{"operation":"document","citation":"CPF 420175012","title":"ENVEN ENERGY VENTURES LLC. — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-11","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.573(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175012","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175012","body":"Notice of Probable Violation involving ENVEN ENERGY VENTURES LLC.. PHMSA's enforcement data identifies the cited regulation as 195.573(c). The case was opened on 2017-04-11 and is reported as closed as of 2018-10-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175012_Closure Letter_10152018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Closure%20Letter_10152018.pdf\n\n420175012_Closure Letter_10152018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Closure%20Letter_10152018_text.pdf\n\n420175012_Final Order_03292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Final%20Order_03292018.pdf\n\n420175012_Final Order_03292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Final%20Order_03292018_text.pdf\n\n420175012_NOPV PCO_04112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_NOPV%20PCO_04112017.pdf\n\n420175012_NOPV PCO_04112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_NOPV%20PCO_04112017_text.pdf\n\n420175012_Operator Response to Notice_05082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Operator%20Response%20to%20Notice_05082017.pdf\n\n420175012_Closure Letter_10152018_text.pdf\n\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nOctober 15, 2018\nDavid Dunwoody\nPresident\nEnVen Energy Ventures, LLC\n333 Clay Street, Suite 4200\nHouston, Texas 77002\nRe: CPF No. 4-2017-5012\nDear Mr. Dunwoody:\nOn November 14 through 17, 2017, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected, EnVen Energy Ventures, LLC(EnVen), Cognac Pipeline Offshore Liquid System. As a\nresult of the inspection, EnVen was issued Final Order on March 29, 2018. The Final Order\nresulted in a compliance order.\nOn May 14, 2018, EnVen submitted their procedure to obtain rectifier inspection reports from\nHilcorp at least six times per calendar year not to exceed 2 ½ months. In addition, EnVen\nsubmitted records of the rectifier readings from January 3, 2015 to September 1, 2018.\nBased on the PHMSA review, it has been determined that EnVen has completed the requirements\nof the Final Order. This letter is to inform you that no further action is necessary and this case is\nnow closed. Thank you for your cooperation.\nSincerely,\nMary L McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420175012_Final Order_03292018_text.pdf\n\nMarch 29, 2018\nMr. David Dunwoody\nPresident\nEnVen Energy Ventures, LLC\n333 Clay Street, Suite 4200\nHouston, Texas 77002\nRe: CPF No. 4-2017-5012\nDear Mr. Dunwoody:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and specifies actions that need to be taken by EnVen Energy Ventures, LLC, to comply\nwith the pipeline safety regulations. When the terms of the compliance order have been\ncompleted, as determined by the Director, Southwest Region, this enforcement action will be\nclosed. Service of the Final Order by certified mail is effective upon the date of mailing as\nprovided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Director, Southwest Region, Office of Pipeline Safety, PHMSA\nMr. David Helminiak, Health, Safety and Environmental Manager, EnVen Energy\nVentures, LLC, 333 Clay Street, Suite 4200, Houston, Texas 77002\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nEnVen Energy Ventures, LLC, ) CPF No. 4-2017-5012\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom November 14-17, 2016, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an on-site pipeline safety inspection of the facilities and records of EnVen Energy\nVentures, LLC’s (EnVen or Respondent) Cognac Pipeline Offshore Liquid System (Cognac\nPipeline), located off the shore of Louisiana. The EnVen Cognac Pipeline transports crude oil\nand consists of approximately 28 miles of 12-inch coated steel piping that extends from\nMississippi Canyon Block 194 Platform in the Gulf of Mexico to the East Bay Central facility on\nthe Southwest Pass of the Mississippi River Delta.1 EnVen engages in the production of oil and\ngas and related hydrocarbons in the Gulf of Mexico.2\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated April 11, 2017, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed\nfinding that EnVen had violated 49 C.F.R. § 195.573 and proposed ordering Respondent to take\ncertain measures to correct the alleged violation.\nEnVen responded to the Notice by letter dated May 8, 2017 (Response). In its Response, the\ncompany did not contest the allegation of violation or the proposed compliance order.\nRespondent did not request a hearing and therefore has waived its right to one.\nFINDING OF VIOLATION\nIn its Response, EnVen did not contest the allegation in the Notice that it violated 49 C.F.R. Part\n195, as follows:\n1 Pipeline Safety Violation Report, (on file with PHMSA), at 1.\n2 EnVen website, available at http://www.enven.com/index.html (last accessed January 29, 2018).\n\n\n\nCPF No. 4-2017-5012\nPage 2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(c), which states:\n§ 195.573 What must I do to monitor external corrosion control?\n(a) …\n(c) Rectifiers and other devices. You must electrically check for proper\nperformance each device in the first column at the frequency stated in the\nsecond column.\nDevice Check Frequency\nRectifier…………………………………\nAt least six times each calendar\nyear, but with intervals not\nexceeding 2 ½ months.\nReverse current switch.\nDiode.\nInterference bond whose failure would\njeopardize structural protection\nOther interference bond\n………………...\nAt least once each calendar year,\nbut with intervals not exceeding\n15 months.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.573(c) by failing to perform\nelectrical checks for proper performance of each rectifier providing cathodic protection to the\nCognac Pipeline at least six times each calendar year, but with intervals not exceeding 2 ½\nmonths. Specifically, the Notice alleged that EnVen personnel stated that EnVen did not own\nthe rectifier providing cathodic protection to its system and therefore did not have documentation\nto determine whether the required checks were performed.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 195.573(c) by failing to perform\nelectrical checks for proper performance of each rectifier providing cathodic protection to the\nCognac Pipeline at least six times each calendar year, but with intervals not exceeding 2½\nmonths.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for the violation of\n49 C.F.R. § 195.573(c). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. Pursuant to the\nauthority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the\nfollowing actions to ensure compliance with the pipeline safety regulations applicable to its\noperations:\n\n\n\nCPF No. 4-2017-5012\nPage 3\n1. With respect to the violation of § 195.573(c) (Item 1), Respondent must perform\nan inspection of the rectifiers protecting the Cognac Pipeline to ensure continued\ncathodic protection. Alternatively, Respondent must institute a process for the future\nreceipt of rectifier electrical-check inspection records to ensure proper operation.\n2. Respondent shall complete Item 1 within 60 days after receipt of the Final Order.\nThe Director may grant an extension of time to comply with any of the required items\nupon a written request timely submitted by the Respondent and demonstrating good\ncause for an extension.\nIt is requested that Respondent maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to the Director. It is\nrequested that these costs be reported in two categories: (1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for\neach day the violation continues or in referral to the Attorney General for appropriate relief in a\ndistrict court of the United States.\nThe terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\nMarch 29, 2018\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":9731}