PARADIGM MIDSTREAM SERVICES - ND, LLC — Notice of Amendment

320196010M_Notice of Amendment_11262019_text.pdf, page 1Official PDFNOTICE 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;#

320196010M_Notice of Amendment_11262019_text.pdf, page 2(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#

320196010M_Notice of Amendment_11262019_text.pdf, page 3Response 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, page 1Official PDFCERTIFIED 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#