# AMERICAN MIDSTREAM (SEACREST), LP — Warning Letter

- **operation:** document
- **citation:** CPF 42022030WL
- **title:** AMERICAN MIDSTREAM (SEACREST), LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-01-27
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.465(a), 192.481(a), 192.491(c), 192.605(a), 192.745(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42022030wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42022030wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42022030wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42022030WL
**body:**

Warning Letter involving AMERICAN MIDSTREAM (SEACREST), LP. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.481(a),  192.491(c),  192.605(a),  192.745(a). The case was opened on 2022-01-27 and is reported as closed as of 2022-01-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42022030WL_Warning Letter_01272022_(20-171915).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022030WL/42022030WL_Warning%20Letter_01272022_(20-171915).pdf

42022030WL_Warning Letter_01272022_(20-171915)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022030WL/42022030WL_Warning%20Letter_01272022_(20-171915)_text.pdf

42022030WL_Warning Letter_01272022_(20-171915)_text.pdf

WARNING LETTER
ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
January 27, 2022
Matthew Rowland
Chief Executive Officer
American Midstream (Seacrest), LP
Third Coast Midstream, LLC
1501 McKinney Street, Suite 800
Houston, Texas 77010
CPF 4-2022-030-WL
Dear Mr. Rowland:
From June 29, 2020 through September 24, 2020, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected American Midstream (Seacrest) LP’s (AMID) offshore gas gathering pipeline
located near St. Mary Parish, Louisiana. AMID is a subsidiary of Third Coast Midstream, LLC
(3CM).
Based on the inspection, it is alleged that AMID has committed probable violations of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the
probable violations are:
1. § 192.465 External corrosion control: Monitoring.
(a) Each pipeline that is under cathodic protection must be tested at least once each
calendar year, but with intervals not exceeding 15 months, to determine whether
the cathodic protection meets the requirements of § 192.463. However, if tests at
those intervals are impractical for separately protected short sections of mains or
transmission lines, not in excess of 100 feet (30 meters), or separately protected
service lines, these pipelines may be surveyed on a sampling basis. At least 10
percent of these protected structures, distributed over the entire system must be
surveyed each calendar year, with a different 10 percent checked each subsequent
year, so that the entire system is tested in each 10-year period.
AMID failed to test its offshore pipeline system to determine the adequacy of cathodic
protection at least once each calendar year, but at intervals not exceeding 15 months, for
calendar year 2018, as required by §192.465(a) and AMID’s own written procedures.



2. AMID’s written procedure, External Corrosion, #14.3, OM-192 – 14.0 Corrosion Control
(Revision #3) Section 6, states:
Each pipeline that is under cathodic protection must be tested at least
once each calendar year, but with intervals not exceeding 15 months
(1x/yr NTE 15 mos), to determine whether the cathodic protection
meets the requirements of §192.463 (See (5) above). However, if
tests at those intervals are impractical for separately protected short
sections of mains or transmission lines, not in excess of 100 feet (30
meters), or separately protected service lines, these pipelines may be
surveyed on a sampling basis. At least 10 percent of these protected
structures, distributed over the entire system must be surveyed each
calendar year, with a different 10 percent checked each subsequent
year, so that the entire system is tested in each 10-year period.
And AMID’s written procedure, Records, #14.8, OM-192 – 14.0 Corrosion Control
(Revision #3) Section 14.8.0 (3), states:
3CM personnel must maintain a record of each analysis, check,
demonstration, examination, inspection, investigation, review,
survey, and test required 49 CFR 192 Subpart I in sufficient detail
to demonstrate the adequacy of corrosion control measures or that
corrosion requiring control measures does not exist. You must retain
these records for at least 5 years, except that records related to 49
CFR Part 192.465(a) and (e) and 192.475(b) must be retained for as
long as the pipeline remains in service.
During PHMSA’s inspection, AMID was unable to provide documentation to show that
annual cathodic protection surveys were conducted or recorded for calendar year 2018, as
required by §192.465(a).
§ 192.491 - Corrosion control records.
(a) . . .
(c) Each operator shall maintain a record of each test, survey, or inspection required
by this subpart in sufficient detail to demonstrate the adequacy of corrosion control
measures or that a corrosive condition does not exist. These records must be retained
for at least 5 years, except that records related to §§ 192.465 (a) and (e) and 192.475(b)
must be retained for as long as the pipeline remains in service.
§ 192.481 - Atmospheric corrosion control: Monitoring.
(a) Each operator must inspect each pipeline or portion of pipeline that is exposed to
the atmosphere for evidence of atmospheric corrosion, as follows:
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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
AMID failed to inspect, or maintain records of any inspection, of its offshore pipelines
exposed to the atmosphere for evidence of atmospheric corrosion at least once each
calendar year, but with intervals not exceeding 15 months, for calendar years 2018 and
2019 as required by §§ 192.481(a) and 192.491(c), and AMID’s written procedures.
AMID’s procedure, Atmospheric Corrosion, #14.5, OM-192 – 14.0 Corrosion Control
(Revision #3), Section 2, states:
2. Monitoring for Atmospheric Corrosion
a. 3CM personnel must inspect each pipeline or portion of
pipeline that is exposed to the atmosphere for evidence of
atmospheric corrosion, as follows:
i. Pipelines located onshore – At least once every 3
calendar years, but with intervals not exceeding 39
months (1/3yrs. NTE 39 mos.).
ii. Pipelines located offshore - At least once each
calendar year, but with intervals not exceeding 15
months (1/yr. NTE 15 mos.).
b. During inspections 3CM personnel must give particular
attention to pipe at soil-to-air interfaces, under thermal
insulation, under disbonded coatings, at pipe supports, in
splash zones, at deck penetrations, and in spans over water.
c. If atmospheric corrosion is found during an inspection,
protection must be provided as described in 14.5.0.
d. 3CM personnel must record atmospheric corrosion
inspections on Form OM-19x- 14.5a Atmospheric Corrosion
Inspection Report.
During the PHMSA inspection, AMID was unable to provide any records to demonstrate
that atmospheric corrosion inspections had been conducted on its offshore pipelines for
calendar years 2018 and 2019 as required by § 192.481(a).
Alternatively, if atmospheric inspections were conducted, AMID failed to follow §
192.491(c) and its written procedures to provide evidence of its annual atmospheric
corrosion surveys for calendar years 2018 and 2019 on Form OM-19x-14.5a Atmospheric
Corrosion Inspection Report.
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3. § 192.605 - Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include procedures
for handling abnormal operations. This manual must be reviewed and updated by the
operator at intervals not exceeding 15 months, but at least once each calendar year.
This manual must be prepared before operations of a pipeline system commence.
Appropriate parts of the manual must be kept at locations where operations and
maintenance activities are conducted.
AMID failed to conduct an annual review of its operations, maintenance, and emergency
manual for calendar years 2015 and 2016 as required by § 192.605(a) and AMID’s written
procedures.
AMID’s procedure, Manual Review, #8.1, OM-192 – 8.0 Normal Operation (Revision #3),
Section 8.1.0, states:
8.1.0 Operations and Maintenance Manual Preparation and Review
1. 3CM 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.
2. This manual shall be reviewed by the 3CM Natural Gas O&M
Review Team at intervals not exceeding 15 months, but at least
once each calendar year, and appropriate changes made as
necessary to ensure that the manual is effective.
3. This manual shall be prepared before initial operations of a
pipeline system commence, and appropriate parts shall be kept
at locations where operations and maintenance activities are
conducted.
. . .
DOCUMENTATION
1. All records indicating review of the O&M Manual by pertinent personnel and
associated changes are retained by the Regulatory Compliance Department and
made available to Company personnel in a number of electronic locations
and/or by hard copy.
During PHMSA’s inspection, AMID was unable to provide documentation that it
conducted annual reviews of its operations, maintenance, and emergency manual for
calendar years 2015 and 2016 as required by § 192.605(a).
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4. §192.745 Valve maintenance: Transmission lines.
(a) Each transmission line valve that might be required during any emergency must
be inspected and partially operated at intervals not exceeding 15 months, but at
least once each calendar year.
AMID failed to inspect and partially operate its transmission line valves at intervals not
exceeding 15 months, but at least once each calendar year for calendar year 2018 as
required by § 192.745(a) and AMID’s written procedures.
AMID’s written procedure, Valve Inspection and Maintenance, #12.5, OM-192 – 12.0
Maintenance (Revision #3), Section 12.5.0 states:
12.5.0 Valve Inspection and Maintenance
1. 3CM Operations will maintain each valve that is necessary for the safe
operation of its pipeline systems in good working order at all times.
2. 3CM Operations shall provide protection for each valve from unauthorized
operation and from vandalism by either locking the valve or locating it within
a locked perimeter fence or secured facility.
3. DOT Emergency Valves – Inspect and partially operate each DOT Emergency
Valve once annually not to exceed 15 months (1x/1yr, NTE 15 mos), to
determine that it is functioning properly (indicated in red in the examples shown
in 12.5.4).
4. DOT Non-Emergency Valves – Inspect DOT Non-Emergency Valves at least
one time every two years, not to exceed 30 months (1x/2yrs, NTE 30 mos) to
ensure that all valves necessary for the safe operation of the pipeline are
maintained in good working order (indicated in green in the examples shown in
Section 12.5.4).
5. Business Critical (non-DOT) Valves – Inspect Business Critical valves at a
frequency determined by Operations based on criticality and site-specific risk
assessment for valves needed for safe, reliable operations (indicated in yellow
in the examples shown in Section 12.5.4).
. . .
DOCUMENTATION
1. Valve inspections shall be recorded on Form OM-19x-12.5a and retained for 5
years (DOT Valves) and the prior inspection for non-DOT and business critical
valves.
2. The valve inspection requirements of this Procedure and any maintenance of
valves shall be documented and dated by the person(s) performing the tasks.
During PHMSA’s inspection, AMID was unable to provide documentation that
transmission line valve inspections were conducted for calendar year 2018. Alternatively,
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if AMID did perform transmission valve inspections for calendar year 2018, it failed to
follow its own procedures that require it to provide documentation of the annual inspection
and partial operation of its transmission line valves.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related
series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,
the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to
a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July
31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the
maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to
exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November
27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum
penalty not to exceed $2,090,022.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to conduct additional enforcement action or penalty assessment proceedings at this
time.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2022-030-WL. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe the
redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Todd Rivera, Senior Manager, Third Coast Midstream, LLC,
TRivera@3CMidstream.com
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