# SUMMIT MIDSTREAM PARTNERS, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 320175001M
- **title:** SUMMIT MIDSTREAM PARTNERS, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-01-04
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.402(c)(12), 195.440(c).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320175001M
**body:**

Notice of Amendment involving SUMMIT MIDSTREAM PARTNERS, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(12),  195.440(c). The case was opened on 2017-01-04 and is reported as closed as of 2017-01-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320175001M_Notice of Amendment_01042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175001M/320175001M_Notice%20of%20Amendment_01042017.pdf

320175001M_Notice of Amendment_01042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175001M/320175001M_Notice%20of%20Amendment_01042017_text.pdf

320175001M_Notice of Amendment_01042017_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 4, 2017
Mr. Rene Casadaban, Chief Operating Officer
Summit Midstream Partners, LLC
1800 One Hughes Landing Blvd., Suite 300
The Woodlands, TX 77380
CPF 3-2017-5001M
Dear Mr. Casadaban:
On April 5-7, 2016, a representative of the Pipeline and Hazardous Materials Safety Administration
(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Summit Midstream Partner,
LLC’s (Summit’s) procedures for damage prevention, public awareness and operations and
maintenance in Epping, North Dakota.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Summit’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:



(12) Establishing and maintaining liaison with fire, police, and other appropriate public
officials to learn the responsibility and resources of each government organization that
may respond to a hazardous liquid or pipeline emergency and acquaint the officials with
the operator's ability in responding to a hazardous liquid or carbon dioxide pipeline
emergency and means of communication.
§195.440 Public awareness
(c) The operator must follow the general program recommendations, including baseline
and supplemental requirements of API RP 1162, unless the operator provides
justification in its program or procedural manual as to why compliance with all or
certain provisions of the recommended practice is not practicable and not necessary for
safety.
Summit’s procedures were inadequate because its Damage Prevention/Public Awareness plan dated
12-31-2013 was missing the following:
 Learn the responsibility and resources of each government organization that may respond to a
hazardous liquids pipeline emergency.
 Identify the types of pipeline emergencies of which the operator notifies the officials.
 Acquaint the officials with the operator's ability in responding to a hazardous liquids pipeline
emergency and means of communication.
 Plan how the operator and officials can engage in mutual assistance to minimize hazards to life
or property.
 Identify if any combined operator/public agency training sessions/exercises are needed.
Summit must address the items above in its procedures.
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
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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 Summit Midstream Partners, LLC maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to [Region Director's name], Director, [Region], Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to
CPF 3-2017-5001M and, for each document you submit, please provide a copy in electronic format
whenever possible.
Since the inspection, Summit Midstream Partners, LLC has submitted revised procedures to resolve
these issues. PHMSA Central Region personnel have reviewed the revised procedures and determined
that the revisions satisfy the deficiencies identified in the above item. Therefore, no further action is
required and this enforcement action is considered closed.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
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