{"operation":"document","citation":"CPF 420192002M","title":"FIELDWOOD ENERGY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-09-30","effective_on":null,"summary":"CLOSED notice of amendment citing 191.5(b), 192.465(d), 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420192002m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420192002m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420192002m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420192002M","body":"Notice of Amendment involving FIELDWOOD ENERGY, LLC. PHMSA's enforcement data identifies the cited regulations as 191.5(b),  192.465(d),  192.605(b)(2). The case was opened on 2019-09-30 and is reported as closed as of 2019-11-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420192002M_Closure Letter_11142019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192002M/420192002M_Closure%20Letter_11142019.pdf\n\n420192002M_Closure Letter_11142019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192002M/420192002M_Closure%20Letter_11142019_text.pdf\n\n420192002M_Notice of Amendment_09302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192002M/420192002M_Notice%20of%20Amendment_09302019.pdf\n\n420192002M_Notice of Amendment_09302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192002M/420192002M_Notice%20of%20Amendment_09302019_text.pdf\n\n420192002M_Operator Response to Notice_11012019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420192002M/420192002M_Operator%20Response%20to%20Notice_11012019.pdf\n\n420192002M_Notice of Amendment_09302019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 30, 2019\nPatrick Eiland\nSenior Vice President, HSE and Regulatory\nFieldwood Energy, LLC\n2000 W Sam Houston Pkwy S.\nSuite 1200\nHouston TX 77042\nCPF 4-2019-2002M\nDear Mr. Eiland:\nFrom April 1, 2019 to May 24, 2019, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nFieldwood Energy, LLC (Fieldwood Energy) procedures for Operations and Maintenance in\nLafayette, Louisiana.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nFieldwood Energy’s plans or procedures, as described below:\n1. §191.5 Immediate notice of certain incidents.\n(b) Each notice required by paragraph (a) of this section must be made to the\nNational Response Center either by telephone to 800-424-8802 (in Washington, DC,\n202 267-2675) or electronically at http://www.nrc.uscg.mil and must include the\nfollowing information:\n\n\n\n(1) Names of operator and person making report and their telephone numbers.\n(2) The location of the incident.\n(3) The time of the incident.\n(4) The number of fatalities and personal injuries, if any.\n(5) All other significant facts that are known by the operator that are relevant\nto the cause of the incident or extent of the damages.\nFieldwood Energy’s O&M Procedure, Section 6 Chapter 4: DOT Accident Reporting was found\nto be inadequate. The procedure includes guidance for the release of a hazardous liquid or carbon\ndioxide, but does not include natural gas in the list of commodities that require reporting incidents\nto the National Response Center, and does not include required information for reporting a release\nof natural gas.\nFieldwood Energy must amend its procedures to ensure that the DOT incident/accident reporting\nrequirements include guidance for natural gas in accordance with 49 CFR Part 191-Transportation\nof Natural and Other Gas by Pipeline; Annual Reports, Incident Reports, and Safety Related\nConditions.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of Subpart I of this part.\nFieldwood Energy’s O&M Procedure, Section 4 Chapter 1: Corrosion Control Program was found\nto be inadequate. Fieldwood Energy’s Corrosion Control Program procedure states during\ninspections, condition of the coating shall be noted and reported. The Corrosion Control Program\nprocedure also states that atmospheric corrosion discovered during inspection shall be evaluated\nand remediated where required to maintain adequate protection. Although the procedure does\nprovide a requirement to conduct atmospheric corrosion inspections, it does not include the\ngrading criteria used to document atmospheric corrosion inspections. Fieldwood Energy uses a\ntwo-tier grading criteria for atmospheric corrosion: type of damage and grade of damage. Types\nof atmospheric damage is listed as follows: 1-disbonding, 2-cracking, 3-peeling, 4-blistering, 5-\nrust stains, 6-algae, dirt, grease, and 7-other. Grade of damage is listed as follows: A-coating\ndamage less than 2% no touch up required), B-2-5% coating damage (some touch up required), C-\n5-10% coating damage (considerable touch up required) and D-critical damage exceeds 10%\n(complete recoating required). None of the above criteria is included in the Corrosion Control\nProgram procedure and is only listed on the Atmospheric Survey Form.\nFieldwood Energy must amend its procedures to ensure that the procedure provides safety during\nmaintenance and operations for controlling corrosion. The procedure must be amended to provide\ndetailed information of how the atmospheric corrosion grading criteria will be implemented.\n2\n\n\n\n3. §192.465 External corrosion control: Monitoring.\n(d) Each operator shall take prompt remedial action to correct any deficiencies\nindicated by the monitoring.\nFieldwood Energy’s O&M Procedure, Section 4 Chapter 1: Corrosion Control Program was found\nto be inadequate. Fieldwood Energy’s procedure states that should a test lead be found damaged\nor defective, the test lead must be repaired in a reasonable time period. The procedure should\ndefine “a reasonable time period.” Fieldwood Energy’s Corrosion control procedure should be\nalso be amended to define “a reasonable time period” for all corrosion control deficiencies found.\nFieldwood Energy must amend its procedures to ensure that there is a requirement for the operator\nto take prompt remedial action to correct any deficiencies indicated by the monitoring.\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 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\n3\n\n\n\nIt is requested (not mandated) that Fieldwood Energy maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Mary L. McDaniel, P.E., Director, Southwest Region,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 4-2019-2002M and, for each document you submit, please provide a\ncopy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4\n\n420192002M_Closure Letter_11142019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 14, 2019\nPatrick Eiland\nSenior Vice President, HSE and Regulatory\nFieldwood Energy, LLC\n2000 W Sam Houston Pkwy S., Suite 1200\nHouston, Texas 77042\nCPF 4-2019-2002M\nDear Mr. Eiland:\nFrom April 1, 2019 to May 24, 2019, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Fieldwood Energy’s procedures in Lafayette, Louisiana. As\na result of the inspection, Fieldwood Energy was issued a Notice of Amendment on September 30,\n2019, which proposed amendment of your procedures.\nFieldwood Energy submitted its amended procedures on November 4, 2019. My staff reviewed\nthe amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":9673}