# BBT MIDLA, LLC — Notice of Probable Violation

**Citation:** CPF 420151007  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-04-20

CLOSED notice of probable violation citing 192.631(c), 192.631(d)(3), 192.631(e)(4), 192.631(j)(1).

## Document text

Notice of Probable Violation involving BBT MIDLA, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(c),  192.631(d)(3),  192.631(e)(4),  192.631(j)(1). The case was opened on 2015-04-20 and is reported as closed as of 2018-01-12. Proposed civil penalty: $17,300. Assessed civil penalty: $17,300. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420151007_Closure Letter_01122018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_Closure%20Letter_01122018.pdf

420151007_Closure Letter_01122018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_Closure%20Letter_01122018_text.pdf

420151007_Final Order_11152016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_Final%20Order_11152016.pdf

420151007_Final Order_11152016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_Final%20Order_11152016_text.pdf

420151007_NOPV PCP PCO_04202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_NOPV%20PCP%20PCO_04202015.pdf

420151007_NOPV PCP PCO_04202015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_NOPV%20PCP%20PCO_04202015_text.pdf

420151007_Operator Response to Notice and Request for Time Extension_05202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_Operator%20Response%20to%20Notice%20and%20Request%20for%20Time%20Extension_05202015.pdf

420151007_Operator Response to Notice_06262015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420151007/420151007_Operator%20Response%20to%20Notice_06262015.pdf

420151007_Final Order_11152016_text.pdf

November 15, 2016
Mr. Lynn L. Bourdon III
Chairman, President and Chief Executive Officer
American Midstream Partners, LP
1400 16th Street, Suite 310
Denver, CO 80202
Re: CPF No. 4-2015-1007
Dear Mr. Bourdon:
Enclosed please find the Final Order issued in the above-referenced case. It makes one finding
of violation, assesses a civil penalty of $17,300, and specifies actions that need to be taken by
American 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, Southwest Region, this
enforcement action will be closed. Service of the Final Order by certified mail is deemed
effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Rodrick M. Seeley, Director, Southwest Region, OPS
Mr. Ryan M. Newburn, Vice President and Assistant General Counsel, American
Midstream Partners, LP
CERTIFIED MAIL - RETURN 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 )
)
American Midstream Partners, LP, ) CPF No. 4-2015-1007
)
Respondent. )
____________________________________)
FINAL ORDER
On June 16-23, 2014, pursuant to 49 U.S.C. § 60117, a representative 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 American
Midstream Partners, LP (American Midstream or Respondent) in Houston, Texas. American
Midstream operates approximately 2,300 miles of pipeline and pipeline facilities that gather and
transport natural gas and link producers and suppliers to natural gas markets. 1 American
Midstream also owns approximately 1.7 million barrels of storage capacity across four
terminals.2
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated April 20, 2015, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the
Notice proposed finding that American Midstream had violated 49 C.F.R. § 192.631, and
proposed assessing a civil penalty of $17,300 for the alleged violation. The Notice also proposed
ordering Respondent to take certain measures to correct the alleged violation.
American Midstream was granted a 30-day extension to respond to the Notice and responded by
letter dated June 26, 2015 (Response). The company contested the allegation, offered an
explanation in response to the Notice, and requested that the proposed civil penalty be reduced.
Respondent did not request a hearing and therefore has waived its right to one.
FINDING OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows:
1 Pipeline Safety Violation Report (Violation Report), (April 20, 2015) (on file with PHMSA), at 1.
2 Id.



CPF No. 4-2015-1007
Page 2
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.631(j)(1), which states:
§ 192.631 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. § 192.631(j)(1) by failing to provide
records sufficient to demonstrate compliance with the requirements of § 192.631(c), (d), and (e).
The requirements of 49 C.F.R. § 192.631 are, in relevant part:
§ 192.631 Control room management
(a) . . . .
(c) Provide adequate information. Each operator must provide its controllers
with the information, tools, processes and procedures necessary for the controllers
to carry out the roles and responsibilities the operator has defined by performing
each of the following:
(1) …
(2) Conduct a point-to-point verification between 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;
(3) Test and verify an internal communication plan to provide adequate
means for manual operation of the pipeline safely, at least once each calendar
year, but at intervals not to exceed 15 months;
(4) Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months . . .
(d) Fatigue mitigation. Each operator must implement the following methods
to reduce the risk associated with controller fatigue that could inhibit a
controller’s ability to carry out the roles and responsibilities the operator has
defined:
(1) . . .
(3) Train controllers and supervisors to recognize the effects of fatigue . . .
(e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator’s plan must include provisions to:
(1) . . .
(4) Review the alarm management plan required by this paragraph at least
once each calendar year, but at intervals not exceeding 15 months, to determine
the effectiveness of the plan. . .
Specifically, the Notice alleged that American Midstream’s procedures specify its records
retention will be between three to five years. American Midstream was able to provide some



CPF No. 4-2015-1007
Page 3
records for 2011 and few records for 2014. There were no records provided for the period
between 2012 and 2013. PHMSA reviewed the records and found them insufficient to
demonstrate compliance with the requirements of § 192.631(c), (d), and (e).
In its Response, American Midstream asserted that it understood the inspector’s request to be
limited to training records. Additionally, at the time of the inspection, American Midstream was
in the process of revising its SCADA system, which impacted the type of documents that were
available. Respondent stated that it provided hard copy documents for review that included
documents from 2013, but also acknowledged that certain records were unavailable at the time of
inspection.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 192.631(j) by failing to provide records sufficient to demonstrate compliance with the
requirements of § 192.631(c), (d), and (e) in that there were systematic documentation and
record retention issues indicated by the inspection. Moreover, Respondent admitted that records
were missing.
This finding of violation will be considered a prior offense 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. 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; and 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 $17,300 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $17,300 for Respondent’s violation of 49 C.F.R.
§ 192.631(j)(1) for failing to provide records sufficient to demonstrate compliance with the
requirements of § 192.631(c), (d), and (e). American Midstream requested that the proposed
penalty be reduced based on a lower degree of culpability. American Midstream asserted that at
the time of inspection, it provided documents for hard copy review, including documents from
2013. Respondent further asserted the 2013 documents contained sufficient information to meet
the training requirements of 49 C.F.R. § 192.631(h); however, the Notice did not allege
documentation was missing for demonstrating compliance with § 192.631(h). The 2013 records
were not submitted with American Midstream’s Response, but even if they had been found and
submitted, there was still additional missing documentation. American Midstream also stated it
understood the inspector’s request to be limited to training records; however, the inspection



CPF No. 4-2015-1007
Page 4
covered all aspects of the Control Room Management program and regulations. Respondent
stated it was in the process of revising its SCADA system which impacted the type of documents
that were available. Furthermore, American Midstream made several claims that relevant
documents were available at the time of the inspection, but has not submitted any of those
records. Even assuming those documents were submitted, Respondent admitted throughout its
Response that certain issues affected its ability to maintain some records, exercises were not
properly documented, and certain specific documentation may not have been maintained. These
admissions demonstrate Respondent failed to take appropriate action to comply with a clearly
applicable requirement. I therefore find reducing the proposed penalty based on American
Midstream’s level of culpability is not justified.
American Midstream stated that it has made several changes to ensure correct records are
capable of being produced, are kept up to date, and are retained. While it is commendable that
Respondent has taken these steps, good faith actions in consideration of reducing the proposed
civil penalty are not those that take place after the violation. Accordingly, having reviewed the
record and considered the assessment criteria, I assess Respondent a civil penalty of $17,300 for
violation of 49 C.F.R. § 192.631(j)(1).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $17,300.
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,
6500 S MacArthur Blvd., Oklahoma City, Oklahoma 79169. The Financial Operations Division
telephone number is (405) 954-8845.
Failure to pay the $17,300 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 Item 1 in the Notice for violations of 49
C.F.R. § 192.631(j). Under 49 U.S.C. § 60118(a), each person who engages in the transportation
of gas or who owns or operates a pipeline facility is required to comply with the applicable
safety standards established under chapter 601. 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:



CPF No. 4-2015-1007
Page 5
1. With respect to the violation of § 192.631(j)(1) (Item 1), Respondent must:
A. Review the company’s procedures and add specifics as to how they will
maintain these records. The procedures should make reference to the forms to
be used (with an appropriate numbering or naming system). The procedures
should also specify who is responsible for completing and maintaining the
documentation; and
B. Submit Item A no later than 60 days from the issuance of the Final Order in
this case; and
C. Following the acceptance of Item A, Respondent should perform the
appropriate activities and complete the documentation to demonstrate
compliance with § 192.631 and forward the appropriate records to PHMSA;
and
D. Submit Item C no later than 180 days from the issuance of the Final Order in
this case.
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.
In addition, pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217,
Respondent is requested (not mandated) to take the following action:
American Midstream should maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to Mr. Rodrick.
M. Seeley, Director, Southwest Region, 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.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000 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.
Under 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: 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. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief 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. Unless the Associate Administrator, upon request, grants a stay, all



CPF No. 4-2015-1007
Page 6
other terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
November 15, 2016
___________________________________ __________________________
Alan K. Mayberry Date Issued
Acting Associate Administrator
for Pipeline Safety

420151007_Closure Letter_01122018_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 12, 2018
Mr. Steve Bergstrom
Executive Chairman, President and Chief Executive Officer
American Midstream Partners, LP
1400 16th Street, Suite 310
Denver, CO 80202
CPF 4-2015-1007
Dear Mr. Bergstrom:
From June 16, 2014 through June 23, 2014, representatives from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
conducted a Control Room Management inspection of American Midstream Partners, LP
(AMID) in Houston, TX. As a result of the inspection AMID was issued a to Notice of Probable
Violation (NOPV) and Proposed Compliance Order and Notice of Amendment (NOA) on April
20, 2015, which proposed amendment of your procedures and submission of records for the
amended procedures.
AMID submitted its amended procedures on March 15, 2017. Also, AMID submitted the
appropriate records with respect to the amended procedures on October 3, 2017 and were in
compliance. My staff reviewed the documents and it appears that the inadequacies outlined in this
Notice of Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Terri J. Binns
Acting Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

420151007_NOPV PCP PCO_04202015_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 20, 2015
Mr. Steve Bergstrom
Executive Chairman, President and Chief Executive Officer
American Midstream Partners LP
1400 16th Street, Suite 310,
Denver, CO 80202
CPF 4-2015-1007
Dear Mr. Bergstrom:
On June 16 - 23, 2014, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Control Room Management Program in Houston, TX.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
1. §192.631 Control room management.
(j) Compliance and deviations. An operator must maintain for review during
inspection:
(1) Records that demonstrate compliance with the requirements of this section



§ 192.631 Control room management.
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(2) Conduct a point-to-point verification between 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;
(3) Test and verify an internal communication plan to provide adequate means
for manual operation of the pipeline safely, at least once each calendar year, but
at intervals not to exceed 15 months;
(4) Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months;
(d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controller's
ability to carry out the roles and responsibilities the operator has defined:
(3) Train controllers and supervisors to recognize the effects of fatigue;
(e) Alarm management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms. An
operator's plan must include provisions to:
(4) Review the alarm management plan required by this paragraph at least once
each calendar year, but at intervals not exceeding 15 months, to determine the
effectiveness of the plan;
During the inspection of American Midstream Partners’ (American) Control Room Management
program PHMSA reviewed American’s procedures and asked to see documentation to
demonstrate compliance with the regulations. American’s procedures specify the records
retention will be between three to five years. American was able to provide some records for
2011 and a few for 2014. There were no records provided for the period between 2012 and
2013. PHMSA reviewed these records and found them insufficient to demonstrate compliance
with the requirements of §192.631(c), (d) and (e).
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 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 $17,300.
2



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 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). 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.
In your correspondence on this matter, please refer to CPF 4-2015-1007 and for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
3



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to American Midstream a Compliance Order
incorporating the following remedial requirements to ensure the compliance of American
Midstream with the pipeline safety regulations:
Item 1: In regards to item Number 1 of the Notice pertaining to maintaining records for
demonstrating compliance with the 192.631 American Midstream must review their procedures
and add specifics as to how they will maintain these records. The procedures should make
reference to the forms to be used (with an appropriate numbering or naming system). The
procedures should also specify who is responsible for completing and maintaining the
documentation.
Item 2: These revised procedures should be forwarded to PHMSA within 60 days of the date of
the final order.
Item 3: Following the acceptance of the revised procedures American Midstream should
perform the appropriate activities and complete the documentation to demonstrate compliance
with 192.631 and forward the appropriate records to PHMSA.
Item 4: The activities should be competed and the records demonstrating compliance should be
forwarded to PHMSA with 180 days of the final order.
Item 5: It is requested (not mandated) that American Midstream maintain documentation of the
safety improvement costs associated with fulfilling this Compliance Order and submit the total to
R. M. Seeley, Director, Southwest Region, 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.
4

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420151007>
- Source ID: `phmsa-enforcement`
- SHA-256: `7fe5070dca860868ed347008f0344ca1b376fefc001925744aa8858a54c6dc80`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T07:59:58.194Z
- Document slug: `phmsa-enforcement-420151007`

### Source metadata

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```