{"operation":"document","citation":"CPF 220191003","title":"DESTIN PIPELINE COMPANY, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-12-18","effective_on":null,"summary":"CLOSED notice of probable violation citing 191.22(c)(2)(i), 192.491(c), 192.616(a), 192.616(b), 192.805(b), 192.805(c), 192.805(g), 192.905(a), 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220191003.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220191003.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220191003","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220191003","body":"Notice of Probable Violation involving DESTIN PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 191.22(c)(2)(i),  192.491(c),  192.616(a),  192.616(b),  192.805(b),  192.805(c),  192.805(g),  192.905(a),  192.947(d). The case was opened on 2019-12-18 and is reported as closed as of 2022-03-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220191003_Closure Letter_03092022_(17-157329S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_Closure%20Letter_03092022_(17-157329S).pdf\n\n220191003_Closure Letter_03092022_(17-157329S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_Closure%20Letter_03092022_(17-157329S)_text.pdf\n\n220191003_Final Order_04102020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_Final%20Order_04102020.pdf\n\n220191003_Final Order_04102020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_Final%20Order_04102020_text.pdf\n\n220191003_NOPV PCO (Revised)_02052020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_NOPV%20PCO%20(Revised)_02052020.pdf\n\n220191003_NOPV PCO (Revised)_02052020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_NOPV%20PCO%20(Revised)_02052020_text.pdf\n\n220191003_NOPV PCO_12182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_NOPV%20PCO_12182019.pdf\n\n220191003_NOPV PCO_12182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_NOPV%20PCO_12182019_text.pdf\n\n220191003_Operator Response to Notice_03052020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191003/220191003_Operator%20Response%20to%20Notice_03052020.pdf\n\n220191003_NOPV PCO (Revised)_02052020_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nFEDERAL EXPRESS – SIGNATURE CONFIRMATION REQUESTED\nFebruary 5, 2020\nMr. Matt Rowland\nPresident and Chief Executive Officer\nThird Coast Midstream, LLC\n1501 McKinney St.\nSuite 800\nHouston, TX 77010\nCPF 2-2019-1003\nDear Mr. Rowland:\nBetween February 26, 2018 and May 3, 2018, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) inspected Destin Pipeline Company, LLC’s (Destin)\nrecords and procedures in Houston, Texas, and Destin’s records and pipeline facilities in\nMississippi. Third Coast Midstream, LLC (TCM) is the parent company and majority owner of\nAmerican Midstream, LLC (AMID) and Destin.\nAs a result of the inspection, it is alleged that Destin has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §191.22 National Registry of Pipeline and LNG Operators.\n(a) …\n(c) Changes. Each operator of a gas pipeline, gas pipeline facility, underground natural\ngas storage facility, LNG plant, or LNG facility must notify PHMSA electronically\n\n\n\nthrough the National Registry of Pipeline, Underground Natural Gas Storage Facility,\nand LNG Operators at http://opsweb.phmsa.dot.gov of certain events.\n(1) …\n(2) An operator must notify PHMSA of any of the following events not later than 60\ndays after the event occurs:\n(i) A change in the primary entity responsible (i.e., with an assigned OPID) for\nmanaging or administering a safety program required by this part covering pipeline\nfacilities operated under multiple OPIDs.\nDestin failed to notify PHMSA not later than 60 days after a change in the primary entity\nresponsible for managing or administering a safety program required by this part covering\npipeline facilities operated under multiple OPIDs.\nAMID became the primary entity responsible for managing or administering the safety\nprograms for Destin Pipeline as of November 1, 2016, as reported on the divestiture\nnotification information submitted by the previous operator of Destin, BP Pipelines (North\nAmerica) Inc. (BP). Destin was required to notify PHMSA by December 31, 2016, 60 days\nafter the effective date of the change in the primary responsible entity.\nDestin submitted the Type C – Shared Safety Program Change notification on April 30,\n2018, exceeding the required notification date of December 31, 2016 by four hundred eighty-\nfive (485) days.\n2. §192.491 Corrosion control records.\n(a) …\n(c) Each operator shall maintain a record of each test, survey, or inspection required by\nthis subpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that a corrosive condition does not exist. These records must be retained\nfor at least 5 years, except that records related to §§192.465(a) and (e) and 192.475(b)\nmust be retained for as long as the pipeline remains in service.\nDestin failed to maintain records of each test, survey, or inspection required by Part 192,\nsubpart I, in sufficient detail to demonstrate the adequacy of corrosion control measures or\nthat a corrosive condition does not exist.\nDuring the inspection, the PHMSA inspector reviewed records documenting Destin’s annual\ncathodic protection (CP) surveys. Review of records documenting the 2016 annual CP\nsurvey revealed remarks of \"Cannot find” at 15 pipe-to-soil (p/s) potential test stations.\nFurther review of records documenting the subsequent 2017 annual CP survey include p/s\npotential readings at each of the referenced 15 test points, and do not include a remark of\n“Cannot find,” indicating the existence of these 15 stations.\n3. §192.616 Public awareness.\n(a) Except for an operator of a master meter or petroleum gas system covered under\nparagraph (j) of this section, each pipeline operator must develop and implement a\nwritten continuing public education program that follows the guidance provided in the\nAmerican Petroleum Institute’s (API) Recommended Practice (RP) 1162 (incorporated\nby reference, see § 192.7).\n2\n\n\n\n(b) The operator's program must follow the general program recommendations of API\nRP 1162 and assess the unique attributes and characteristics of the operator's pipeline\nand facilities.\nDestin failed to assess the unique attributes and characteristics of its pipeline and facilities in\nits Public Awareness (PA) Program baseline message brochures. Destin transports natural\ngas and it uses the AMID PA Program.\nIn 2015 and in 2016, AMID on behalf of Destin sent (or otherwise delivered) generic\nbaseline message brochures to the affected public, excavators, emergency responders, and\npublic officials that did not identify the product transported by Destin as natural gas, and did\nnot describe the unique attributes and characteristics of natural gas or a pipeline transporting\nnatural gas.\n4. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) …\n(g) Identify those covered tasks and the intervals at which evaluation of the individual’s\nqualifications is needed; and\nDestin failed to follow the provisions of its written qualification program to determine the\nintervals at which evaluation of certain covered tasks was needed. Destin uses the AMID\nOperator Qualification (OQ) Program as its written qualification program.\nSection 2.4 of the AMID OQ Plan contains requirements to establish re-evaluation intervals\nusing a DIF analysis, based on each task’s difficulty, importance, and frequency of\nperformance. The AMID OQ Plan requires a rating of 1-5 be assigned to difficulty,\nimportance, and frequency for each covered task. These values are then used to determine a\nre-evaluation interval based on a decision tree included in the above-referenced Section\n(Figure 2.4.2-1). The values of difficulty, importance, frequency and the established re-\nevaluation intervals are listed in Appendix 2.1 of the AMID OQ Plan, titled “Covered Task\nList with Re-Evaluation Interval and Span of Control.”\nPHMSA’s inspection revealed multiple examples of re-evaluation intervals that were not\nestablished in accordance with the DIF analysis procedure described in Section 2.4 of the\nAMID OQ Plan.\n5. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) …\n(b) Ensure through evaluation that individuals performing covered tasks are qualified;\nDestin failed to comply with § 192.805(b) because the company’s written qualification\nprogram did not include adequate provisions to ensure through evaluation that individuals\nperforming covered tasks are qualified. As noted above, Destin uses the AMID OQ Program\nas its written qualification program.\n3\n\n\n\nAt the time of PHMSA’s inspection, the AMID OQ Program relied on evaluation material\nfrom three OQ service providers. PHMSA’s review of the AMID OQ Program identified\nseveral instances where the evaluation material from each of the three service providers was\ninadequate to evaluate an individual’s knowledge, skill and ability to perform a given\ncovered task. Specifically, accepted evaluations for multiple covered tasks were identified\nthat referenced material not applicable to the given covered task, or contained an insufficient\nnumber of questions pertinent to the covered task. Moreover, PHMSA’s review revealed\nseveral instances of accepted performance evaluations which were irrelevant to the task for\nwhich they were intended to demonstrate an individual’s ability to perform the covered\ntask(s).\n6. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) …\n(c) Allow individuals that are not qualified pursuant to this subpart to perform a\ncovered task if directed and observed by an individual that is qualified;\nDestin failed to comply with § 192.805(c) because the company’s OQ program did not\ninclude adequate provisions to allow individuals that are not qualified to perform an OQ\ncovered task under the direction and observation of a qualified individual. As noted above,\nDestin uses the AMID OQ Program as its written qualification program.\nAt the time of the inspection, the PHMSA inspector noted several covered tasks in the AMID\nOQ Program with spans-of-control for multiple non-qualified individuals to be observed by a\nsingle qualified individual not suited to the specific task. It should be noted that during an\nAugust 2014 PHMSA inspection of the AMID OQ Plan, the issue of excessive\nspan-of-control values was raised by the PHMSA inspector. At that time, the AMID OQ\nPlan Administrator agreed to change all spans-of-control to 1:1, except for maintenance\nwelding which was changed to 1:0. A revised AMID OQ Program was submitted at the end\nof the 2014 inspection to demonstrate the changes.\n§192.905 How does an operator identify a high consequence area?\n(a) General. To determine which segments of an operator's transmission pipeline\nsystem are covered by this subpart, an operator must identify the high consequence\nareas. An operator must use method (1) or (2) from the definition in §192.9031 to\nidentify a high consequence area. An operator may apply one method to its entire\npipeline system, or an operator may apply one method to individual portions of the\npipeline system. An operator must describe in its integrity management program which\nmethod it is applying to each portion of the operator's pipeline system. The description\nmust include the potential impact radius when utilized to establish a high consequence\narea. (See appendix E.I. for guidance on identifying high consequence areas.)\n1 Excerpt of the definition of High consequence area in §192.903: [w]here a potential impact circle is calculated\nunder either method (1) or (2) to establish a high consequence area, the length of the high consequence area\nextends axially along the length of the pipeline from the outermost edge of the first potential impact circle that\ncontains either an identified site or 20 or more buildings intended for human occupancy to the outermost edge of the\nlast contiguous potential impact circle that contains either an identified site or 20 or more buildings intended for\nhuman occupancy. (See Figure E.I.A. in Appendix E.)\n4\n7.\n\n\n\n8. Destin failed to include information required per the definition of a High Consequence Area\n(HCA), as defined in §192.903.\nDestin used method 2 to establish the HCAs along its pipeline. Under 49 C.F.R. §192.903,\nmethod 2 is defined as:\n(2) The area within a potential impact circle containing—\n(i) 20 or more buildings intended for human occupancy, unless the exception in\nparagraph (4) applies; or\n(ii) An identified site.\nDestin did not include the length of HCAs which extends axially along the length of the\npipeline from the outermost edge of the first potential impact circle that contains either an\nidentified site or 20 or more buildings intended for human occupancy to the outermost edge\nof the last contiguous potential impact circle that contains either an identified site or 20 or\nmore buildings intended for human occupancy, as required per §192.903.\nIn response to the probable violations discovered during the PHMSA inspection, on\nApril 4, 2018, Destin submitted to PHMSA a revised supplemental 2017 Annual Report and\nrevised 2017 Pipeline System Summary HCAs which reflected corrected HCA mileages after\nproperly applying the above-referenced requirements of §192.903.\n§192.947 What records must an operator keep?\nAn operator must maintain, for the useful life of the pipeline, records that demonstrate\ncompliance with the requirements of this subpart. At minimum, an operator must\nmaintain the following records for review during an inspection.\n… (d) Documents to support any decision, analysis and process developed and used to\nimplement and evaluate each element of the baseline assessment plan and integrity\nmanagement program. Documents include those developed and used in support of any\nidentification, calculation, amendment, modification, justification, deviation and\ndetermination made, and any action taken to implement and evaluate any of the\nprogram elements;\nDestin failed to comply with the regulation because it did not maintain, for the useful life of\nthe pipeline, records to support their decisions, analysis and processes developed and used to\nimplement and evaluate each element of the integrity management program. Specifically,\nDestin personnel were not able to produce the following records to support BP’s and AMID’s\ndecisions, analyses, and processes used to implement and evaluate each element of the\nintegrity management program:\n In-line inspection (ILI) tool validation records for reassessments conducted in October\n2013 and November 2014 (36\" Sandhill Compressor Station to Pascagoula Gas Plant\nLine and 16\" Pascagoula Gas Plant to Chevron Refinery Line, respectively). Section\n192.947(c)(1) requires operators to follow Section 6.2 of ASME/ANSI B31.8S when\nselecting the appropriate ILI tool. Section 6.2.5 of ASME/ANSI B31.8S requires\noperators to assess the general reliability of the ILI method by considering the confidence\nlevel of the ILI method (e.g., probability of detecting, classifying, and sizing the\nanomalies). During PHMSA’s inspection, Destin personnel were unable to produce\n5\n\n\n\nrecords of such validations of the above-referenced October 2013 and November 2014\nreassessments.\n Records documenting Destin’s decision to reduce HCA mileage. During PHMSA’s\nrecords review, it was noted that Destin reported 10.5 miles of HCAs in its 2016 Annual\nReport versus 1.89 miles in its 2017 Original Annual Report and 2.28 in its 2017\nSupplemental Annual Report. This decision followed a review of HCAs after transfer of\nownership of the pipeline from BP to AMID in 2016. The PHMSA inspectors noted this\nchange in HCA mileage during their records review during the week of April 30, 2018.\nAMID’s Management of Change Report, Form 11.1, documenting the decision and\nreason for the HCA mileage change, was not submitted to PHMSA until May 1, 2018.\nProposed Compliance Order\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a\nrelated series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring\nprior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per\nday, with a maximum penalty not to exceed $2,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to propose a civil penalty assessment at this time.\nWith respect to Items 5 and 6, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Destin Pipeline\nCompany, LLC. Please refer to the Proposed Compliance Order, which is enclosed and made a\npart of this Notice.\nWarning Items\nWith respect to Items 1, 2, 3, 4, 7, and 8, we have reviewed the circumstances and supporting\ndocuments involved in this case and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to promptly correct these items.\nFailure to do so may result in additional enforcement action.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. All\nmaterial submit in response to this enforcement action may be made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\n6\n\n\n\nFollowing the receipt of this Notice, you have 30 days to submit written comments, or request a\nhearing under 49 CFR § 190.211. If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order. If you are responding to this Notice, we propose that\nyou submit your correspondence to my office within 30 days from the receipt of this Notice.\nThis period may be extended by written request for good cause.\nIn your correspondence on this matter, please refer to CPF 2-2019-1003 and, for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n7\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Destin Pipeline Company, LLC (Destin Pipeline)\na Compliance Order incorporating the following remedial requirements to ensure the compliance\nof Destin Pipeline with the pipeline safety regulations:\n1. 2. 3. 4. In regard to Item Number 5 of the Notice pertaining to evaluation of individuals performing\ncovered tasks, Destin Pipeline must:\na. Review all written, electronic and oral examinations to assure they contain a sufficient\nnumber of questions with sufficient detail and complexity to establish an individual’s\nknowledge of the given covered task.\nb. Review all performance verification materials to assure they provide for actual\nperformance of the covered task.\nc. Replace, modify or supplement all evaluation material to assure the material will\nadequately establish an individual’s knowledge, skill and ability to perform a covered\ntask properly.\nIn regard to Item Number 6 of the Notice pertaining to Destin Pipeline’s failure to include\nadequate provisions to allow individuals that are not qualified to perform an OQ covered task\nunder the direction and observation of a qualified individual, Destin Pipeline must review\nand update the span of control limits for all covered tasks included in its OQ Program to\nensure each’s appropriateness and effectiveness.\nDestin Pipeline must complete the above items within the following time requirements:\na. Within 90 days of issuance of the Final Order, Destin Pipeline must complete the\nrequirements of Numbers 1a, 1b, and 1c of proposed compliance order above. Destin\npipeline must submit to the Director, Office of Pipeline Safety, PHMSA Southern\nRegion, a list of all covered tasks with evaluation material that was replaced, modified, or\nsupplemented.\nb. Within 90 days of issuance of the Final Order, Destin Pipeline must complete the\nrequirements of Number 2 of proposed compliance order above. Destin pipeline must\nsubmit to the Director, Office of Pipeline Safety, PHMSA Southern Region, a list of\ncovered tasks reviewed and span-of-control limits that were changed.\nIt is requested (not mandated) that Destin Pipeline maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the total to\nthe Director, Office of Pipeline Safety, PHMSA Southern Region. It is requested that these\ncosts be reported in two categories: 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses, and 2) total cost associated with replacements, additions\nand other changes to pipeline infrastructure.\n8\n\n220191003_Final Order_04102020_text.pdf\n\nVIA EMAIL TO: mrowland@3cmidstream.com and rlouderman@3cmidstream.com\nMr. Matt Rowland\nPresident and Chief Executive Officer\nThird Coast Midstream, LLC\n1501 McKinney Street, Suite 800\nHouston, Texas 77010\nRe: CPF No. 2-2019-1003\nDear Rowland:\nEnclosed please find the Final Order issued in the above-referenced case to your subsidiary,\nDestin Pipeline Company, LLC. It makes findings of violation and specifies actions that need to\nbe taken to comply with the pipeline safety regulations. When the terms of the compliance order\nare completed, as determined by the Director, Southern Region, this enforcement action will be\nclosed. Service of the Final Order by e-mail is effective upon the date of mailing as provided\nunder 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA\nMs. Ronda Louderman, Senior Manager, Pipeline Transportation Compliance, Third\nCoast Midstream, LLC\nVIA EMAIL – CONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n__________________________________________\nIn the Matter of )\nDestin Pipeline Company, LLC, ) CPF No. 2-2019-1003\na subsidiary of Third Coast Midstream, LLC, )\n)\n)\n)\nRespondent. )\n__________________________________________)\nFINAL ORDER\nOn February 5, 2020, pursuant to 49 C.F.R. § 190.207, the Director, Southern Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Destin Pipeline\nCompany, LLC (Respondent). The Notice proposed finding that Respondent had violated the\npipeline safety regulations in 49 C.F.R. Parts 191 and 192. The Notice also proposed certain\nmeasures to correct the violations. Respondent did not contest the allegations of violation or\ncorrective measures.\nBased upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the\npipeline safety regulations listed below, as more fully described in the enclosed Notice, which is\nincorporated by reference:\n49 C.F.R. § 192.805(b) (Item 5) ─ Respondent failed to have and follow a written\nqualification program that ensured through evaluation that individuals performing\ncovered tasks are qualified.\n49 C.F.R. § 192.805(c) (Item 6) ─ Respondent failed to have and follow a written\nqualification program that allowed individuals that are not qualified pursuant to\nsubpart N to perform a covered task if directed and observed by an individual that\nis qualified.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nCOMPLIANCE ACTIONS\nPursuant to 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the violations. The Director may grant an\n\n\n\nCPF No. 2-2019-1003\nPage 2\nextension of time to comply with any of the required items upon a written request timely\nsubmitted by the Respondent and demonstrating good cause for an extension. Upon completion\nof ordered actions, Respondent may request that the Director close the case. Failure to comply\nwith this Order may result in the assessment of civil penalties under 49 C.F.R. § 190.223 or in\nreferral to the Attorney General for appropriate relief in a district court of the United States.\nWARNING ITEMS\nWith respect to Items 1, 2, 3, 4, 7, and 8, the Notice alleged probable violations of 49 C.F.R. §§\n191.22(c)(2)(i), 192.491(c), 192.616(a) & (b), 192.805(g), 192.905(a), and 192.947(d),\nrespectively, but did not propose a civil penalty or compliance order for these items. Therefore,\nthese are considered to be warning items. If OPS finds a violation of any of these items in a\nsubsequent inspection, Respondent may be subject to future enforcement action.\nThe terms and conditions of this order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nApril 10, 2020\n___________________________________ _________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n220191003_Closure Letter_03092022_(17-157329S)_text.pdf\n\nDELIVERY METHOD – VIA FEDERAL EXPRESS\nMarch 9, 2022\nMr. Matt Rowland\nPresident & Chief Executive Officer\nThird Coast, LLC\n1501 McKinney St., Suite 800\nHouston, TX 77010\nCPF 2-2019-1003\nDear Mr. Rowland:\nBetween February 26, 2018 and May 3, 2018, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected Destin Pipeline Company, LLC’s (Destin)\nrecords and procedures in Houston, Texas and Destin’s records and pipeline facilities in\nMississippi, pursuant to Chapter 601 of 49 United States Code. Third Coast, LLC (TC) is the\nparent company and majority owner of American Midstream, LLC (AMID) and Destin. As a\nresult of the inspection PHMSA issued a Notice of Probable Violation and Proposed Compliance\nOrder on February 5, 2020 and a Final Order on April 8, 2020.\nTC submitted its responses from May 5, 2020 through February 9, 2022. PHMSA has reviewed\nTC’s responses and determined that TC has complied with the terms of the Final Order.\nThis letter is to inform you no further action is necessary, and this case is now closed.\nPlease be advised that this letter refers only to the referenced case (CPF 2-2019-1003) and not to\nany other PHMSA cases, if any.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":27753}