EL PASO FIELD SERVICES — Notice of Probable Violation

120025008_final order_12222003_text.pdf, page 1Official PDFUS Department of Transportation Research and Special Pregrams Administration 400 Seventh St S W Washington DC 20590 Mr Robert G. Philhps President El Paso Field Services, L. P. 4 Greenway Plaza Houston, TX 77046 Re: CPF No. 1-2002-5008 Dear Mr. Phillips: Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in the above-referenced case. It makes a finding of violation and finds that you have completed the corrective actions proposed in the Notice. The Final Order also finds that you have addressed the inadequacies in your procedures cited in the Notice. This case is now closed. Your receipt of the Final Order constitutes service of that document under 49 C. F. R. ) 190. 5. Sincerely, James Reynolds Pipeline Comphance Registry Office of Pipeline Safety Enclosure CERTIFIED MAIL — RETURN RECEIPT RE UESTED#

120025008_final order_12222003_text.pdf, page 2DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, DC 20590 In the Matter of El Paso Field Services, L. P. , Respondent. CPF No. 1-2002-5008 FINAL ORDER On March 25-26, 2002, pursuant to 49 U. S C ) 60117, representatives of the Eastern and Central Regions, Office of Pipehne Safety (OPS) inspected El Paso Field Service, L. P 's (Respondent's) integrity management program at Respondent's facihty in Houston, Texas. As a result of the inspection, the Director, Eastern Region, OPS, issued to Respondent, by letter dated July 3, 2002, a Notice of Probable Violation, Proposed Comphance Order, and Notice of Amendment (Notice). In accordance with 49 C F R. ) 190. 207, the Notice proposed finding that Respondent had violated 49 C. F. R. $ 195 452(b)(2) and proposed that Respondent take certain measures to correct the alleged violation. The Notice also alleged inadequacies in Respondent's integrity management program and proposed to require amendment of Respondent's procedures to comply with the requirements of 49 C. F. R. ) 195 452(b)(2) Respondent responded to the Notice by letter dated July 25, 2002 (Response). Respondent did not contest the allegations of violation but provided information concerning the corrective actions it planned to take. In addition, Respondent stated that it would amend its procedures to address procedural inadequacies alleged in the Notice by October 8, 2002. Respondent did not request a hearing, and therefore has waived its right to one. FINDING OF VIOLATION In its Response, Respondent did not contest the alleged violations in the Notice. Accordingly, I find that Respondent violated the following section of 49 C. F R Part 195, as more fully described in the Notice 49 C. F. R. ) 195 452(b)(2) — faihng to complete identification of pipeline segments that could affect a high consequence area by December 31, 2001 Respondent failed to evaluate ten miles of regulated inter-plant hnes near Corpus Christ, Texas. This findmg of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent#

120025008_final order_12222003_text.pdf, page 3COMPLIANCE ORDER The Notice proposed a comphance order with respect to the violation of 49 C. F. R. ) 195. 452(b)(2). Under 49 U. S. C. ( 60118(a), each person who engages in the transportation ofhazardous hquids or who owns or operates a pipehne facility is required to comply with the applicable safety standards estabhshed under chapter 601. The Director, Eastern Region, OPS has indicated that Respondent has taken the following action specified in the proposed compliance order: Respondent performed a high consequence area impact analysis on the ten miles of regulated inter-plant hnes near Corpus Christi, Texas Accordingly, since comphance has been achieved with respect to these violations, the comphance terms are not included in this Order. AMENDMENT OF PROCEDURES In addition to the cited violation, the Notice alleged inadequacies in Respondent's integrity management program procedures and proposed to require amencbnent of Respondent's procedures to comply with the requirements of 49 C. F. R. $ 195. 452(b)(2). On October 4, 2002, Respondent submitted copies of its amended procedures, which the Director, Eastern Region, OPS reviewed. Accordingly, based on the results of this review, I find that Respondent's original procedures as described in the Notice were inadequate to ensure safe operation of its pipehne system, but that Respondent has corrected the identified inadequacies. Respondent need not take any further action with respect to the inadequacy cited in the Notice. No need exists to issue an order directing amendment. ) ~(~. &/cg Date Issued , Stacey Ggr Associate A nistrator for Pip ne Safety#