ENVEN ENERGY VENTURES LLC. — Notice of Amendment

party submissionOfficial PDF420175013M_Operator Response to Notice_05082017.pdf#

420175013M_Closure Letter_12012017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED December 1, 2017 Mr. David Dunwoody President EnVen Energy Ventures LLC 333 Clay St. Suite 4200 Houston, TX 77002 CPF 4-2017-5013M Dear Mr. Dunwoody: On November 14 through 17, 2016, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected EnVen Energy Ventures, LLC (EnVen) procedures for Operations and Maintenance of the Cognac Pipeline Offshore Liquid System located offshore Louisiana. As a result of the inspection, EnVen was issued a Notice of Amendment on April 6, 2017, which proposed amendment of your procedures. EnVen submitted the requested procedural modification on May 8, 2017. My staff reviewed the amended procedure, and the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you that no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Frank Causey Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420175013M_Notice of Amendment_04112017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 11, 2017 David Dunwoody President EnVen Energy Ventures LLC 333 Clay St. Suite 4200 Houston, TX 77002 CPF 4-2017-5013M Dear Mr. Dunwoody: On November 14 through 17, 2016, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected EnVen Energy Ventures, LLC (Enven) procedures for Operations and Maintenance of the Cognac Pipeline Offshore Liquid System located offshore Louisiana. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Enven’s plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part.#

420175013M_Notice of Amendment_04112017_text.pdf, page 2§195.571 What criteria must I use to determine the adequacy of cathodic protection? Cathodic protection required by this subpart must comply with one or more of the applicable criteria and other considerations for cathodic protection contained paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by reference, see §195.3). Enven procedures do not specify the use of a saturated Silver/Silver Chloride reference electrode or the compensated voltage equivalent if a Copper/Copper Sulfate reference electrode is used when conducting annual cathodic protection potential monitoring of the Cognac Pipeline Offshore Liquid System. 2. §195.402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. §195.573 What must I do to monitor external corrosion control? (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 21/2 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. Procedures for electrical checks of the rectifiers providing impressed current to the Cognac Pipeline Offshore Liquid System were not included in Enven’s corrosion control procedures. 2#

420175013M_Notice of Amendment_04112017_text.pdf, page 3Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all material you submit in response to this enforcement action is subject to being 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations 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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within [number of days] days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that EnVen Energy Ventures, LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2017-5013M 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 Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#