# EL PASO FIELD SERVICES — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120025008
- **title:** EL PASO FIELD SERVICES — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2002-07-03
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.452(b)(2).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120025008
**body:**

Notice of Probable Violation involving EL PASO FIELD SERVICES. PHMSA's enforcement data identifies the cited regulation as 195.452(b)(2). The case was opened on 2002-07-03 and is reported as closed as of 2003-12-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120025008_Final Order_12222003.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120025008/120025008_Final%20Order_12222003.pdf

120025008_final order_12222003_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120025008/120025008_final%20order_12222003_text.pdf

120025008_final order_12222003_text.pdf

US 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



DEPARTMENT 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



COMPLIANCE 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
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