{"operation":"document","citation":"CPF 420075009M","title":"NOBLE MIDSTREAM SERVICES, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-03-28","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(c), 195.452(e), 195.452(f)(6), 195.452(h)(4)(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420075009M","body":"Notice of Amendment involving NOBLE MIDSTREAM SERVICES, LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(c),  195.452(e),  195.452(f)(6),  195.452(h)(4)(i). The case was opened on 2007-03-28 and is reported as closed as of 2007-11-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420075009M_Notice Letter_03282007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075009M/420075009M_Notice%20Letter_03282007.pdf\n\n420075009M_Operator Response to Notice Letter_04302007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075009M/420075009M_Operator%20Response%20to%20Notice%20Letter_04302007.pdf\n\n420075009M_Notice Letter_03282007.pdf\n\n\" *\n@\nU.5. Deoqrtment\nof Tronsportofion\nPipeline qnd\nHozordour trtoteriols sof ety\nAdmlnistrqtion\n8701 Soulh Gessner, Suite 1110\nHouston, TX 77074\nMAR 2 e ?001\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN REGEIPT REQUESTED\nMarch 28, 2007\nMr. Richard Peneguy, Jr.\nNoble Energy, Inc.\nVice President and General Manager, Offshore Division\n100 Glenborough, Suite 100\nHouston. Texas 77067\ncPF 4-2007-5009M\nDear Mr. Peneguy, Jr.:\nOn July 10-14,2006, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 60'l of 49 United States Code inspecled your\nprocedures for your Integrity Management Program (lMP) in Houston, TX.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nNoble Energy, Inc.'s (Noble) plan or procedure and are described below:\n1. 5195.452 Pipeline integrity management in high consequence areas'\n(fl What are the elements of an integrity management program?\nAn integrity management program begins with the initial framework. An operator\nmust continually change the program to reflect operating experience, conclusions\ndrawn from results of ttre integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) A process for identifying which pipeline\nsegments could affect a high\nconsequence area.\n(3) An analysis that integrates all available information\nabout the integritY of\nthe entire pipeline and the consequences of a failure\n(see paragraph (g) ofthis section);\n\n\n\n(6) ldentification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) ofthis section)\nNoble Energy must modify their procedures to provide sufficient detail to ensure consistent\napplication fbr the consideration of threats and preventive and mitigative measures for pipeline\nfacilities. Noble does not include facilities as separate from the main pipeline, and analysis of the\ndirect or the indirect impact of facilities on a High Consequence Area (HCA) is not considered\nNoble must identify threats in a comprehensive manner in those facilities identified as affecting an\nHCA in order to piovide the basis for determination of appropriate assessments to be pedormed\nand the prioritization of preventive and mitigative measures to reduce facility risks.\n2. $ 195.452 Pipeline integrity management in high consequence areas'\n(f) see above\n(4) Criteria for remedial actions to address integrity issues raised by the\nassessment methods and information analysis (see paragraph (h) of this\nsection)\n(h) What actions must an operator take to address integrity issues?\n(1) Generat requirements. An operator must take prompt action to address all\nanomalous conditions that the operator discovers through integrity\nassessment or information analysis ... evaluate all anomalous conditions and\nremediate those that could reduce a pipeline's integrity ... demonstrate that\nthe remediation of the condition will ensure the condition is unlikely to pose a\nthreat to the long-term integrity of the pipeline. A reduction in operating\npressure cannot exceed 365 days without an operator taking further remedaal\naction to ensure the Safety of the pipeline. An operator must comply with\n5195.422 when making a repair.\n(4) Special requirements for scheduling remediation-\n(i) lmmediate repair conditions. An operator's evaluation and\nremediation schedule must provide for immediate repair conditions. To\nmaintain safety, an operator must temporarily reduce operating\npressure or shut down the pipeline until the operator completes the\nrepair of these conditions. An operator must calculate the temporary\nreduction in operating pressure using the formula in section 451.7 ot\nASME/ANSI B31.4 (incorporated by reference, see $195'3).\nNoble Energy must modify their procedure for calculation of the appropriate pressure reduction for\nmetal loss inomalies caused by corrosion or otherfactors that incorporates ASME/ANSI 831.4'\nNoble Energy's IMP manual section 4.0'l , paragraph 3-4 does not adequately refer to the use of\nthe ASME B31.4 Section 451 .7 or document other acceptable methods to ensure that appropriate\naction is taken for immediate or other repair conditions.\n3. S 195.452 Pipeline integrity management in high consequence areas\n(e) What are the risk factors for establishing an assessment schedule (for\nboth the baseline and continual integrity assessments)?\n(1) An operator must establish an integrity assessment schedule that\nprioritizes pipeline segments for assessment (see paragraphs (d) (1)\nand fi) (3) of this section). An operator must base the assessment\nschedule on all risk factors that reflect the risk conditions on the\npipeline segment. The factors an operator must consider include, but\nare not limited to:\n\n\n\n(i) Results of the previous integrity assessment, defect type and\nsize that the assessment method can detect, and defect growth\nrate;\n(ii) Pipe size, material, manufacturing information, coating type\nand condition, and seam tYPe\n(iii) Leak history, repair history and cathodic protection history;\n(iv) Product transported;\n(v) Operating stress level;\n(vi) Existing or projected activities in the area;\n(vii) Local Cnvironmental factors that could affect the pipeline\n(e.g., corrosivity of soil, subsidence, climatic);\n(viii) Geo-technical hazards; and\n(ix) Physical support of the segment such as by a cable\nsuspension bridge.\n(2) Appendix G of this part provides further guidance on risk factors.\nNoble Energy must modify their risk analysis process to include all risk factors required by\n5195.452 (e) for evaluation of threats that impact the integrity of the pipeline system' Noble\nEnergy's risk analysis process shows modest participation or review by lM personnel and lacks a\nsufficJent analytical evaluation that adequately measures risks for development or modification of\nthe BAP. Input data defaults were sometimes used because of a lack of information about the\nactual condition of the pipeline. Noble must take steps to collect data to minimize distortion in risk\nranking and to identify the most important risk drivers for segments that can affect an HCA.\n4. S 195.452 Pipeline integrity management in high consequence areas.\n(f) see above\n(2) A baseline assessment plan meeting the requirements of paragraph (c) of\nthis section:\n(c) What must be in the baseline assessment plan?\n(1) An operator must inctude each of the following elements in its written\nbaseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe' An\noperator must assess the integrity of the line pipe by any of the\nfollowing methods. The methods an operator selects to assess low\nfrequenCy electric resistance welded pipe or lap welded pipe\nsusceptible to longitudinal seam failure must be capable of assessing\nseam integrity and of detecting corrosion and deformation anomalies.\n(A) Internll inspection tool or tools capable of detecting corrosion and\ndeformation anomalies including dents, gouges and grooves;\n(B) Pressure test conducted in accordance with subpart E of this part;\n(Cl External corrosion direct assessment in accordance with 5195.588;\nor\n(D) Other technology that the operator demonstrates can provide an\nequivalent understanding of the condition of the line pipe. An 9^p-e13t9l\nchoosing this option muit notify the Office of Pipeline Safety (OPS) 90\ndays beiore conducting the assessment, by sending a notice to the\naddress or facsimile number specified in paragraph (m) of this section.\n(2) An operator must document, prior to implementing any changes to the\nplan, any modification to the plan, and reasons for the modification'\n\n\n\nNoble Energy must modify the process to ensure the appropriate assessment method is selected\nand the justification for that selection must be comprehensive and formally documented. Noble\nEnergy must have the ability to understand all the threats to each pipeline segment (e.9.,\nsusceptible to dents, has exhibited crack-like features in past). The relative importance of threats\nand their associated consequences that make up this risk profile must be understood to support\neffective decision-making regarding the overall management of pipeline integrity.\nln regard to ltems 1 and 2 listed above, Noble provided finalized documentation via email to\nPHMSA on December 1, 2006, of various changes made to the lMP. After considering the\nmaterial provided, PHMSA deemed the modifications adequate, and no further action is required in\nresponse to ltems 1 and 2 of this Notice.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. S 60108(a) and 49 C.F.R. S 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. lf you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). lf you do not respond within 30 days of receipt of this Notice, this\nconstitutes 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.\nlf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. S 190.237). lf you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nln your correspondence on this matter, please refer to GPF 4-2006-5009M, and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\n,-prhMr{\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":11447}