{"operation":"document","citation":"CPF 420195008M","title":"FIELDWOOD ENERGY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-03-11","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(5), 195.402(e)(9), 195.403(c), 195.452(f)(1), 195.555.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420195008M","body":"Notice of Amendment involving FIELDWOOD ENERGY, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(5),  195.402(e)(9),  195.403(c),  195.452(f)(1),  195.555. The case was opened on 2019-03-11 and is reported as closed as of 2019-10-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420195008M_Closure Letter_10172019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195008M/420195008M_Closure%20Letter_10172019.pdf\n\n420195008M_Closure Letter_10172019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195008M/420195008M_Closure%20Letter_10172019_text.pdf\n\n420195008M_Notice of Amendment_03112019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195008M/420195008M_Notice%20of%20Amendment_03112019.pdf\n\n420195008M_Notice of Amendment_03112019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195008M/420195008M_Notice%20of%20Amendment_03112019_text.pdf\n\n420195008M_Operator Reponse to Notice_04152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195008M/420195008M_Operator%20Reponse%20to%20Notice_04152019.pdf\n\n420195008M_Notice of Amendment_03112019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 11, 2019\nJoel Plauche\nVice President, HSE and Regulatory\nFieldwood Energy, LLC\n2014 W. Pinhook Rd, Suite 800\nLafayette, Louisiana 70508\nCPF-4-2019-5008M\nDear Mr. Plauche:\nFrom July 18, 2017 to October 27, 2017, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nFieldwood Energy’s procedures for Operations and Maintenance in Lafayette, 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. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(5) Analyzing pipeline accidents to determine their causes.\nFieldwood Energy’s Safe Work Practice, Section C, Chapter 4: Incident Investigation Process was\nfound to be inadequate and must be amended to ensure that this document includes procedures for\nanalyzing pipeline accidents to determine their causes. The Inspector reviewed Section C, Chapter\n4 and found that the Incident Investigation Process did not include any detailed analysis techniques\nor methods to analyze pipeline accidents to determine their causes. The Inspector also reviewed\nthe DOT Pipeline Repair Protocols which states that failures shall be thoroughly investigated prior\nto repair, and that the completion of a DOT Gas or Hazardous Liquid Pipeline Leak and Repair\n\n\n\nReport will constitute an adequate analysis for investigating failures. Neither the repair protocol\ndocument nor the report includes adequate procedures for analyzing pipeline accidents to\ndetermine their causes.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(e) Emergencies. The manual required by paragraph (a) of this section must\ninclude procedures for the following to provide safety when an emergency\ncondition occurs:\n(9) Providing for a post-accident review of employee activities to determine\nwhether the procedures were effective in each emergency and taking\ncorrective action where deficiencies are found.\nFieldwood Energy’s O&M Manual, Section C, Chapter 4: Incident Investigation Process was\nfound to be inadequate and must be amended to include a requirement for post-accident reviews\nof employee activities to determine whether procedures were effective in each emergency and that\ncorrective actions were taken where deficiencies were found. Fieldwood Energy’s Incident\nInvestigation Process did not include a procedure for conducting post-accident reviews of\nemployee activities to ensure procedures were effective in each emergency and did not include a\nrequirement to take corrective action where deficiencies were found.\n3. §195.403 Emergency Response Training.\n(c) Each operator shall require and verify that its supervisors maintain a\nthorough knowledge of that portion of the emergency response procedures\nestablished under 195.402 for which they are responsible to ensure compliance.\nFieldwood Energy’s Emergency Response Training Document was found to be inadequate and\nmust be amended to ensure that this document includes the requirement for supervisors to maintain\na thorough knowledge of that portion of the emergency response procedures for which they are\nresponsible to ensure compliance, and a procedure for verification of the supervisor’s knowledge.\nThe Inspector reviewed the Emergency Response Training Document and it did not include any\nspecific requirements that supervisors be knowledgeable of that portion of the emergency response\nprocedures for which they are responsible.\n4. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area;\nFieldwood Energy’s Integrity Management Plan (IMP) Section 1.05: Segment Identification:\n2\n\n\n\nWater Transport Analysis was found to be inadequate and must be amended to ensure the process\nto identify segments must account for the full range of relevant factors. The Inspector reviewed\nthe Segment Identification: Water Transport Analysis and found that it did not include\nrequirements to take additional factors into account to better understand water transport of a spilled\ncommodity ( changes in commodity properties due to interaction with the environment,\ncommodity solubility, abnormal stream conditions, such as erosion of stream bottom or bank,\nsubsurface water transport as well as surface water transport, indirect introduction into water, and\nintroduction into water from spray releases. )\n5. §195.555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge\nof that portion of the corrosion control procedures established under\n§195.402(c)(3) for which they are responsible for insuring compliance.\nFieldwood Energy’s Corrosion Control Program document was found to be inadequate and must\nbe amended to ensure that supervisors are required to maintain a thorough knowledge of that\nportion of the corrosion control procedures for which they are responsible for ensuring compliance.\nThe Inspector reviewed the Corrosion Control Program document and it did not contain any\nspecific requirements for corrosion control supervisors to maintain a thorough knowledge of their\ncorrosion control procedures.\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.\nIt is requested (not mandated) that Fieldwood Energy, LLC maintain documentation of the safety\n3\n\n\n\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-4-2019-5008M 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\n420195008M_Closure Letter_10172019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 17, 2019\nJoel Plauche\nVice President, HSE and Regulatory\nFieldwood Energy, LLC\n2014 W. Pinhook Rd, Suite 800\nLafayette, Louisiana 70508\nCPF 4-2019-5008M\nDear Mr. Plauche:\nFrom July 18, 2017 to October 27, 2017, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Fieldwood Energy, LLC (Fieldwood)\nprocedures in Lafayette, Louisiana. As a result of the inspection, Fieldwood was issued a Notice\nof Amendment on March 11, 2019.\nFieldwood submitted its amended procedures on May 9, 2019. My staff reviewed the amended\nprocedures and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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\n\n420195008M_Operator Reponse to Notice_04152019.pdf\n\nIÉ FIELDWOOD ENERGY\nRECEIVED\nAPR 1 5 2019\nApril 15, 2019\nBI:\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nU.S. Department of Transportation\n8701 S. Gessner, Suite 630\nHouston, TX 77074\nSUBJECT: CPF-4-2019-5008M - Notice of Amendment\nMs. McDaniel,\nFieldwood received the above listed Notice of Amendment.\nFieldwood is notifying your office that we intend to take actions to update the\nprocedures and processes to properly identify the elements not clearly defined.\nItem #1: - Fieldwood is working on updating the current incident tracking system to\ninclude a section that will store the information regarding documentation of analyzing\nthe pipeline accidents to determine their causes.\nItem #2: - Fieldwood is working on updating the current incident tracking system to\ninclude a section for post-accident review of employee activities to determine if\nprocedures were part of the cause.\nItem #3: - Fieldwood's supervisors are required to be trained in Emergency Response.\nWe have worked on clearly identifying the requirement for Supervisors to be trained in\nour programs. And verifying it is clearly stated.\nItem #4: - The Integrity Management Plan has been updated to include the missing\nstated information.\nItem #5: - Fieldwood does require supervisors to be trained in corrosion control\nprocedures. We have updated our program to clearly state and document supervisor\ntraining.\nFieldwood Energy LL.C•2014 W. Pinhook Rd. Suite 800-Lafayette, LA 70508 • (337) 354-8000 main\n\n\n\nFieldwood will continue to update and correct the programs to clear up the verbiage and\nverify proper documentation to support.\nPlease contact me at (337) 354-8015 or via email at trisha.hackett@fwellc.com with any\nquestions or concerns.\nSincerely,\nJusna tackett\nTrisha Hackett\nCompliance Coordinator","truncated":false,"body_characters":12719}