{"operation":"document","citation":"CPF 420195009M","title":"TALOS ENERGY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-03-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420195009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420195009M","body":"Notice of Amendment involving TALOS ENERGY, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3). The case was opened on 2019-03-08 and is reported as closed as of 2020-02-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420195009M_Closure Letter_02282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195009M/420195009M_Closure%20Letter_02282020.pdf\n\n420195009M_Closure Letter_02282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195009M/420195009M_Closure%20Letter_02282020_text.pdf\n\n420195009M_Notice of Amendment_03082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195009M/420195009M_Notice%20of%20Amendment_03082019.pdf\n\n420195009M_Notice of Amendment_03082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195009M/420195009M_Notice%20of%20Amendment_03082019_text.pdf\n\n420195009M_Operator Response to Notice_06192019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195009M/420195009M_Operator%20Response%20to%20Notice_06192019.pdf\n\n420195009M_Notice of Amendment_03082019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 8, 2019\nMelissa Logan\nRegulatory Manager\nTalos Energy, LLC\n500 Dallas Street\nHouston, Texas 77002\nCPF-4-2019-5009M\nDear Ms. Logan:\nFrom July 31, 2017 to October 19, 2017, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nTalos Energy, LLC (Talos) procedures for the Main Pass 72A offshore liquid platform.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTalos 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 manual of\nwritten procedures for conducting normal operations and maintenance activities and\nhandling abnormal operations and emergencies. This manual shall be reviewed at intervals\nnot exceeding 15 months, but at least once each calendar year, and appropriate changes\nmade as necessary to ensure that the manual is effective. This manual shall be prepared\nbefore initial operations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted\nThroughout the Talos Operation & Maintenance Manual the procedures replicate, paraphrase and\nreference the regulations. The procedures need to provide specific detail, unique to Talos,\ndiscussing how they will safely complete the process in order to satisfy the requirements of\n§195.402(a).\n\n\n\nThe following procedures in the Talos Operations & Maintenance Manual need to be amended to\ninclude the necessary provisions to comply with the code sections as intended:\n1. Section 1 Introduction, parrots the code and lacks the specificity necessary to comply with\n2. 3. 4. 5. 6. 7. §195.402(c)(13);\nSection 3.2 Startup and Section 3.3 Shutdown, parrots the code and does not discuss starting\nup and shutting down a pipeline in enough detail to satisfy §195.402(c)(7);\nSection 13 Abnormal Operations, parrots the code, references the previous operator, and\ndoes not discuss the following items in enough detail to satisfy §195.402(d); responding to,\ninvestigating and correcting abnormal operating conditions, follow up monitoring, correcting\nvariations from normal operation, accurately listing appropriate personnel to notify, and\nperiodically reviewing the response of operator personnel to determine the effectiveness of\nresponding to abnormal operations;\nSection 14.1 Safety Related Condition, parrots the code and lacks the specificity necessary\nto comply with §195.402(f);\nSection 16 Welder Qualifications, parrots the code and does not discuss the following items\nin enough detail to satisfy §195.214, §195.222(a), §195.226(a), and §195.234(c); using a\nqualified welding procedure, qualifying tests, qualifying welders, arc burns and ground wires,\nand non-destructive testing of welding;\nSection 18 Damage Prevention, incorrectly labels the Facility Supervisor position and lacks\nthe specificity necessary to comply with §195.402(c)(12); and\nSection 19 Emergency Response Plans, parrots the code and does not discuss the following\nitems in enough detail to satisfy §195.402(c)(5), §195.402(e), §195.403(a), §195.403(b);\nreceiving, identifying and classifying Notices of Events, response guidelines, emergency\nshutdown or pressure reduction, controlling spills to minimize possible ignition, minimizing\npublic exposure to injury, characteristics and hazards of hazardous liquids transported,\nconditions that are likely to cause emergencies, steps necessary to control a release of\nhazardous liquid, types, sizes and consequences of fire and appropriate response, review of\nemergency response personnel performance, and training of supervisors on emergency\nresponse procedures.\nTalos must amend its processes and procedures to adequately describe the requirements for the\nprocedures listed above and to ensure compliance with §195.402(a).\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following to provide safety during maintenance and\nnormal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with each of\nthe requirements of this subpart and subpart H of this part.\nThroughout the Talos Operation & Maintenance Manual the procedures replicate, paraphrase and\nreference the regulations. The procedures need to provide specific detail, unique to Talos,\ndiscussing how they will safely complete the process in order to satisfy the requirements of\n§195.402(c)(3)\n2\n\n\n\nThe following procedures in the Talos Operations & Maintenance Manual need to be amended to\ninclude the necessary provisions to comply with the code sections as intended:\n1. 2. 3. 4. 5. 6. Section 4.4 Record Retention, parrots the code and does not discuss maintaining pump station\noperating records and the retention of maps and records of cathodic systems in sufficient detail\nto satisfy §195.404(b) and §195.589(a);\nSection 8.1 Scraper & Sphere Facilities, parrots the code and fails to discuss safety devices\non scraper and sphere facilities in sufficient detail to satisfy §195.426;\nSection 9.1 Maximum Operating Pressure, does not discuss the establishment of Maximum\nOperating Pressure in sufficient detail to satisfy §195.406(a);\nSection 10 Corrosion Control, parrots the code and does not discuss the following items in\nenough detail to satisfy §195.561, §195.571, §195.573, §195.575(a), §195.577(a), §195.579,\n§195.581(a) §195.583(a), §195.585(a) and §195.587; repair of exposed pipe, corrosion\nmonitoring criteria, where and how corrosion testing is done, correction of identified corrosion\ndeficiencies, electrical isolation of submerged pipelines, testing for and responding to stray\ncurrents, investigating and remediating internal corrosion, corrosion inhibitor testing,\nexamining removed pipe, inspecting aboveground pipelines for atmospheric corrosion,\nrepairing and replacing externally corroded pipe, and evaluating remaining strength of\ninternally and externally corroded pipe;\nSection 11.1 Valve Inspections and Section 11.2 Valve Inspection Procedure, parrots the\ncode and fails to discuss valve maintenance in sufficient detail to satisfy §195.420(a); and\nSection 17.1 Testing Requirements, parrots the code and fails to discuss pressure testing in\nenough detail to satisfy §195.302(b).\nTalos must amend its process and procedures to adequately describe the requirements for the\nprocedures listed above and to ensure compliance with §195.402(c)(3).\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).\n3\n\n\n\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 90 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 Talos Energy, LLC 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 McDaniel, Director, Southwest Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF-4-2019-5009M and, for each document you submit, please provide a copy in\nelectronic 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\n420195009M_Closure Letter_02282020_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 28, 2020\nMelissa Logan\nRegulatory Manager\nTalos Energy, LLC\n500 Dallas Street\nHouston, Texas 77002\nCPF 4-2019-5009M\nDear Ms. Logan:\nFrom July 31, 2017 through October 16, 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 Talos Energy, LLC (Talos) procedures in\nHouston, Texas. As a result of the inspection, Talos was issued a Notice of Amendment on July\n24, 2018, which proposed amendment of your procedures.\nTalos submitted its amended procedures on August 24, 2018 and January 7, 2019. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have 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\nOffice of Pipeline Safety","truncated":false,"body_characters":11466}