# NOBLE MIDSTREAM SERVICES, LLC — Warning Letter - **operation:** document - **citation:** CPF 420097001W - **title:** NOBLE MIDSTREAM SERVICES, LLC — Warning Letter - **source type:** enforcement - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** historical - **official:** true - **published on:** 2009-01-16 - **effective on:** Not available - **summary:** CLOSED warning letter citing 195.583(a). - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420097001w.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420097001w.md - **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420097001w - **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420097001W **body:** Warning Letter involving NOBLE MIDSTREAM SERVICES, LLC. PHMSA's enforcement data identifies the cited regulation as 195.583(a). The case was opened on 2009-01-16 and is reported as closed as of 2009-01-16. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 420097001W_Warning_01162009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420097001W/420097001W_Warning_01162009.pdf 420097001W_Warning_01162009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420097001W/420097001W_Warning_01162009_text.pdf 420097001W_Warning_01162009_text.pdf WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 16, 2009 Mr. Richard Peneguy, Jr. Noble Energy, Inc. Vice President and General Manager, Offshore Division 100 Glenborough, Suite 100 Houston, Texas 77067 CPF 4-2009-7001W Dear Mr. Peneguy, Jr.: On June 24-27, 2008, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected records and procedures of your Main Pass 305 Pipeline System at your Venice, Louisiana office. As a result of the inspection, it appears that you have committed probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violations is: 1. §195.583 What must I do to monitor atmospheric corrosion control? (a) You must inspect each pipeline or portion of pipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, as follows: If the pipeline is located: Then the frequency of inspection is: Onshore……………………… At least once every 3 calendar years, but with intervals not exceeding 39 months Offshore……………………… At least once each calendar year, but with Intervals not exceeding 15 months (b) During inspections you must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. (c) If you find atmospheric corrosion during an inspection, you must provide protection against the corrosion as required by Sec. 195.581. Above ground valves and associated piping and much of the offshore piping exhibited very heavy coating damage and atmospheric corrosion. Corrosion will continue to attack these components and compromise the integrity of the pipeline system if not addressed. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violations persists up to a maximum of $1,000,000 for any related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Be advised that failure to do so will result in Noble Energy Inc. being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-2009-7001W. 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). Sincerely, R. M. Seeley Director, Southwest Region, Pipeline and Hazardous Material Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 2 - **truncated:** false - **body characters:** 3875