifying, and
classifying of event notices that need immediate response by the operator. Additionally, Oasis'
training program allegedly failed to instruct, as provided by § 195.403(a)(5), emergency
response personnel on the potential causes, types, sizes, and consequences of fires and the
appropriate use of portable fire extinguishers and other on-site fire-control equipment, involving,
where feasible, a simulated pipeline emergency condition.
In its Response, Oasis provided information related to the training of its personnel and certain
improvements it had made to its training program in support of its request that PHMSA
withdraw this item or reduce it to a warning item or a notice of amendment.4
Oasis maintained that the steps it had taken in response to the Notice warrant a reduction of this
item from a probable violation to something less. The record, however, does not provide a basis
for doing so. Significantly, Oasis acknowledged in its Response that “it did not meet all of its
operator personnel training requirements at the start of the JC pipeline facility.”5 Oasis further
stated that it “acknowledged deficiencies identified during the 2018 inspection in real time,
demonstrating its collaborative, open approach with PHMSA.”
Oasis’s actions in addressing these training deficiencies are welcomed by PHMSA, but such
4 Response, at 4-5.
5 Id., at 4.



CPF No. 3-2019-5020
Page 4
after-the-fact conduct does not provide a basis to absolve Oasis of its acknowledged violations,
nor does it warrant reducing the violation to something less. The violation was not merely a
failure to have adequate training procedures, which could serve as the basis for a notice of
amendment, but rather, a failure to conduct code compliance training for 39 individuals from
2016 to 2018. There is nothing in the record to rebut this allegation.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.403(a) by failing to establish and conduct a continuing training program to instruct
emergency response personnel to carry out the emergency procedures established under
§ 195.402 that relate to their assignments.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.420(b), which states:
§ 195.420 Valve maintenance.
(a) ….
(b) Each operator shall, at intervals not exceeding 7½ months, but at
least twice each calendar year, inspect each mainline valve to determine that
it is functioning properly.
The Notice alleged that Respondent violated 49 C.F.R. § 195.420(b) by failing to inspect each
mainline valve to determine that it is functioning properly, at intervals not exceeding 7½ months
but at least twice each calendar year. Specifically, the Notice alleged that the JC pipeline went
into service on October 10, 2016, but the first valve inspection was not completed until March 3,
2018. According to the Notice, Oasis personnel stated to PHMSA inspectors that no valve
inspections had occurred during that period. Thus, there were two inspection cycles missed for
four valves, for a total of eight valve inspections that were not performed.
In its Response, Oasis stated that “[w]ithout conceding the underlying violation,” it
acknowledged that it “did not meet frequency requirements for valve inspections at the start of
the JC pipeline facility” and that it had “acknowledged deficiencies identified during the subject
inspection in real time, demonstrating its collaborative, open approach with PHMSA.”6 The
company therefore suggested that the agency should reduce the proposed civil penalty, an
argument that is discussed more fully in the “Assessment of Penalty” section below.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.420(b) by failing to inspect each mainline valve to determine that it is functioning
properly, at intervals not exceeding 7½ months but at least twice each calendar year.
Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.446(h)(4), which states:
§ 195.446 Control room management.
(a) ….
(h) Training. Each operator must establish a controller training
program and review the training program content to identify potential
improvements at least once each calendar year, but at intervals not to exceed
6 Id., at 5-6.



CPF No. 3-2019-5020
Page 5
15 months. An operator's program must provide for training each controller
to carry out the roles and responsibilities defined by the operator. In
addition, the training program must include the following elements:
(1) . . .
(4) Training that will provide a controller a working knowledge of the
pipeline system, especially during the development of abnormal operating
conditions;
The Notice alleged that Respondent violated 49 C.F.R. § 195.446(h)(4) by failing to establish a
controller training program that provides its controllers with a working knowledge of the
operator’s pipeline system, especially during the development of abnormal operating conditions.
Specifically, the Notice alleged that an essential part of the working knowledge of the pipeline
system includes knowledge of its safety-related data points, and that Oasis had not developed a
list of such points.7 Five controllers attended the operator's control room management training
and during its inspection, PHMSA allegedly interviewed one controller who stated that he had
not seen a list of safety-related points for Oasis’ system and was unaware of which points were
safety-related beyond “Maximum Operating Pressure” (MOP) and high pressure.
In its Response, Oasis stated that it did not “contest the alleged violation subject to the correction
of relevant facts.”8 In particular, Oasis contended that the company had provided information to
PHMSA demonstrating that safety-related points had actually been identified to the OPS
inspectors prior to the 2018 inspection. Oasis requested that PHMSA consider the relevant facts
and either withdraw or convert the alleged violation to a warning item or notice of amendment.
The record, however, does not support a “correction” of the alleged facts since none of the facts
put forward by Respondent actually relate to the training received by its controllers, nor do they
warrant a reduction of this item to a warning or notice of amendment. The most relevant facts
underlying the alleged violation stand uncontested and are sufficient on their own to uphold the
violation. First, the Notice alleged that one of Oasis’s own controllers stated during an interview
with a PHMSA inspector that he was not aware of which SCADA points were safety-related and
had not seen a list of such points. That fact alone, without credible evidence rebutting the
allegation, shows that Oasis failed to properly train all of its controllers consistent with the
requirements of the regulation. Although Oasis stated in its Response that it provided PHMSA
with a list of safety-related data points during the inspection, that fact does not rebut the
allegation that Oasis failed to properly train its employees on these safety-related data points, an
7 To conduct an adequate control room management training program, an operator must provide its controllers with
“a working knowledge” of the company’s pipeline system. This is spelled out in more detail under paragraph (c) of
§ 195.466, which requires that an operator must provide its controllers with the information, tools, processes and
procedures necessary to carry out their responsibilities. This specifically includes the ability to conduct a “point-to-
point verification between [Supervisory Control and Data Acquisition Systems (SCADA)] displays and related field
equipment when field equipment is added or moved and when other changes that affect pipeline safety are made to
field equipment or SCADA displays.” For more information about safety-related SCADA points, see Control Room
Management Frequently Asked Questions (FAQs) (updated 1/16/2018), FAQ C.01, at
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/technical-resources/pipeline/ control-room-
management/60636/faqs-control-room-management-20180726.pdf,
8 Response, at 6-7.



CPF No. 3-2019-5020
Page 6
allegation that is supported by the statement referenced above by an Oasis controller. Second, as
Oasis admits in its Response, it did not amend its procedures to include a detailed list of safety-
related data points specific to its unique system until after the PHMSA inspection took place.9
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.446(h)(4) by failing to establish a controller training program that provides its controllers
with a working knowledge of the company’s pipeline system, especially during the development
of abnormal operating conditions.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.446(j)(1), which states:
§ 195.446 Control room management.
(a) ….
(j) Compliance and deviations. An operator must maintain for review
during inspection:
(1) Records that demonstrate compliance with the requirements of this
section;
The Notice alleged that Respondent violated 49 C.F.R. § 195.446(j)(1) by failing to maintain
records as required by § 195.446(j)(1) to demonstrate compliance with the control room
management regulations. Specifically, the Notice alleged that during the inspection, Oasis could
not produce records for the point-to-point verifications required by § 195.446(c)(2). A total of
14 points did not have verification documentation.
In its Response, Oasis contested the allegation of violation and stated as follows: “Subject to
correction of relevant facts, Oasis contests the alleged violation without requesting a hearing.”10
Specifically, Oasis stated in its Response that it “provided PHMSA records of point-to-point
verifications and lists of identified safety-related points as well as revisions to associated
procedures as part of the 2018 inspection process on May 7, 2018, June 04, 2018, September 13,
2019, and on October 1, 2018, … [and that] point-to-point verifications are not required to show
compliance with § 195.466(c)(2).”11 In addition, Oasis submitted a Supplemental Response for
Item 6 that purports to address the allegation in the Notice that Oasis was unable to provide
records evidencing that point-to-point verification was performed for the 14 points alleged to be
lacking relevant records.12
Oasis’s argument that point-to-point verifications are not required to show compliance with
9 Id.
10 Id., at 7. The Response went on to state that Oasis was “providing information and explanations it believes should
be considered by the Administration for the purpose of changing, reducing, or eliminating the PCP for the alleged
violation.” Some of this information challenged the allegation of violation and is therefore discussed here. Other
information sought to reduce or eliminate the proposed penalty and is therefore discussed in the “Assessment of
Penalty” section below.
11 Id., at 8.
12 Supplemental Response, at 1, 4.



CPF No. 3-2019-5020
Page 7
§ l95.446(c)(2) is incorrect. Section 195.446(c)(2) clearly states that operators, via their
controllers, must “[c]onduct a point-to-point verification between SCAD A displays and related
field equipment when field equipment is added ….” This is a requirement for the initial
connection of these devices and an operator is required to maintain for review during a PHMSA
inspection all records demonstrating compliance with the verification requirement. Oasis failed
to do so in this case. Further, the records provided by Oasis in its Supplemental Response show
that the 14 points were verified in 2017. The Oasis pipeline went into operation in 2016 and the
records that were allegedly missing relate to the initial point-to-point verifications that were
required to take place in 2016.
Accordingly, after considering all of the evidence and the legal issues presented, I find
that Respondent violated 49 C.F.R. § 195.446(j)(1) by failing to maintain records as required by
§ 195.446(j)(1) to demonstrate compliance with the control room regulations in § 195.446(c)(2).
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 195.505(b), which states:
§ 195.505 Qualification program.
Each operator shall have and follow a written qualification program.
The program shall include provisions to:
(a) ….
(b) Ensure through evaluation that individuals performing covered
tasks are qualified; . . .
The Notice alleged that Respondent violated 49 C.F.R. § 195.505 by failing to follow its own
written qualification program. Specifically, the Notice alleged that Oasis' Operator Qualification
(OQ) plan required written (knowledge) and performance evaluations for all covered tasks as
listed in the plan’s Appendix C, "Qualification Requirements Column - Knowledge and
Performance." Although written evaluations were completed before pipeline operations began,
there were no performance evaluations conducted until after the JC pipeline began operations on
October 10, 2016. Oasis provided information detailing certain tasks that were performed by
nine unqualified personnel. Based on documentation the PHMSA inspector reviewed, the JC
pipeline was operated from October 10, 2016, through May 1, 2017, by four unqualified North
Dakota controllers. It wasn’t until April 4, 2017 that the first Houston controller received
adequate operator qualification training and began controlling the pipeline on May 2, 2017.
Additionally, this submittal showed that five other OQ covered tasks (i.e., patrolling,
launching/receiving pigs, operating valves, and line locating) were performed on the pipeline by
six unqualified field personnel in North Dakota.
In its Response, Oasis acknowledged “that it did not meet key personnel qualification
requirements in accordance with [its] Operator Qualification program (OQ) at the start of the JC
pipeline facility . . .” and that the company “acknowledged deficiencies identified during the
2018 inspection in real time, demonstrating Oasis’s collaborative, open approach with
PHMSA.”13 The company also provided certain information that sought to reduce or eliminate
the proposed penalty, which will be discussed more fully in the “Assessment of Penalty” section
13 Id., at 9-10.



CPF No. 3-2019-5020
Page 8
below, but nothing in Oasis’s Response shows that Oasis did not violate the regulation.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.505 by failing to follow its own written qualification program.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.14 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; any effect that
the penalty may have on its ability to continue doing business; and the good faith of Respondent
in attempting to comply with the pipeline safety regulations. In addition, I may consider the
economic benefit gained from the violation without any reduction because of subsequent
damages, and such other matters as justice may require. The Notice proposed a total civil
penalty of $207,800 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $20,300 for Respondent’s violation of 49 C.F.R.
§ 194.107(c)(1)(ix), for failing to perform all required PREP drills on the JC pipeline within a
three-year period, as required by the PREP guidelines, or a drill program that is equivalent to
PREP. In its Response, Oasis requested that the proposed civil penalty be reduced or eliminated,
under the good-faith assessment criterion, on the basis that it had instituted certain improvements
to its emergency response program and that it had made “chronological improvement in both
drill frequency and administrative process.”15 While Oasis is to be commended for improving its
internal processes to ensure compliance with the pipeline safety regulations, such post-inspection
activities do not warrant the withdrawal of, or a reduction in, a proposed civil penalty. Further,
such ongoing actions and improvements are ones that PHMSA would expect of any prudent
operator. In summary, I can find no evidence or argument in the record that would warrant
elimination or reduction of the proposed penalty.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $20,300 for violation of 49 C.F.R. § 194.407(c)(1)(ix).
Item 4: The Notice proposed a civil penalty of $21,400 for Respondent’s violation of 49 C.F.R.
§ 195.420(b), for failing to inspect, at intervals not exceeding 7½ months but at least twice each
calendar year, each mainline valve on the JC pipeline to determine that it functioned properly. In
its Response, Oasis asked that the proposed civil penalty be eliminated or reduced, particularly
14 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.
15 Response, at 2.



CPF No. 3-2019-5020
Page 9
by receiving a credit under PHMSA’s “good faith” penalty criterion. In support of its request,
Oasis stated that in 2016, it had committed to implementing a cloud-based system for preventive
maintenance and repairs and had committed additional resources to further develop this system
in 2018. I find that while Oasis may have made efforts to improve its maintenance and repair
software and committed additional resources to its Operations and Maintenance (O&M) efforts
in 2018, there is no evidence that such measures were aimed specifically at correcting or
preventing violations of § 195.420(b) prior to the 2018 PHMSA inspection. On the contrary,
Oasis failed to comply with a requirement that was clearly applicable and did not have a
reasonable justification for non-compliance. Additionally, the proposed civil penalty already
accounted for, and proposed a lower penalty on account of, pipeline safety being minimally
affected. Therefore, no elimination or further reduction of the proposed civil penalty for Item 4
is justified. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Respondent a civil penalty of $21,400 for violation of 49 C.F.R. § 195.420(b).
Item 5: The Notice proposed a civil penalty of $46,600 for Respondent’s violation of 49 C.F.R.
§ 195.446(h)(4), for failing to failing to establish a controller training program that provides its
controllers with a working knowledge of the company’s pipeline system, especially for abnormal
operating conditions. In its Response, Oasis requested that the proposed civil penalty be
eliminated or reduced based on improvements it had made to its procedures to address the
violation alleged in the Notice. However, as was the case with the previous Item, the procedural
changes were not implemented by Oasis until after OPS began its 2018 inspection, and thus do
not serve as the basis to reduce or eliminate the proposed civil penalty.
Additionally, Oasis objected to the proposed penalty amount because it ‘appears inconsistent
with PHMSA policy.16 Specifically, Oasis asserted that the imposition of a civil penalty, and the
bringing of this Item as a regulatory violation, as opposed to a Notice of Amendment(NOA),
appear inconsistent with sections 3.1.1.3 and 3.1.3.1 of PHMSA’s Pipeline Safety Enforcement
Procedures.
17 I disagree. Oasis’s contention misapplies the procedures and omits significant
language contained therein. First, the enforcement procedures are used as guidance for bringing
enforcement cases, but are not to be construed as mandatory or binding when PHMSA exercises
its enforcement authority and discretion. Second, section 3.1.1.3 specifically states that “[a] civil
penalty may be proposed for any probable violation . . .” The Director was well within his
discretion to propose a civil penalty for this Item, and nothing in the procedures or the
regulations prevent me from imposing a civil penalty for this Item. With regard to section
3.1.3.1, which discusses when to use an NOA for an alleged violation of the pipeline safety
regulations, I reject the contention that this Item should have been an NOA. As I found above
for this Item, Oasis failed to properly train its controllers with respect to its procedures, not that
the procedures were inadequate to ensure compliance with the regulation, and the improper
training was not an isolated event but involved a number of individuals over a sustained period
of time. For these reasons, I reject Oasis’s contention that bringing this Item in the Notice and
with a proposed civil penalty attached is inconsistent with PHMSA’s internal enforcement
policies.
16 Id., at 7.
17 See https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/regulatory-
compliance/pipeline/enforcement/69421/section-3-selection-administrative-enforcement-actions-april-27-2018.pdf.



CPF No. 3-2019-5020
Page 10
The proposed civil penalty correctly accounted for Oasis' failure to comply with a requirement
that was clearly applicable and the absence of a reasonable justification for the non-compliance.
Finally, the proposed civil penalty accounted for the fact that the OPS inspectors discovered the
violation, and that the violation could affect a high consequence area segment during day-to-day
operations. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Respondent a civil penalty of $46,600 for violation of 49 C.F.R. § 195.446(h)(4).
Item 6: The Notice proposed a civil penalty of $20,000 for Respondent’s violation of 49 C.F.R.
§ 195.446(j)(1), for failing to maintain records demonstrating compliance with § 195.446(c)(2).
In its Response and Supplemental Response, Oasis requested that the proposed civil penalty
associated with this Item be eliminated or reduced, but did not provide any information in
support of its request as it relates to the proposed penalty calculation beyond what was addressed
above in the “Findings of Violation” section. Finally, Oasis alleged that the proposed civil
penalty and the nature of how this Item was brought (Notice versus NOA) violated PHMSA
policy. For the same reasons stated above in Item 5, I reject the contention that this Item is
somehow inconsistent with PHMSA’s enforcement policy. I would further note that the
proposed penalty already took into account the fact that the non-compliance involved a records
violation and that pipeline safety was minimally affected. Additionally, the proposed civil
penalty correctly accounted for Oasis' failure to comply with a requirement that was clearly
applicable and the company’s failure to have a reasonable justification for its non-compliance.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $20,000 for violation of 49 C.F.R. § 195.446(j)(1).
Item 7: The Notice proposed a civil penalty of $99,500 for Respondent’s violation of 49 C.F.R.
§ 195.505(b), for failing to follow its written qualification program by allowing four unqualified
North Dakota controllers to operate the JC pipeline between October 10, 2016, through May 1,
2017, and that five other covered tasks (patrolling, launching/receiving pigs, operating valves,
and line locating) were performed by six unqualified field personnel in North Dakota. In its
Response, Oasis requested that the proposed civil penalty be eliminated or reduced, arguing that,
contrary to the allegations in the Notice, the right-of-way patrols were performed by qualified
personnel and that there were five, rather than six, unqualified employees who performed
covered tasks.
The record reflects that Oasis is correct that the qualification issue was discovered and corrected
prior to the PHMSA inspection, that there were five, not six, unqualified employees performing
covered tasks, and that four controllers operated the pipeline while being unqualified. In
addition, the record reflects that Oasis took documented steps to address the cause of the non-
compliance and was in the process of correcting the non-compliance when it was discovered by
PHMSA. Such action warrants a reduction in the civil penalty under the culpability assessment
criterion. Oasis’s failure to self-report the violation is already accounted for in the civil penalty
calculation under the “Circumstances” assessment criterion on the Violation Report.
Accordingly, the culpability factor used in calculating the proposed civil penalty is reduced from
three to four, and the number of instances of violation is reduced from ten to nine. Based upon
the foregoing, I assess Respondent a reduced civil penalty of $69,400 for violation of 49 C.F.R.
§ 195.505(b).
In summary, having reviewed the record and considered the assessment criteria for each of the



CPF No. 3-2019-5020
Page 11
Items cited above, I assess Respondent a total reduced civil penalty of $177,700.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $177,700 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 3 and 5 in the Notice for
violations of 49 C.F.R. §§ 195.403(a) and 195.446(h)(4), respectively. Under 49 U.S.C.
§ 60118(a), each person who engages in the transportation of hazardous liquids or who owns or
operates a pipeline facility is required to comply with the applicable safety standards established
under chapter 601. The Director has indicated that Respondent has completed the program
enhancements and training as required by the Proposed Compliance Order to address the
deficiencies that served as the basis for the violation in Item 3. Accordingly, I find that
compliance has been achieved with respect to this violation. Therefore, the compliance terms
proposed in the Notice for Item 3 are not included in this Order.
As for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and
49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance
with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.446(h)(4) (Item 5), Respondent must amend
its controller training program to include a list of safety-related data points. Oasis
must provide the revised program and documentation of training provided to its
controllers to the Director within 90 days of receipt of this Final Order.
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.
It is requested (not mandated) that Respondent maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total to the
Director. 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



CPF No. 3-2019-5020
Page 12
with replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each
day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
WARNING ITEMS
With respect to Items 2, 8 and 9, the Notice alleged probable violations of Part 195, but
identified them as warning items pursuant to § 190.205. The warnings were for:
49 C.F.R. § 195.402(d)(1) (Item 2) ─ Respondent’s alleged failure to follow for
each pipeline system a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and
emergencies;
49 C.F.R. § 195.563(a) (Item 8) ─ Respondent’s alleged failure to have a
cathodic protection system in operation no later than one year after its pipeline
was constructed; and
49 C.F.R. § 195.591 (Item 9) – Respondent’s alleged failure to comply with the
requirements and recommendations of NACE SP0102-2010 when conducting the
in-line inspection of pipelines required by Part 195.
If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be
subject to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this
Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and
meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays
the payment of any civil penalty assessed. The other terms of the order, including corrective
action, remain in effect unless the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
August 19, 2020
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

320195020_Closure Letter_02262021_text.pdf

VIA ELECTRONIC MAIL TO: jswaren@oasispetroleum.com
February 26, 2021
Jason Swaren
Vice President, Operations
Oasis Midstream Partners
1001 Fannin St. Suite 1500
Houston, TX 77002
CPF 3-2019-5020
Dear Mr. Swaren:
On August 19, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Oasis Midstream Partners, LP a Final Order in the above-referenced case. This Order
included a Compliance Order and Civil Penalty assessment. Based on our review of the
documentation you provided and confirmation of payment of the civil penalty, it has been
determined that you have 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,
Gregory A. Ochs
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320195020>
- Source ID: `phmsa-enforcement`
- SHA-256: `ad31ae19e3f695b9ef6da686a3715ed7fd79cb300e04c5d5b286f04f61da3a51`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T00:53:22.111Z
- Document slug: `phmsa-enforcement-320195020`

### Source metadata

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```