# ENVEN ENERGY VENTURES LLC. — Notice of Probable Violation

- **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:** Not available
- **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.

Official case documents:

420175012_Closure Letter_10152018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Closure%20Letter_10152018.pdf

420175012_Closure Letter_10152018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Closure%20Letter_10152018_text.pdf

420175012_Final Order_03292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Final%20Order_03292018.pdf

420175012_Final Order_03292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Final%20Order_03292018_text.pdf

420175012_NOPV PCO_04112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_NOPV%20PCO_04112017.pdf

420175012_NOPV PCO_04112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_NOPV%20PCO_04112017_text.pdf

420175012_Operator Response to Notice_05082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175012/420175012_Operator%20Response%20to%20Notice_05082017.pdf

420175012_Closure Letter_10152018_text.pdf

CERTIFIED MAIL – RETURN RECEIPT REQUESTED
October 15, 2018
David Dunwoody
President
EnVen Energy Ventures, LLC
333 Clay Street, Suite 4200
Houston, Texas 77002
Re: CPF No. 4-2017-5012
Dear Mr. Dunwoody:
On November 14 through 17, 2017, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected, EnVen Energy Ventures, LLC(EnVen), Cognac Pipeline Offshore Liquid System. As a
result of the inspection, EnVen was issued Final Order on March 29, 2018. The Final Order
resulted in a compliance order.
On May 14, 2018, EnVen submitted their procedure to obtain rectifier inspection reports from
Hilcorp at least six times per calendar year not to exceed 2 ½ months. In addition, EnVen
submitted records of the rectifier readings from January 3, 2015 to September 1, 2018.
Based on the PHMSA review, it has been determined that EnVen has completed the requirements
of the Final Order. This letter is to inform you that no further action is necessary and this case is
now closed. Thank you for your cooperation.
Sincerely,
Mary L McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

420175012_Final Order_03292018_text.pdf

March 29, 2018
Mr. David Dunwoody
President
EnVen Energy Ventures, LLC
333 Clay Street, Suite 4200
Houston, Texas 77002
Re: CPF No. 4-2017-5012
Dear Mr. Dunwoody:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and specifies actions that need to be taken by EnVen Energy Ventures, LLC, to comply
with the pipeline safety regulations. When the terms of the compliance order have been
completed, as determined by the Director, Southwest Region, this enforcement action will be
closed. Service of the Final Order by certified mail is effective upon the date of mailing as
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. David Helminiak, Health, Safety and Environmental Manager, EnVen Energy
Ventures, LLC, 333 Clay Street, Suite 4200, Houston, Texas 77002
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 )
EnVen Energy Ventures, LLC, ) CPF No. 4-2017-5012
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From November 14-17, 2016, 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 EnVen Energy
Ventures, LLC’s (EnVen or Respondent) Cognac Pipeline Offshore Liquid System (Cognac
Pipeline), located off the shore of Louisiana. The EnVen Cognac Pipeline transports crude oil
and consists of approximately 28 miles of 12-inch coated steel piping that extends from
Mississippi Canyon Block 194 Platform in the Gulf of Mexico to the East Bay Central facility on
the Southwest Pass of the Mississippi River Delta.1 EnVen engages in the production of oil and
gas and related hydrocarbons in the Gulf of Mexico.2
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated April 11, 2017, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that EnVen had violated 49 C.F.R. § 195.573 and proposed ordering Respondent to take
certain measures to correct the alleged violation.
EnVen responded to the Notice by letter dated May 8, 2017 (Response). In its Response, the
company did not contest the allegation of violation or the proposed compliance order.
Respondent did not request a hearing and therefore has waived its right to one.
FINDING OF VIOLATION
In its Response, EnVen did not contest the allegation in the Notice that it violated 49 C.F.R. Part
195, as follows:
1 Pipeline Safety Violation Report, (on file with PHMSA), at 1.
2 EnVen website, available at http://www.enven.com/index.html (last accessed January 29, 2018).



CPF No. 4-2017-5012
Page 2
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(c), which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) …
(c) Rectifiers and other devices. You must electrically check for proper
performance each device in the first column at the frequency stated in the
second column.
Device Check Frequency
Rectifier…………………………………
At least six times each calendar
year, but with intervals not
exceeding 2 ½ months.
Reverse current switch.
Diode.
Interference bond whose failure would
jeopardize structural protection
Other interference bond
………………...
At least once each calendar year,
but with intervals not exceeding
15 months.
The Notice alleged that Respondent violated 49 C.F.R. § 195.573(c) by failing to perform
electrical checks for proper performance of each rectifier providing cathodic protection to the
Cognac Pipeline at least six times each calendar year, but with intervals not exceeding 2 ½
months. Specifically, the Notice alleged that EnVen personnel stated that EnVen did not own
the rectifier providing cathodic protection to its system and therefore did not have documentation
to determine whether the required checks were performed.
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. § 195.573(c) by failing to perform
electrical checks for proper performance of each rectifier providing cathodic protection to the
Cognac Pipeline at least six times each calendar year, but with intervals not exceeding 2½
months.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 1 in the Notice for the violation of
49 C.F.R. § 195.573(c). 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. Pursuant to the
authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the
following actions to ensure compliance with the pipeline safety regulations applicable to its
operations:



CPF No. 4-2017-5012
Page 3
1. With respect to the violation of § 195.573(c) (Item 1), Respondent must perform
an inspection of the rectifiers protecting the Cognac Pipeline to ensure continued
cathodic protection. Alternatively, Respondent must institute a process for the future
receipt of rectifier electrical-check inspection records to ensure proper operation.
2. Respondent shall complete Item 1 within 60 days after receipt of the Final Order.
The Director may grant an extension of time to comply with any of the required items
upon a written request timely submitted by the Respondent and demonstrating good
cause for an extension.
It is requested that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. 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.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for
each day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
March 29, 2018
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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