# HIGH POINT GAS GATHERING, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 420207004
- **title:** HIGH POINT GAS GATHERING, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2020-04-24
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(c)(13), 195.49, 195.573(a)(1), 195.583(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420207004.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420207004.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420207004
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420207004
**body:**

Notice of Probable Violation involving HIGH POINT GAS GATHERING, LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(13),  195.49,  195.573(a)(1),  195.583(a). The case was opened on 2020-04-24 and is reported as closed as of 2021-06-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420207004_Closure Letter_06222021_(19-164169S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_Closure%20Letter_06222021_(19-164169S).pdf

420207004_Closure Letter_06222021_(19-164169S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_Closure%20Letter_06222021_(19-164169S)_text.pdf

420207004_Final Order_01042021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_Final%20Order_01042021.pdf

420207004_Final Order_01042021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_Final%20Order_01042021_text.pdf

420207004_NOPV PCO_04242020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_NOPV%20PCO_04242020.pdf

420207004_NOPV PCO_04242020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_NOPV%20PCO_04242020_text.pdf

420207004_Operator Response to Notice_06112020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420207004/420207004_Operator%20Response%20to%20Notice_06112020.pdf

420207004_Final Order_01042021_text.pdf

January 4, 2021
VIA ELECTRONIC MAIL TO: mrowland@3cmidstream.com
Mr. Matthew Rowland
President and Chief Executive Officer
Third Coast Midstream Holdings, LLC
1501 McKinney Street, Suite 800
Houston, Texas 77010
Re: CPF No. 4-2020-7004
Dear Mr. Rowland:
Enclosed please find the Final Order issued in the above-referenced case. It withdraws an
allegation of violation, makes other findings of violation and specifies actions that need to be
taken by your operating entity, High Point Gas Gathering, LLC, to comply with the pipeline
safety regulations. When the terms of the compliance order have been completed, as determined
by the Director, Southwest Region, this enforcement action will be closed. Service of the Final
Order by electronic mail is effective upon the date of transmission as provided under 49 C.F.R. §
190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Lawrence Rearick, Director, Pipeline Integrity, High Point Gas Gathering, LLC,
lrearick@3cmidstream.com
Mr. Kevin Stanley, Senior Manager, EHS, High Point Gas Gathering, LLC,
kstanley@3cmidstream.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Third Coast Midstream Holdings, LLC, ) d.b.a. High Point Gas Gathering, LLC, )
)
)
)
Respondent. )
____________________________________)
CPF No. 4-2020-7004
FINAL ORDER
From May 13, 2019, through May 15, 2019, pursuant to 49 U.S.C. § 60117, a representative of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of High Point
Gas Gathering, LLC’s (High Point or Respondent) 10-inch crude pipeline from Viosca Knoll-
817 production platform to the Main Pass-290 platform in the Gulf of Mexico. High Point is an
operating entity of Third Coast Midstream Holdings, LLC.1
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated April 24, 2020, a Notice of Probable Violation and Proposed
Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R. § 190.205. In
accordance with 49 C.F.R. § 190.207, the Notice proposed finding that High Point had
committed three violations of 49 C.F.R. Part 195 and proposed ordering Respondent to take
certain measures to correct the alleged violations. The warning item required no further action
but warned the operator to correct the probable violation or face possible future enforcement
action.
High Point responded to the Notice by letter dated June 11, 2020 (Response). The company
contested one of the allegations and submitted additional records in response to the Notice.
Respondent did not request a hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows:
1 Third Coast Midstream website, Third Coast Midstream's W9 Forms for Our Operating Entities, available at
https://www.3cmidstream.com/customer-resources html (last accessed November 15, 2020).



CPF 4-2020-7004
Page 2
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(13), which states:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations
and maintenance activities and handling abnormal operations and
emergencies. This manual shall be reviewed at intervals not exceeding 15
months, but at least once each calendar year, and appropriate changes made
as necessary to insure that the manual is effective….
(b) ….
(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:
(1) ….
(13) Periodically reviewing the work done by operator personnel to
determine the effectiveness of the procedures used in normal operation and
maintenance and taking corrective action where deficiencies are found.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(13) by failing to
periodically review the work performed by its operating personnel to determine the effectiveness
of its Operation and Maintenance (O&M) procedures and take corrective action where
deficiencies are found. Specifically, the Notice alleged that High Point failed to provide any
records to demonstrate that it periodically reviewed the work of Local Operations Supervision,
AMID Training personnel, third parties, and others designated by its O&M procedures to
determine compliance and effectiveness since 2017.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(c)(13) by failing to
periodically review the work performed by its operating personnel to determine the effectiveness
of its O&M procedures and take corrective action where deficiencies are found.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1), which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine
whether cathodic protection required by this subpart complies with
§195.571:
(1) Conduct tests on the protected pipeline at least once each calendar
year, but with intervals not exceeding 15 months. However, if tests at those
intervals are impractical for separately protected short sections of bare or
ineffectively coated pipelines, testing may be done at least once every 3
calendar years, but with intervals not exceeding 39 months.
The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct an
annual cathodic protection (CP) survey on its 10-inch offshore crude pipelines at Viosca Knoll-
817 to Main Pass-290 at least once each calendar year, but with intervals not exceeding 15



CPF 4-2020-7004
Page 3
months to ensure that the pipeline is protected. Specifically, the Notice alleged that High Point
provided CP survey reports for 2016 and 2017 performed by the previous operator, Genesis
Offshore Holdings, but stated that a CP survey was not performed in 2018.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct
an annual CP survey on its 10-inch offshore crude pipelines at Viosca Knoll-817 to Main Pass-
290 at least once each calendar year, but with intervals not exceeding 15 months to ensure that
the pipeline is protected.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.583(a), which states:
§ 195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed
to the atmosphere for evidence of atmospheric corrosion, as follows:
If the pipeline is located: Then the frequency of inspection is:
Onshore At least once every 3 calendar years, but
with intervals not exceeding 39 months
Offshore At least once each calendar year, but
with intervals not exceeding 15 months
The Notice alleged that Respondent violated 49 C.F.R. § 195.583(a) by failing to inspect
exposed portions of its 10-inch offshore crude pipelines from Viosca Knoll-817 to Main Pass-290
for evidence of atmospheric corrosion (A/C) at least once each calendar year, with intervals not to
exceed 15 months. Specifically, the Notice alleged that High Point’s written procedure, OM-195 –
14.5 Atmospheric Corrosion Rev. 1 Eff 09/04/2018, section 14.5.0 2.a. ii. Monitoring for
Atmospheric Corrosion, required pipelines located offshore to be inspected for evidence of
atmospheric corrosion at least once each calendar year, but with intervals not exceeding 15 months.
In addition, the Notice alleged High Point’s written procedure required personnel to record
atmospheric corrosion inspections. Yet, the Notice alleged, when the PHMSA inspector requested
A/C inspections for 2016, 2017, and 2018, High Point only provided A/C inspections performed in
2016 and 2017 by the previous operator, Genesis Offshore, and stated that an A/C inspection was not
performed on the system for calendar year 2018.
In its Response, High Point contested this allegation of violation. High Point stated that its 2018
A/C inspection records were subsequently located and provided its 2018 Piping Inspection Report.
The Director contended the Piping Inspection Report documentation does not demonstrate
compliance with § 195.583(a) but did not explain the reason. Based on my review of the record, I
find that the record demonstrates Respondent inspected the pipeline for evidence of atmospheric
corrosion. The Piping Inspection Report includes 25 data points where metal loss was measured;
notations for inactive pitting; a map of inactive pitting and light active external corrosion; and several
pictures. Accordingly, after considering all of the evidence, I find that High Point inspected the
exposed portions of its 10-inch offshore crude pipeline from Viosca Knoll-817 to Main Pass-290 for



CPF 4-2020-7004
Page 4
evidence of A/C in December 2018. Based upon the foregoing, I hereby order that Item 4 be
withdrawn.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 2, 3, and 4 in the Notice for
violations of 49 C.F.R. §§ 195.402(c)(13), 195.573(a)(1), and 195.583(a), respectively. Under
49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601. The Director has indicated that Respondent has taken the
following actions to address one of the cited violations:
1. With respect to the violation of § 195.573(a)(1) (Item 3), Respondent provided
records demonstrating that it conducted an annual CP survey on its 10-inch offshore
crude pipeline at Viosca Knoll-817 to Main Pass-290 on June 14, 2019, and the CP
reading was within criteria. Accordingly, I find that compliance has been achieved
with respect to this violation.
With respect to the alleged violation of § 195.583(a) (Item 4), this Item and the proposed
compliance order items are withdrawn. Therefore, the compliance terms proposed in the Notice
for Items 3 and 4 are not included in this Order.
As for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and 49
C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with
the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.402(c)(13) (Item 2), Respondent must
conduct a review for work done by operating personnel to determine the effectiveness
and adequacy of its O&M procedures.
2. All documentation demonstrating compliance must be submitted to the Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration, 8701
South Gessner, Suite 630, Houston, Texas 77074 for review within 120 days of
receipt of the Final Order.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
It is requested (not mandated) that Respondent maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total to the
Director. It is requested that these costs be reported in two categories: (1) total cost associated
with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated



CPF 4-2020-7004
Page 5
with replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each
day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
WARNING ITEM
With respect to Item 1, the Notice alleged probable violation of Part 195, but identified it as a
warning item pursuant to § 190.205. The warning was for:
49 C.F.R. § 195.49 (Item 1) ─ Respondent’s alleged failure to complete and
submit its DOT Form PHMSA F 7000-1.1 (Annual Report) for the 6.145 miles of
crude oil pipeline for calendar years 2017 and 2018 within the required time frames.
If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject
to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this
Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and
meet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective
action, remain in effect unless the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
January 4, 2021
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

420207004_Closure Letter_06222021_(19-164169S)_text.pdf

ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
June 22, 2021
Matthew Rowland
President and Chief Executive Officer
Third Coast Midstream Holdings, LLC
1501 McKinney Street, Suite 800
Houston, Texas 77010
CPF 4-2020-7004
Dear Mr. Rowland:
On January 4, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to High Point Gas Gathering, LLC a Final Order in the above-referenced case. This Order included
a Compliance Order and a Warning Item. Based on our review of the documentation High Point
provided, PHMSA has determined that you have complied with the terms of the Final Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
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