{"operation":"document","citation":"CPF 420175029M","title":"DCP MIDSTREAM — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-07","effective_on":null,"summary":"CLOSED notice of amendment citing 195.202, 195.402(a), 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175029m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175029m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175029m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175029M","body":"Notice of Amendment involving DCP MIDSTREAM. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.402(a),  195.402(c)(3). The case was opened on 2017-08-07 and is reported as closed as of 2017-09-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175029M_Closure Letter_09082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175029M/420175029M_Closure%20Letter_09082017.pdf\n\n420175029M_Closure Letter_09082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175029M/420175029M_Closure%20Letter_09082017_text.pdf\n\n420175029M_Notice of Amendment_08072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175029M/420175029M_Notice%20of%20Amendment_08072017.pdf\n\n420175029M_Notice of Amendment_08072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175029M/420175029M_Notice%20of%20Amendment_08072017_text.pdf\n\n420175029M_Operator Response to Notice (Amended Procedures)_09072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175029M/420175029M_Operator%20Response%20to%20Notice%20(Amended%20Procedures)_09072017.pdf\n\n420175029M_Closure Letter_09082017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 8, 2017\nMr. Brent Backes\nDCP Midstream\nGeneral Counsel and Vice President\n370 17th Street, Suite 2500\nDenver, CO 80202\nCPF 4-2017-5029M\nDear Mr. Backes:\nOn August 7, 2017, the Pipeline and Hazardous Materials Safety Administration issued to DCP\nMidstream (DCP), a Notice of Amendment which proposed amendment of your procedures.\nDCP submitted its amended procedures on September 7, 2017. My staff reviewed the amended\nprocedures, and it appears that inadequacies outlined in this Notice of Amendment have been\ncorrected.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nFrank Causey\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420175029M_Notice of Amendment_08072017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 7, 2017\nMr. Brent Backes\nDCP Midstream\nGeneral Counsel and Vice President\n370 17th Street, Suite 2500\nDenver, CO 80202\nCPF 4-2017-5029M\nDear Mr. Backes:\nOn multiple dates between the months of May and December of 2016, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code inspected the DCP Midstream (DCP) procedures for operations, maintenance,\nintegrity management and emergency response in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nDCP’s plans or procedures, as described below:\n1. §195. 402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nDCP’s written procedure, B-01, Section 5 does not include a process to calculate a reasonable\ninitial estimate of the amount of released product and a written procedure for submitting additional\ntelephonic reports when new information becomes available as required by §195.52 (c) and (d).\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nDCP’s procedure IP-005, is inadequate and fails to identify permissible repair methods for each\ntype of defect.\nDuring the inspection DCP provided IP-005: Pipe Repair procedure which states, “allowable repair\nmethods: Allowable repair methods are detailed in the Liquid O&M Manual Procedure F-20\nPipeline Repairs, Gas O&M Manual Procedure M-05 Pipeline Repairs, and the DCP\nMidstream Required Practice, Pipeline Repair and Lowering”.\nThe PHMSA inspector reviewed Pipeline Repair and Lowering - required practice that describes\nthe methods and requirements for the repair of all hydrocarbon pipelines (September 2012) and\nTable 1: Repair Matrix within this required practice and this procedure is not adequate.\nDCP provided revised procedure (June 2016). Based on review of this procedure, it appears that it\nmet the requirement.\n3. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n2\n\n\n\nDuring the inspection, the PHMSA inspector reviewed DCP’s pressure testing procedures (Section\nE) and IP-016 (SCC Susceptibility Analysis). IP- 016, Section 2.4.2 states,\nLines on which Noteworthy SCC Has Been Found\nThe response requirements for lines on which noteworthy SCC has been found are more\nstringent than those for lines without noteworthy SCC, as shown in Figure 4.\nSCC Assessments\nDepending on the severity of SCC found, one of several responses is required: a spike\nhydrostatic test, an in-line inspection, or SCCDA.\n Lines that have experienced an in-service rupture are automatically assigned a\nVery High SCC susceptibility rating. These lines require an immediate pressure\nreduction and a spike hydrostatic test. Where practical, the spike test should be\ncompleted within 90 days of the release. These lines shall be placed in a\nhydrostatic retest program for future management of SCC.\n For other lines with a Very High SCC susceptibility rating, an immediate pressure\nreduction and a spike hydrostatic test is also required.\n For lines with a High SCC susceptibility rating, a pressure reduction is optional\nand the line requires either a spike hydrostatic test or an in-line inspection with a\ntool capable of reliably detecting and sizing SCC.\n For lines with a Medium SCC susceptibility rating, SCCDA is required.\n For lines with a Low SCC susceptibility rating, no additional SCC integrity\nassessment is required until the next SCC susceptibility assessment.\nAnd, section 2.7: Reassessment intervals states: The SCC Project Manager in conjunction with the\nSCC SME is responsible for setting a reassessment interval for all segments with a Very High or\nHigh susceptibility. The reassessment interval may be based on the expected remaining life of\nSCC that may still exist on the line with a suitable factor of safety.\nError! Reference source not found., taken from ASME B31.8S Appendix A-3, can be used to\nestablish reassessment intervals. Other methods of estimating the remaining life may be used if\njustified by an engineering analysis. Consideration may be given to shorter reassessment intervals\nfor lines that have not been previously pressure tested using a spike test or in-line inspected using\na crack detection tool.\nWhen the PHMSA inspector requested DCP to provide the guidance or instruction on how to\nperform Spike test, the operator provided Section E, Pressure Testing. Based on review of the\npressure testing procedures, DCP failed to include “Spike Test”.\n4. §195. 402 Procedural manual for operations, maintenance, and emergencies\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\n3\n\n\n\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nDuring the inspection, the PHMSA inspectors reviewed DCP’s H-11: Electrical Isolation and\ndetermined the process does not provide adequate direction to personnel to protect the pipeline\nagainst damage from fault currents or lightning and take protective measures at insulating devices.\n5. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nDCP does not give detailed information on what precautions must be taken to minimize damage\nto coating used for bores and directional drills.\nDCP’s CORR-2160 procedure is inadequate.\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 DCP Southern Hills maintain documentation of the safety\n4\n\n\n\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Jon Manning, Acting Director, SW Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 4-2017-5029M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nIn regard to Item 2 listed above, DCP Southern Hills updated Pipeline Repair and Lowering – The\nRequired Practice (RP) and provided in June 2016. After considering the material provided,\nPHMSA deemed the modifications to be adequate.\nSincerely,\nFrank Causey\nActing Director, SW Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5","truncated":false,"body_characters":12085}