{"operation":"document","citation":"CPF 32022003NOA","title":"SUMMIT MIDSTREAM PARTNERS, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-01-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022003noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022003noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022003noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32022003NOA","body":"Notice of Amendment involving SUMMIT MIDSTREAM PARTNERS, LLC. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2022-01-03 and is reported as closed as of 2022-03-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32022003NOA_Closure Letter_03072022_(21-199716).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022003NOA/32022003NOA_Closure%20Letter_03072022_(21-199716).pdf\n\n32022003NOA_Closure Letter_03072022_(21-199716)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022003NOA/32022003NOA_Closure%20Letter_03072022_(21-199716)_text.pdf\n\n32022003NOA_Notice of Amendment_01032022_(21-199716).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022003NOA/32022003NOA_Notice%20of%20Amendment_01032022_(21-199716).pdf\n\n32022003NOA_Notice of Amendment_01032022_(21-199716)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022003NOA/32022003NOA_Notice%20of%20Amendment_01032022_(21-199716)_text.pdf\n\n32022003NOA_Notice of Amendment_01032022_(21-199716)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: heath.deneke@summitmidstream.com and\nMStratmann@summitmidstream.com\nJanuary 3, 2022\nMr. Heath Deneke\nPresident/CEO\nSummit Midstream Partners, LLC\n910 Louisiana Street, Suite 4200\nHouston, TX 77002\nCPF 3-2022-003-NOA\nDear Mr. Deneke:\nOn March 23, April 26 to 29, May 10 to 12 and June 8 to 10, 2021, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code inspected Summit Midstream Partners, LLC (SMP) procedures for public\nawareness, damage prevention, operator qualifications, facilities and storage, time-dependent\nthreats, operations, maintenance, assessment and repair, integrity management, and design and\nconstruction virtually and in Epping, North Dakota.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSMP’s plans or procedures, as described below:\n1. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\n\n\n\nSMP’s procedures were inadequate because section 2.4.3 of the Construction Manual incorrectly\nstated that truck shipments shall conform to recommendations of API RP 5L1. Section\n195.207(c) requires operators to follow API RP 5LT for truck shipments, not API RP 5L1, which\nis relevant for railroad shipments. A July 23, 2021 submittal by SMP corrected the above issues.\nNo further action is necessary.\n2. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nSMP’s procedures were inadequate because the Construction Manual Section 8.5.1 specified, in\npart, that “COMPANY will specify the percentage of welds to be x-rayed if it is less than 100 %”\nwhich does not align with § 195.234(d), and §195.234(e). On September 20, 2021 SMP\nsubmitted amendments to its procedures which comply with §§ 195.234(d) and (e). No further\naction is required.\n3. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nSMP’s procedures were inadequate because there was no procedure in the Construction Manual\nspecifying installation of above ground components in accordance with § 195.254. On July 23,\n2021 SMP submitted amendments that satisfactorily address the above issues. No further action\nis necessary.\n4. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nSMP’s procedures were inadequate because Section 16.3.3 of the Construction Manual did not\ncomply with the test pressure and time requirements of § 195.304. Specifically, the procedure\nstates: “CONTRACTOR shall perform a hydrostatic test which stresses the pipe at the low point\nof the section being tested to a maximum of 98% of its specified minimum yield strength unless\nlimited by flange or valve rating. The line shall hold the specified test pressure without further\npumping for a minimum period of 8 hours.” On September 20, 2021 SMP submitted\namendments to its procedures which comply with § 195.304. No further action is required.\n5. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\n2\n\n\n\nSMP’s procedures were inadequate because Section 16.3.3. of the Construction Manual did not\ninclude the testing of tie-ins, as required by § 195.308. On September 20, 2021 SMP submitted\namendments to its procedures which comply with § 195.308. No further action is required.\n6. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nSMP’s procedures were inadequate because Section 16.3.3 of the Construction Manual did not\ninclude the pressure test record requirements of § 195.310. On September 20, 2021 SMP\nsubmitted amendments to its procedures which comply with § 195.310. No further action is\nrequired.\n7. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\nSMP’s procedures were inadequate because the procedure titled Engineering Standard ENG.CP-\n001 Above Ground Protective Coatings for Steel Surfaces did not contain procedures for\ntransition zone wraps but only paints. SMP must amend its procedures to comply with §\n195.581.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n60 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\n3\n\n\n\nIt is requested (not mandated) that Summit Midstream Partners, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Gregory A. Ochs, Director,\nCentral Region Office of Pipeline Safety, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 3-2022-003-NOA\nand, for each document you submit, please provide a copy in electronic format whenever\npossible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Mr. Matthew Stratmann, Senior Director, Integrity and Health & Safety, Summit\nMidstream Partners, LLC, 910 Louisiana Street, Suite 4200, Houston, TX 77002,\n(MStratmann@summitmidstream.com)\n4\n\n32022003NOA_Closure Letter_03072022_(21-199716)_text.pdf\n\nVIA ELECTRONIC MAIL TO: heath.deneke@summitmidstream.com and\nMStratmann@summitmidstream.com\nMarch 7, 2022\nMr. Heath Deneke\nPresident/CEO\nSummit Midstream Partners, LLC\n910 Louisiana Street, Suite 4200\nHouston, TX 77002\nRe: CPF 3-2022-003-NOA\nDear Mr Deneke:\nOn March 23, April 26 to 29, May 10 to 12 and June 8 to 10, 2021, a representative from the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of\n49 United States Code, conducted an on-site pipeline safety inspection of Summit Midstream\nPartners, LLC (SMP) procedures virtually and in Epping, North Dakota. As a result of the\ninspection, SMP was issued a Notice of Amendment on January 3, 2022 which proposed\namendment of your procedures.\nSMP submitted its amended procedures on March 4, 2022. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Matthew Stratmann, Senior Director, Integrity and Health & Safety, Summit\nMidstream Partners, LLC, 910 Louisiana Street, Suite 4200, Houston, TX 77002,\n(MStratmann@summitmidstream.com)","truncated":false,"body_characters":10343}