{"operation":"document","citation":"CPF 420175013M","title":"ENVEN ENERGY VENTURES LLC. — Notice of Amendment","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 amendment citing 195.402(c)(3), 195.571, 195.573(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175013m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175013m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175013m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175013M","body":"Notice of Amendment involving ENVEN ENERGY VENTURES LLC.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.571,  195.573(c). The case was opened on 2017-04-11 and is reported as closed as of 2017-12-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175013M_Closure Letter_12012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175013M/420175013M_Closure%20Letter_12012017.pdf\n\n420175013M_Closure Letter_12012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175013M/420175013M_Closure%20Letter_12012017_text.pdf\n\n420175013M_Notice of Amendment_04112017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175013M/420175013M_Notice%20of%20Amendment_04112017.pdf\n\n420175013M_Notice of Amendment_04112017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175013M/420175013M_Notice%20of%20Amendment_04112017_text.pdf\n\n420175013M_Operator Response to Notice_05082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175013M/420175013M_Operator%20Response%20to%20Notice_05082017.pdf\n\n420175013M_Closure Letter_12012017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 1, 2017\nMr. David Dunwoody\nPresident\nEnVen Energy Ventures LLC\n333 Clay St. Suite 4200\nHouston, TX 77002\nCPF 4-2017-5013M\nDear Mr. Dunwoody:\nOn November 14 through 17, 2016, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected EnVen Energy\nVentures, LLC (EnVen) procedures for Operations and Maintenance of the Cognac Pipeline Offshore\nLiquid System located offshore Louisiana. As a result of the inspection, EnVen was issued a Notice of\nAmendment on April 6, 2017, which proposed amendment of your procedures.\nEnVen submitted the requested procedural modification on May 8, 2017. My staff reviewed the\namended procedure, and the inadequacies outlined in this Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nFrank Causey\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420175013M_Notice of Amendment_04112017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 11, 2017\nDavid Dunwoody\nPresident\nEnVen Energy Ventures LLC\n333 Clay St. Suite 4200\nHouston, TX 77002\nCPF 4-2017-5013M\nDear Mr. Dunwoody:\nOn November 14 through 17, 2016, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nEnVen Energy Ventures, LLC (Enven) procedures for Operations and Maintenance of the Cognac\nPipeline Offshore Liquid System located offshore Louisiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEnven’s plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this section\nmust include procedures for the following to provide safety during maintenance and normal\noperations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the\nrequirements of this subpart and subpart H of this part.\n\n\n\n§195.571 What criteria must I use to determine the adequacy of cathodic protection?\nCathodic protection required by this subpart must comply with one or more of the applicable\ncriteria and other considerations for cathodic protection contained paragraphs 6.2.2, 6.2.3,\n6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by reference, see §195.3).\nEnven procedures do not specify the use of a saturated Silver/Silver Chloride reference electrode\nor the compensated voltage equivalent if a Copper/Copper Sulfate reference electrode is used when\nconducting annual cathodic protection potential monitoring of the Cognac Pipeline Offshore\nLiquid System.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this section\nmust include procedures for the following to provide safety during maintenance and normal\noperations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the\nrequirements of this subpart and subpart H of this part.\n§195.573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper performance each\ndevice in the first column at the frequency stated in the second column.\nDevice Check frequency\nRectifier At least six times each calendar year, but with\nintervals not exceeding 21/2 months.\nReverse current switch\nDiode\nInterference bond whose failure would\njeopardize structural protection\nOther interference bond At least once each calendar year, but with\nintervals not exceeding 15 months.\nProcedures for electrical checks of the rectifiers providing impressed current to the Cognac\nPipeline Offshore Liquid System were not included in Enven’s corrosion control procedures.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within [number of days]\ndays of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested (not mandated) that EnVen Energy Ventures, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to R. M. Seeley, Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2017-5013M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":7734}