# CHAPARRAL ENERGY, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420135025
- **title:** CHAPARRAL ENERGY, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2013-10-31
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.111, 195.214, 195.403, 195.420.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420135025.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420135025
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420135025
**body:**

Notice of Probable Violation involving CHAPARRAL ENERGY, LLC. PHMSA's enforcement data identifies the cited regulations as 195.111,  195.214,  195.403,  195.420. The case was opened on 2013-10-31 and is reported as closed as of 2014-12-12. Proposed civil penalty: $47,900. Assessed civil penalty: $47,900. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420135025_Final Order_12122014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135025/420135025_Final%20Order_12122014.pdf

420135025_Final Order_12122014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135025/420135025_Final%20Order_12122014_text.pdf

420135025_NOPV PCP PCO_10312013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135025/420135025_NOPV%20PCP%20PCO_10312013.pdf

420135025_NOPV PCP PCO_10312013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135025/420135025_NOPV%20PCP%20PCO_10312013_text.pdf

420135025_Operator Response and Request for Time Extension_11262013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135025/420135025_Operator%20Response%20and%20Request%20for%20Time%20Extension_11262013.pdf

420135025_Final Order_12122014_text.pdf

DECEMBER 12, 2014
Mr. Mark Fischer
Chairman, Chief Executive Officer
Chaparral Energy, LLC
701 Cedar Lake Blvd.
Oklahoma City, OK 73114
Re: CPF No. 4-2013-5025
Dear Mr. Fischer:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and assesses a civil penalty of $47,900. It further finds that Chaparral Energy, LLC,
has completed the actions specified in the Notice to comply with the pipeline safety regulations.
Since the civil penalty was paid by wire transfer dated January 10, 2014, this enforcement action
will be closed upon service of this Final Order. Service of the Final Order by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. R.M. Seeley, Director, Southwest Region, PHMSA, OPS
Mr. David Ketelsleger, SVP and General Counsel, Chaparral Energy, LLC
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Chaparral Energy, LLC, ) CPF No. 4-2013-5025
)
Respondent. )
____________________________________)
FINAL ORDER
On multiple dates in 2012, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of the facilities and records of Chaparral Energy,
LLC (Chaparral or Respondent), in Oklahoma, Kansas and Texas. Chaparral is a privately-
owned oil and gas exploration/drilling company that operates approximately 230 miles of
hazardous liquid pipelines in these three states.1
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated October 31, 2013, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice) which also included a warning pursuant to
49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that
Chaparral had violated 49 C.F.R. §§ 195.111, 195.214, and 195.420 and assessing a civil penalty
of $47,900 for the alleged violations. The Notice also proposed ordering Respondent to take
certain measures to correct the alleged violations. The warning item required no further action,
but warned the operator to correct the probable violation or face possible enforcement action.
Chaparral responded to the Notice by letter dated January 9, 2014 (Response). The company did
not contest the allegations of violation and paid the proposed civil penalty of $47,900, as
provided in 49 C.F.R. § 190.227. Payment of the penalty serves to close the case with prejudice
to Respondent.
FINDINGS OF VIOLATION
In its Response, Chaparral did not contest the allegations in the Notice that it violated 49 C.F.R.
Part 195, as follows:
1 PHMSA Annual Report, Chaparral Energy, LLC. See
https://primis.phmsa.dot.gov/comm/reports/operator/OperatorReport opid 31672.html?nocache=6234.



CPF No: 4-2013-5025
Page 2
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.111, which states:
§ 195.111 Fracture propagation.
A carbon dioxide pipeline system must be designed to mitigate
the effects of fracture propagation.
The Notice alleged that Respondent violated 49 C.F.R. § 195.111 by failing to design its
recently-constructed carbon dioxide pipeline system to mitigate the effects of fracture
propagation. Specifically, the Notice alleged that despite multiple requests from PHMSA,
Chaparral was unable to produce a fracture propagation analysis demonstrating that its carbon-
dioxide Farnsworth Laterals had been designed to mitigate the effects of fracture propagation
prior to, or subsequent to commissioning of the lines in 2011. Chaparral could not demonstrate it
had performed a separate fracture propagation analysis for each of the Farnsworth Laterals, as
follows:
• 4” east lateral, constructed Oct/Nov 2010
• 6” west lateral, constructed Jan/Mar 2011.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.111 by failing to design its
recently-constructed carbon dioxide pipeline system to mitigate the effects of fracture
propagation.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.214, which states:
§ 195.214 Welding procedures.
(a) Welding must be performed by a qualified welder in accordance
with welding procedures qualified under Section 5 of API 1104 or Section
IX of the ASME Boiler and Pressure Vessel Code (incorporated by
reference, see § 195.3). The quality of the test welds used to qualify the
welding procedure shall be determined by destructive testing.
(b) Each welding procedure must be recorded in detail, including the
results of the qualifying tests. This record must be retained and followed
whenever the procedure is used.
The Notice alleged that Respondent violated 49 C.F.R. § 195.214 by using welding procedures
on the Farnsworth Laterals, as described above, that had not been properly qualified in
accordance with Section 5 of [American Petroleum Institute (API)] 1104 or Section IX of the
ASME Boiler and Pressure Vessel Code. Specifically, the Notice alleged that PHMSA requested
a copy of Chaparral’s complete welding procedure, including both the welding procedure
specification (WPS) as well as the procedure qualification record (PQR). According to the
Notice, Respondent provided qualification records indicating its welders had been qualified to
procedure “A100” (but with no procedure qualification documents), and the “A100” procedure
was missing important elements that would qualify it as a complete welding procedure.



CPF No: 4-2013-5025
Page 3
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.214 by using welding
procedures on the Farnsworth Laterals that were not qualified in accordance with Section 5 of
API 1104 or Section IX of the ASME Boiler and Pressure Vessel Code.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.420, which states, in
relevant part:
§ 195.420 Valve maintenance.
(a) Each operator shall maintain each valve that is necessary for
the safe operation of its pipeline systems in good working order at all
times.
(b) Each operator shall, at intervals not exceeding 7½ months, but at
least twice each calendar year, inspect each mainline valve to determine
that it is functioning properly. . . .
The Notice alleged that Respondent violated 49 C.F.R. § 195.420 by failing to perform valve
inspections at proper intervals, and by failing to perform complete inspections in order to
determine that each valve functioned properly. Specifically, the Notice alleged that Chaparral
could not produce valve maintenance records on the Borger mainline block valves (MLVs) 3 and
6 showing they had been inspected in April 2011. Instead, the company’s valve maintenance
records allegedly indicated that MLVs 3 and 6 had been inspected in November 2010 and
December 2010, but did not show that inspections had been conducted in April 2011, when
inspections had been conducted for the other MLVs.
In addition, the Notice alleged that Chaparral failed to perform proper inspections for all of the
valves inspected in November 2010 and December 2011. Specifically, the Notice alleged that
the company’s maintenance records indicated the valves “could not operate due to operating
conditions.” Chaparral’s Operation and Management (O&M) procedures implementing
§ 195.420(b) required valves to be operated “to the fullest extent practical and then returned to
[their] position,” but there was no follow-up documentation indicating Respondent had returned
to perform maintenance on the valves when conditions were more favorable.
Respondent did not contest these allegations of violation. Accordingly, based upon a review of
all of the evidence, I find that Respondent violated 49 C.F.R. § 195.420 by failing to perform
valve inspections at proper intervals and by failing to perform complete inspections in order to
determine that each valve functioned properly.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any



CPF No: 4-2013-5025
Page 4
related series of violations.2 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect
that the penalty may have on its ability to continue doing business; and the good faith of
Respondent in attempting to comply with the pipeline safety regulations. In addition, I may
consider the economic benefit gained from the violation without any reduction because of
subsequent damages, and such other matters as justice may require. The Notice proposed a total
civil penalty of $47,900 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $19,000 for Respondent’s violation of 49 C.F.R.
§ 195.111, for failing to design its recently-constructed carbon dioxide pipeline system to
mitigate the effects of fracture propagation. Chaparral paid the proposed penalty in full, which
serves to close the case with prejudice to Respondent. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Respondent a civil penalty of $19,000 for the
violation cited above.
Item 4: The Notice proposed a civil penalty of $28,900 for Respondent’s violation of 49 C.F.R.
§ 195.420, for failing to perform valve inspections at the proper intervals and to determine that
all valves were functioning properly. Chaparral paid the proposed penalty in full, which serves
to close the case with prejudice to Respondent. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $28,900 for the
violation cited above.
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $47,900, which amount has
already been paid by Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for
violations of 49 C.F.R. §§ 195.111 and 195.214, respectively. Under 49 U.S.C. § 60118(a), each
person who engages in the transportation of hazardous liquids or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601. The Director indicates that Respondent has taken the following actions specified in
the proposed compliance order:
1. With respect to the violation of § 195.111 (Item 1), Respondent submitted
recently-completed fracture propagation analyses for the Farnsworth Laterals to the
Director on January 9, 2014.
2. With respect to the violation of § 195.214 (Item 2), Respondent provided
2 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Pub. L. No. 112-90, § 2(a)(1), 125 Stat.
1904, January 3, 2012, increased the civil penalty liability for violating a pipeline safety standard to $200,000 per
violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.



CPF No: 4-2013-5025
Page 5
qualification paperwork for the weld procedure (A101) that was actually used on the
Farnsworth Laterals. Respondent also provided confirmation that the weld procedure
used on the lines had been properly qualified and documented.
The Region Director has reviewed Respondent’s submissions under Items 1 and 2 and has found
them to be satisfactory. Therefore, the compliance terms proposed in the Notice are not included
in this Order.
WARNING ITEM
With respect to Item 3, the Notice alleged a probable violation of Part 195 but did not propose a
civil penalty or compliance order for this item. Therefore, this is considered to be a warning
item. The warning is for:
49 C.F.R. § 195.403 (Item 3) ─ Respondent’s alleged failure to adequately
document its emergency response training program.
Chaparral presented information in its Response showing it had taken certain actions to address
this item. If OPS finds a violation of this provision in a subsequent inspection, Respondent may
be subject to future enforcement action.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420135025_NOPV PCP PCO_10312013_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 31, 2013
Mr. David Ketelsleger
SVP General Counsel
Chaparral Energy LLC
701 Cedar Lake Blvd
Oklahoma City OK 73114
CPF 4-2013-5025
Dear Mr. Ketelsleger:
On multiples dates in April, May, August, September, and October, 2012, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
pursuant to Chapter 601 of 49 United States Code inspected Chaparral Energy CO2 pipeline records and
facilities in Oklahoma, Kansas and Texas.
As a result of the inspection, it appears that you have committed probable violations of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable
violations are:
1. §195.111 Fracture propagation.
A carbon dioxide pipeline system must be designed to mitigate the effects of fracture
propagation.



Chaparral could not demonstrate that it had designed its recently constructed pipeline(s) to
mitigate the effects of fracture propagation.
A documented fracture propagation analysis was requested by PHMSA to demonstrate
compliance with the requirement that the Farnsworth Laterals were designed to mitigate the
effects of fracture propagation. It was determined that Chaparral had not performed a fracture
propagation analysis. In addition, Chaparral could not demonstrate that fracture propagation
design considerations and analysis had been performed prior to or subsequent to the
commissioning of the Farnsworth laterals in 2011.
The fracture propagation analysis for the Farnsworth laterals was requested multiple times by
PHMSA Southwest Region personnel, including at the initial construction inspection
documentation review in April 2012, and during subsequent and follow up inspections (office
and field), telephone conversations and by email.
Also, the construction of the Coffeyville pipeline took place contemporaneously with the 2012
PHMSA Southwest Region inspection of the existing Chaparral CO2 pipelines, including the
Farnsworth laterals. The necessity for each of the three pipelines to have its own fracture
propagation analysis performed was discussed and that Chaparral should commence work upon a
documented fracture propagation analysis for the Coffeyville pipeline project while there was
still time to avoid placing that pipeline in service without being in compliance with the
requirement that it be designed to mitigate the effects of fracture propagation. A fracture
propagation analysis for the Coffeyville pipeline was accomplished and was (after revision)
found by PHMSA to be acceptable, in August 2012.
Due to differences in construction and materials, there is still the requirement to perform a
separate fracture propagation analysis for each of the Farnsworth Laterals as follows:
• 4" east lateral constructed Oct/Nov 2010
• 6" west lateral constructed Jan/Mar 2011
2. § 195.214 Welding procedures
(a) Welding must be performed by a qualified welder in accordance with welding
procedures qualified under Section 5 of API 1104 or Section IX of the ASME Boiler and
Pressure Vessel Code (ibr, see § 195.3) . The quality of the test welds used to qualify the
welding procedure shall be determined by destructive testing.
(b) Each welding procedure must be recorded in detail, including the results of the
qualifying tests. This record must be retained and followed whenever the procedure is
used.
2



Welding performed during the construction of the Farnsworth Lateral was not performed in
accordance with a qualified welding procedure. Welding procedures presented by Chaparral
were not qualified in accordance with Section 5 of API 1104 or Section IX of the ASME Boiler
and Pressure Vessel Code (ibr, see § 195.3) . Chaparral has not shown that the quality of the test
welds used to qualify the welding procedure was determined by destructive testing, or that test
welds were examined. The welding procedure presented did not include the results of qualifying
tests and was missing essential variables.
There are two Farnsworth Laterals as follows:
• 4" east lateral constructed Oct/Nov 2010
• 6" west lateral constructed Jan/Mar 2011
At the initial construction inspection documentation review in April 2012 PHMSA personnel
requested the welder qualification records and the welding procedure specification (WPS) as
well as the procedure qualification record (PQR) for the welding performed during the
construction of the Farnsworth Laterals. A complete welding procedure contains both the WPS
and the PQR.
The welder qualification records presented at the inspection indicated that welders were qualified
to procedure “A100.” There was not a procedure qualification record available from Chaparral
for this weld procedure A100 to which welders were qualified. A one page procedure
specification document was available for procedure “A100,” however; no procedure
qualification document was ever produced, despite repeated requests from PHMSA personnel
during the course of the inspection.
It also appears that the welding procedure “A100” presented at the audit is missing important
essential variables, such as speed of travel and other parameters, such as material group
discrepancies between procedure and construction, and discrepancies between weld procedure
and welder qualification such as changes in filler group and joint design.
3. §195.403 Emergency Response Training.
(a) Each operator shall establish and conduct a continuing training program to instruct emergency
response personnel to:
(1) Carry out the emergency procedures established under 195.402 that relate to their assignments;
(2) Know the characteristics and hazards of the hazardous liquids or carbon dioxide transported,
including, in case of flammable HVL, flammability of mixtures with air, odorless vapors, and water
reactions;
(3) Recognize conditions that are likely to cause emergencies, predict the consequences of facility
malfunctions or failures and hazardous liquids or carbon dioxide spills, and take appropriate
corrective action;
(4) Take steps necessary to control any accidental release of hazardous liquid or carbon dioxide
and to minimize the potential for fire, explosion, toxicity, or environmental damage; and
3



(5) Learn the potential causes, types, sizes, and consequences of fire and the appropriate use of
portable fire extinguishers and other on-site fire control equipment, involving, where feasible, a
simulated pipeline emergency condition.
(b) At the intervals not exceeding 15 months, but at least once each calendar year, each operator
shall:
(1) Review with personnel their performance in meeting the objectives of the emergency response
training program set forth in paragraph (a) of this section; and
(2) Make appropriate changes to the emergency response training program as necessary to ensure
that it is effective.
PHMSA was unable to confirm that Chaparral conducted the appropriate emergency response
training. PHMSA requested documentation to demonstrate appropriate training of emergency
response personnel during the records portion of the inspection. There was not adequate
documentation provided by Chaparral at the 2012 inspection to demonstrate appropriate training
of emergency response personnel. Chaparral indicated that emergency response personnel
training would be conducted as soon as possible. Chaparral has since provided documentation of
emergency response personnel training, conducted in the first quarter of 2013 at locations where
Chaparral personnel are stationed.
4. § 195.420 Valve maintenance.
(a) Each operator shall maintain each valve that is necessary for the safe operation of its
pipeline systems in good working order at all times.
(b) Each operator shall, at intervals not exceeding 7 1/2 months, but at least twice each
calendar year, inspect each mainline valve to determine that it is functioning properly.
Chaparral did not perform valve inspections at the proper intervals and inspections were not
complete in order to determine that each valve could function properly. PHMSA personnel
requested Chaparral valve maintenance records and related documentation during the records
portion of the inspection. Chaparral valve maintenance records were missing on the Borger line
for some mainline block valves. Valve maintenance records indicate that mainline block valves
(MLV) 3 and 6 were inspected in November 2010 and December 2011. Other mainline block
valves were inspected in April 2011 per the documentation provided at the inspection; however,
there was no indication on the April 2011 valve inspection report that either MLV 3 or 6 were
inspected at that time.
In addition, Chaparral valve maintenance records are noted as “5 - could not operate due to
operating conditions” for all valves listed on the November 2010 and December 2011 valve
maintenance records. Chaparral O&M procedure 195.420 Valve Maintenance Process
Description states “Valves should be operated to the fullest extent practical and then returned to
its position…” There was no documentation provided to indicate that further valve maintenance
was performed, such as returning to a valve to perform a partial operation of that valve when
operating conditions became more favorable to performing valve maintenance and inspection
activities.
4



The evidence demonstrates that the operator violated § 195.420 by failing to conduct a proper
inspection per the regulations related to inspecting each main line valve. In the event that such
inspections were, in fact, performed, the evidence demonstrates the operator violated
§195.404(c)(3) by failing to maintain a record of each inspection and test required by this subpart
for at least 2 years or until the next inspection or test is performed, whichever is longer.
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per
violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.
For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per
violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.
The Compliance Officer has reviewed the circumstances and supporting documentation involved in the
above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of
$47,900 as follows:
Item number PENALTY
1 $19,000
4 $28,900
Warning Items
With respect to item(s) 3 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 promptly correct these item(s). Failure to do so may result
in additional enforcement action.
Proposed Compliance Order
With respect to items numbers 1 and 2 pursuant to 49 United States Code § 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Chaparral. Please
refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.
Response to this Notice
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. All material you
submit in response to this enforcement action may be 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). If you do not respond
within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations
5



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 a Final Order.
In your correspondence on this matter, please refer to CPF 4-2013-5025 and for each document you
submit, please provide a copy in electronic format whenever possible.
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
6



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) proposes to issue to Chaparral Energy LLC a Compliance Order incorporating the following
remedial requirements to ensure the compliance of Chaparral Energy LLC with the pipeline safety
regulations:
1. In regard to Item Number 1 of the Notice pertaining to fracture propagation analyses,
Chaparral shall perform a technically sound fracture propagation analysis for each of the
Farnsworth Laterals. This analysis should be completed with 30 days of the Final Order.
Should the fracture propagation analysis determine that the existing design and
construction of either or both of the Farnsworth laterals as commissioned is deficient with
regard to mitigating the effects of fracture propagation, Chaparral develop a plan and
submit that to PHMSA with 30 days of completing the analysis for approval.
2. 4. In regard to Item Number 2 of the Notice pertaining to incomplete welding procedure
documentation, including no procedure qualification document for welding procedure
A100, Chaparral shall qualify this procedure per the appropriate standard and submit the
documentation showing that A100 is a complete and qualified welding procedure.
Chaparral shall separately address quality of weld issues as could be related to all missing
essential variables in the A100 document as presented by Chaparral as the procedure used
in constructing the Farnsworth laterals.
Chaparral shall complete item 2 within 30 days of the issuance of the Final Order.
It is requested (not mandated) that Chaparral maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total
to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: 1) total cost
associated with preparation/revision of plans, procedures, studies and analyses, and 2)
total cost associated with replacements, additions and other changes to pipeline
infrastructure.
7
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