# DCP MIDSTREAM — Notice of Amendment

**Citation:** CPF 520175010M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-06-26

CLOSED notice of amendment citing 195.402(c)(3).

## Document text

Notice of Amendment involving DCP MIDSTREAM. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2017-06-26 and is reported as closed as of 2017-10-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520175010M_Closure Letter_10062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Closure%20Letter_10062017.pdf

520175010M_Closure Letter_10062017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Closure%20Letter_10062017_text.pdf

520175010M_Notice of Amendment_06262017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Notice%20of%20Amendment_06262017.pdf

520175010M_Notice of Amendment_06262017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Notice%20of%20Amendment_06262017_text.pdf

520175010M_Operator Response to Notice_07242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Operator%20Response%20to%20Notice_07242017.pdf

520175010M_Closure Letter_10062017_text.pdf

VIA FED EX – TRACKING NO. 7704 3810 0713
October 6, 2017
Mr. Jerry Barnhill
Senior Vice President
EHS and Pipeline Services
DCP Operating Company, LP
(Formerly named DCP Midstream, LP)
370 17th Street
Denver, CO 80202
CPF 5-2017-5010M
Closure Letter
Dear Mr. Barhill:
From September 2016 through March 2017, a representative from the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,
conducted an on-site pipeline safety inspection of DCP Operating Company’s (DCP)
procedures in Colorado and Kansas. As a result of the inspection, DCP was issued a Notice
of Amendment on June 26, 2017, which proposed amendment of your procedures.
DCP submitted its amended procedures on July 24, 2017. My staff reviewed the amended
procedures, 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,
Dustin Hubbard
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 C. Allen (#152397)

520175010M_Notice of Amendment_06262017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 26, 2017
Mr. Jerry Barnhill
Senior Vice President
EHS and Pipeline Services
DCP Midstream
370 17th Street
Denver, CO 80202
CPF 5-2017-5010M
Dear Mr. Barnhill:
From September 2016 through March 2017, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected DCP
Midstream’s (DCPM) procedures for the Wattenberg to Bushton HVL System in Colorado and
Kansas.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within DCPM’s
plans or procedures, as described below:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety during maintenance
and normal operations:
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of
the requirements of this subpart and subpart H of this part.
DCP Midstream (DCPM) did not establish adequate written external corrosion control procedures to
address the circumstances in which is a close-interval survey or comparable technology is practicable
in accordance with §195.573(a)(2). At the time of the inspection, it was noted that DCPM’s external
corrosion control procedures for identifying a close-interval survey (CIS) or comparable technology



only apply for the new pipeline construction within 2 years or the preventive and mitigative measures
activities for segments that could affect a high-consequence area. Therefore, DPCM must modify their
procedure to describe the circumstances in which a close-interval survey or comparable technology is
practicable and necessary to accomplish the objectives of paragraph 10.1.1.3 of NACE SP 0169 for all
the pipelines in accordance with §195.573(a)(2).
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all material
you submit in response to this enforcement action is subject to being 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 the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §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 an Order Directing Amendment. If your plans or procedures
are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures
to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose
that you submit your amended procedures to my office within 30 days of receipt of this Notice. This
period may be extended by written request for good cause. Once the inadequacies identified herein
have been addressed in your amended procedures, this enforcement action will be closed.
It is requested (not mandated) that DCP Midstream maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)
and submit the total to Dustin Hubbard, Acting Director, Western Region, Pipeline and Hazardous
Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-
2017-5010M and, for each document you submit, please provide a copy in electronic format whenever
possible.
Sincerely,
Dustin Hubbard
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 C. Allen (#152397)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520175010M>
- Source ID: `phmsa-enforcement`
- SHA-256: `c7cb3d5367298d298d06257223c90354fada882862e547c69fe2f5f7151e64e2`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T21:23:19.415Z
- Document slug: `phmsa-enforcement-520175010m`

### Source metadata

```json
{
  "cpf": "520175010M",
  "operator": "DCP MIDSTREAM",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.402(c)(3)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
  "attachments": [
    {
      "name": "520175010M_Closure Letter_10062017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Closure%20Letter_10062017.pdf",
      "bytes": 34679,
      "category": "agency_document"
    },
    {
      "name": "520175010M_Closure Letter_10062017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Closure%20Letter_10062017_text.pdf",
      "bytes": 76696,
      "category": "agency_document"
    },
    {
      "name": "520175010M_Notice of Amendment_06262017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Notice%20of%20Amendment_06262017.pdf",
      "bytes": 99487,
      "category": "agency_document"
    },
    {
      "name": "520175010M_Notice of Amendment_06262017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Notice%20of%20Amendment_06262017_text.pdf",
      "bytes": 85750,
      "category": "agency_document"
    },
    {
      "name": "520175010M_Operator Response to Notice_07242017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520175010M/520175010M_Operator%20Response%20to%20Notice_07242017.pdf",
      "bytes": 80096,
      "category": "party_submission"
    }
  ],
  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "DCP MIDSTREAM"
}
```
