ENVEN ENERGY VENTURES LLC. — Notice of Probable Violation

case documentOfficial PDF420175012_NOPV PCO_04112017.pdf#

case documentOfficial PDF420175012_NOPV PCO_04112017_text.pdf#

party submissionOfficial PDF420175012_Operator Response to Notice_05082017.pdf#

420175012_Closure Letter_10152018_text.pdf, page 1Official PDFCERTIFIED 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, page 1Official PDFMarch 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#

420175012_Final Order_03292018_text.pdf, page 2U.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).#

420175012_Final Order_03292018_text.pdf, page 3CPF 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:#

420175012_Final Order_03292018_text.pdf, page 4CPF 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#