{"operation":"document","citation":"CPF 420095008W","title":"APACHE CORPORATION — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-06-26","effective_on":null,"summary":"CLOSED warning letter citing 195.406, 195.567, 195.573(a)(1), 195.573(d), 195.589.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420095008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420095008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420095008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420095008W","body":"Warning Letter involving APACHE CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.406,  195.567,  195.573(a)(1),  195.573(d),  195.589. The case was opened on 2009-06-26 and is reported as closed as of 2009-06-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420095008W_Warning_06262009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420095008W/420095008W_Warning_06262009.pdf\n\n420095008W_Warning_06262009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420095008W/420095008W_Warning_06262009_text.pdf\n\n420095008W_Warning_06262009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 26, 2009\nMr. David Carmony\nVice President Operations Gulf Coast Region\nApache Corporation\n2000 Post Oak Blvd\nSuite 100\nHouston, TX 77056\nCPF 4-2009-5008W\nDear Mr. Carmony:\nOn October 27-31 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nGibbstown crude oil pipeline in Cameron Parish, Louisiana and your Grand Isle crude oil\npipeline in Jefferson Parish, Louisiana.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(1) The internal design pressure of the pipe determined in accordance with\n§195.106. However, for steel pipe in pipelines being converted under §195.5, if one\nor more factors of the design formula (§195.106) are unknown, one of the following\npressures is to be used as design pressure:\n\n\n\n(i) Eighty percent of the first test pressure that produces yield under section\nN5.0 of Appendix N of ASME B31.8, reduced by the appropriate factors in\n§§195.106(a) and (e); or\n(ii) If the pipe is 323.8 mm (12¾ in) or less outside diameter and is not tested\nto yield under this paragraph, 1379 kPa (200 psig).\n(2) The design pressure of any other component of the pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under Subpart E of this part.\n(4) Eighty percent of the factory test pressure or of the prototype test pressure for\nany individually installed component which is excepted from testing under §195.305.\n(5) For pipelines under §§195.302(b)(1) and (b)(2)(i), that have not been pressure\ntested under Subpart E of this part, 80 percent of the test pressure or highest\noperating pressure to which the pipeline was subjected for 4 or more continuous\nhours that can be demonstrated by recording charts or logs made at the time the\ntest or operations were conducted.\n(b) No operator may permit the pressure in a pipeline during surges or other\nvariations from normal operations to exceed 110 percent of the operating pressure\nlimit established under paragraph (a) of this section. Each operator must provide\nadequate controls and protective equipment to control the pressure within this limit.\nThere were no records provided, at the time of the inspection, to substantiate MOP\ndetermination. Apache had acquired this pipeline from BP in 2006 and apparently MOP\nwas only provided verbally with no test or other documentation. Apache has since\nperformed a hydro test on February 14, 2009, and established MOP accordingly.\n2. §195.567 Which pipelines must have test leads and what must I do to install and\nmaintain the leads?\n(a) General. Except for offshore pipelines, each buried or submerged pipeline or\nsegment of pipeline under cathodic protection required by this subpart must have\nelectrical test leads for external corrosion control. However, this requirement does\nnot apply until December 27, 2004, to pipelines or pipeline segments on which test\nleads were not required by regulations in effect before January 28, 2002.\n(b) Installation. You must install test leads as follows:\n(1) Locate the leads at intervals frequent enough to obtain electrical measurements\nindicating the adequacy of cathodic protection.\n2\n\n\n\n(2) Provide enough looping or slack so backfilling will not unduly stress or break\nthe lead and the lead will otherwise remain mechanically secure and electrically\nconductive.\n(3) Prevent lead attachments from causing stress concentrations on pipe.\n(4) For leads installed in conduits, suitably insulate the lead from the conduit.\n(5) At the connection to the pipeline, coat each bared test lead wire and bared\nmetallic area with an electrical insulating material compatible with the pipe coating\nand the insulation on the wire.\n(c) Maintenance. You must maintain the test lead wires in a condition that enables\nyou to obtain electrical measurements to determine whether cathodic protection\ncomplies with Sec. 195.571.\nAt the time of the inspection, it was observed that there was no test lead attached to the\npipe at LA Rd 1143 (Dorcelie Rd) cased crossing. There was a casing vent which had a\ncasing to soil potential of -1.162 volt at the time of the inspection, indicating a probable\nshort.\nA casing potential of -0.676 volt was documented on the Apache 2008 annual survey\nwhich also had no indication of pipe to soil potential at that location.\n3. §195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with Sec. 195.571:\n(1) Conduct tests on the protected pipeline at least once each calendar year, but\nwith intervals not exceeding 15 months. However, if tests at those intervals are\nimpractical for separately protected short sections of bare or ineffectively coated\npipelines, testing may be done at least once every 3 calendar years, but with\nintervals not exceeding 39 months.\nDuring the inspection a visit was made to the pipeline crossing at Louisiana Hwy 82.\nThere is a casing vent and cathodic protection test station at that location, however there\nis no record of a reading being taken by Apache. The 2008 annual survey had no record\nof cathodic protection readings at this test station location.\n4. § 195.573 What must I do to monitor external corrosion control?\n3\n\n\n\n(d) Breakout tanks. You must inspect each cathodic protection system used to\ncontrol corrosion on the bottom of an aboveground breakout tank to ensure that\noperation and\nmaintenance of the system are in accordance with API Recommended Practice 651.\nHowever, this inspection is not required if you note in the corrosion control\nprocedures established under Sec. 195.402(c)(3) why compliance with all or certain\noperation and maintenance provisions of API Recommended Practice 651 is not\nnecessary for the safety of the tank.\nThere was no documentation available at the inspection to demonstrate that tank bottom\ncathodic protection readings were being taken on Tank 4. There were no tank cathodic\nprotection readings on the 2008 annual survey documentation provided at the inspection.\n5. §195.589 What corrosion control information do I have to maintain?\na) You must maintain current records or maps to show the location of--\n(1) Cathodically protected pipelines;\n(2) Cathodic protection facilities, including galvanic anodes, installed after January\n28, 2002; and\n(3) Neighboring structures bonded to cathodic protection systems.\n(b) Records or maps showing a stated number of anodes, installed in a stated\nmanner or spacing, need not show specific distances to each buried anode.\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs. 195.569,\n195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the\npipeline remains in service.\nAt the time of the inspection, the inspector was informed by Apache personnel that the\nrectifier northwest of, and nearest to, Tank #4 was returned to service approximately a\nweek before the inspection. This rectifier was not on the rectifier survey, and had\napparently not been in service since before the purchase of the system from BP in 2006.\nAlthough Tank #4 cathodic protection readings taken at the inspection ranged from -\n0.860 to -1.318 it is not known exactly how long this rectifier had been out of service and\nhow cathodic protection of the breakout tank may have been compromised.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\n4\n\n\n\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Apache being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2009-5008W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\n5","truncated":false,"body_characters":10111}