# PARADIGM MIDSTREAM SERVICES - ND, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 320196010M
- **title:** PARADIGM MIDSTREAM SERVICES - ND, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-11-26
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.446(e).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320196010m.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320196010m.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320196010m
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320196010M
**body:**

Notice of Amendment involving PARADIGM MIDSTREAM SERVICES - ND, LLC. PHMSA's enforcement data identifies the cited regulation as 195.446(e). The case was opened on 2019-11-26 and is reported as closed as of 2020-01-08. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320196010M_Closure Letter_01082020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Closure%20Letter_01082020.pdf

320196010M_Closure Letter_01082020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Closure%20Letter_01082020_text.pdf

320196010M_Notice of Amendment_11262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Notice%20of%20Amendment_11262019.pdf

320196010M_Notice of Amendment_11262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Notice%20of%20Amendment_11262019_text.pdf

320196010M_Notice of Amendment_11262019_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 26, 2019
Mr. Troy Andrews
Chief Executive Officer
Paradigm Energy Partners
LLC 545 East John Carpenter Freeway, Suite 800
Irving, Texas 75062
CPF 3-2019-6010M
Dear Mr. Andrews:
On January 24-26, 2017, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Paradigm Midstream Services – ND, LLC procedures for operations, maintenance, control
room, operator qualification and public awareness in Keene, North Dakota.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Paradigm’s plans or procedures, as described below:
1. §195.446 Control room management.
(e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
(1) Review SCADA safety-related alarm operations using a process that
ensures alarms are accurate and support safe pipeline operations;
(2) Identify at least once each calendar month points affecting safety that
have been taken off scan in the SCADA host, have had alarms inhibited,
generated false alarms, or that have had forced or manual values for
periods of time exceeding that required for associated maintenance or
operating activities;



(3) Verify the correct safety-related alarm set-point values and alarm
descriptions when associated field instruments are calibrated or changed
and at least once each calendar year, but at intervals not to exceed 15
months;
(4) Review the alarm management plan required by this paragraph at
least once each calendar year, but at intervals not exceeding 15 months, to
determine the effectiveness of the plan;
(5) Monitor the content and volume of general activity being directed to
and required of each controller at least once each calendar year, but at
intervals not exceeding 15 months, that will assure controllers have
sufficient time to analyze and react to incoming alarms; and
(6) Address deficiencies identified through the implementation of
paragraphs (e)(1) through (e)(5) of this section.
Paradigm’s Control Room Management plan is missing sections on
maintenance, alarm philosophy, detailed design and other topical sections.
Also, there was no procedure for developing alarm set points. Finally, there is
no procedure to address Item (3) above. Paradigm developed an alarm set
point procedure and maintenance section in a separate procedure from its alarm
management plan in response to this finding. It is not clear how the new
procedure and the existing alarm management procedures mesh to provide a
comprehensive alarm management plan. Paradigm must amend its alarm
management plan to include a procedure to: Verify the correct safety-related
alarm set-point values and alarm descriptions when associated field instruments
are calibrated or changed and at least once each calendar year, but at intervals
not to exceed 15 months. Paradigm must also clarify how various alarm
management procedures work together. It is recommended that Paradigm also
review the below list of topical areas for an alarm management plan and add
applicable sections to its alarm management plan.
 Alarm philosophy
 Alarm identification
 Alarm rationalization, not necessarily alarm reduction.
 Detailed design
 Implementation
 Operation
 Maintenance
 Monitoring
 Assessment (including a method to confirm effective controller
response)
 Internal audits
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 60 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 [Company name] 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 3-2019-6010M and, for each document you submit, please
provide a copy in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
Copy:
Mr. Tommy Janik, Chief Operating Officer
Paradigm Midstream Services – ND, LLC.
545 East John Carpenter Freeway, Suite 800,
Irving, TX 75062
3

320196010M_Closure Letter_01082020_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
January 8, 2020
Mr. Troy Andrews
Chief Executive Officer
Paradigm Energy Partners
LLC 545 East John Carpenter Freeway, Suite 800
Irving, Texas 75062
Re: CPF 3-2019-6010M
Dear Mr. Andrews:
On January 24-26, 2017, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Paradigm
Midstream Services – ND, LLC (Paradigm) procedures for operations, maintenance, control room,
operator qualification and public awareness in Keene, North Dakota. As a result of the inspection,
Paradigm was issued a Notice of Amendment on November 26, 2019, which proposed amendment of
your procedures.
PHMSA received Paradigm’s amended procedures on December 23, 2019. My staff reviewed these
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,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Copy:
Mr. Tommy Janik, Chief Operating Officer
Paradigm Midstream Services – ND, LLC.
545 East John Carpenter Freeway, Suite 800,
Irving, TX 75062
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