# PLAINS PIPELINE, L.P. — Safety Order

- **operation:** document
- **citation:** CPF 42024029NOPSO
- **title:** PLAINS PIPELINE, L.P. — Safety Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-05-17
- **effective on:** Not available
- **summary:** CLOSED safety order.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024029nopso.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024029nopso
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024029NOPSO
**body:**

Safety Order involving PLAINS PIPELINE, L.P.. The dataset does not identify a cited regulation for this case. The case was opened on 2024-05-17 and is reported as closed as of 2026-01-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024029NOPSO_Closure Letter_01222026_(24-302881).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024029NOPSO/42024029NOPSO_Closure%20Letter_01222026_(24-302881).pdf

42024029NOPSO_Closure Letter_01222026_(24-302881)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024029NOPSO/42024029NOPSO_Closure%20Letter_01222026_(24-302881)_text.pdf

42024029NOPSO_Consent Agreement and Order_07082025_(24-302881).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024029NOPSO/42024029NOPSO_Consent%20Agreement%20and%20Order_07082025_(24-302881).pdf

42024029NOPSO_Consent Agreement and Order_07082025_(24-302881)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024029NOPSO/42024029NOPSO_Consent%20Agreement%20and%20Order_07082025_(24-302881)_text.pdf

42024029NOPSO_Notice of Proposed Safety Order_05172024_(24-302881).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024029NOPSO/42024029NOPSO_Notice%20of%20Proposed%20Safety%20Order_05172024_(24-302881).pdf

42024029NOPSO_Notice of Proposed Safety Order_05172024_(24-302881)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024029NOPSO/42024029NOPSO_Notice%20of%20Proposed%20Safety%20Order_05172024_(24-302881)_text.pdf

42024029NOPSO_Consent Agreement and Order_07082025_(24-302881)_text.pdf

July 8, 2025
VIA ELECTRONIC MAIL TO: chris.chandler@plains.com
Chris R. Chandler
Executive Vice President, and Chief Operating Officer
Plains All American Pipeline, L.P.
333 Clay Street, Suite 1900
Houston, Texas 77002
CPF No. 4-2024-029-NOPSO
Dear Mr. Chandler:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Plains All American
Pipeline, L.P., which was executed on May 14, 2025. Service of the Consent Order and Consent
Agreement by electronic mail is deemed effective upon the date of transmission and
acknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Annie Cook, Counsel for Plains All American Pipeline, L.P., Bracewell LLP,
annie.cook@bracewell.com
Joe Perez, Senior Attorney, Plains All American Pipeline, L.P., joe.perez@plains.com



Ngiabi Gicuhi, Director, HSE Regulatory Compliance, Plains All American Pipeline, L.P.,
Ngiabi.Gicuhi@plains.com
Kevin Cunningham, HSE Regulatory Compliance Programs, Plains All American Pipeline,
L.P., kevin.cunningham@plains.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 )
Plains Pipeline, L.P., )
a subsidiary of Plains All American )
Pipeline, L.P., ) CPF No. 4-2024-029-NOPSO
)
)
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated May 17, 2024, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Proposed Safety Order (Notice) to
Plains Pipeline, L.P., a subsidiary of Plains All American Pipeline, L.P. (Plains or Respondent).
In accordance with 49 CFR § 190.239, the Notice alleged that conditions exist on Plains’ Cotton
Draw Pipeline that pose an integrity risk to public safety, property, or the environment. The
Notice also proposed that Respondent take certain corrective measures to remedy the alleged
conditions and ensure that the public, property, and the environment are protected from the
potential risk.
In response to the Notice, Respondent requested an informal consultation, whereupon the parties
engaged in good-faith settlement discussions that have resulted in the Consent Agreement
attached to this Consent Order that settles all of the allegations in the Notice.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order. Plains is hereby ordered to comply with the terms of the Consent Agreement
pursuant to its terms.
Pursuant to 49 U.S.C. § 60101, et seq., failure to comply with this Consent Order may result in
the assessment of civil penalties as set forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in
referral to the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 CFR § 190.5.
______________________ ______________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Plains Pipeline, L.P., )
a subsidiary of Plains All American )
Pipeline, L.P., ) CPF No. 4-2024-029-NOPSO
)
)
)
Respondent. )
____________________________________)
CONSENT AGREEMENT
From August 7 through 11, 2017 and in March and April of 2023, pursuant to Chapter 601 of
title 49, United States Code, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), investigated the pipeline facilities and records of
Plains Pipeline, L.P., a subsidiary of Plains All American Pipeline, L.P. (Plains or Respondent).
Plains operates the Cotton Draw Pipeline, a segment of its Plains Basin System. The Cotton
Draw Pipeline is comprised of two segments (Section 17 to Cotton Draw 12-inch and Cotton
Draw to El Mar 12-inch), totaling twelve (12) miles of 12-inch API 5L X-52 Grade pipe
originating at an existing field gathering lease in Eddy County, New Mexico, traversing through
Lea County, New Mexico, and terminating at Plains’ Cotton Draw Injection Station in Loving
County, Texas. The Cotton Draw Pipeline expansion was constructed in 2016 and includes a
40,000-barrel breakout tank located at Cotton Draw Station near El Mar, Texas.
As a result of the investigation, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated May 17, 2024, a Notice of Proposed Safety Order (Notice). The
Notice alleged that conditions exist on Respondent’s pipeline system that pose a pipeline
integrity risk to public safety, property, or the environment. The Notice also proposed that Plains
take certain corrective measures to remedy the alleged conditions and ensure that the public,
property, and the environment are protected from the alleged integrity risk.
On July 15, 2024, after receiving a time extension to respond, Plains responded to the Notice by
submitting a written response and request for an informal consultation under 49 CFR
§ 190.239(b)(2). PHMSA and Respondent (the Parties) held informal consultation on August 8,
2024.



As a result of the informal consultation, the Parties agree that settlement of this proceeding and
resolution of the Item 1 compliance order associated with the Final Order (CPF 4-2019-5004)1
by entry into this Consent Agreement (Agreement) is the most appropriate means of resolving
the issues raised in the Notice, will avoid further administrative proceedings or litigation, and is
in the public interest. Therefore, pursuant to 49 CFR § 190.239(b)(2), without adjudication of
any issue of law or fact, and upon consent and agreement, the Parties agree to the following
terms and conditions.
I. General Provisions
1. Respondent acknowledges that as the operator of the pipeline facilities subject to
the Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the
Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative
orders issued thereunder. For purposes of this Agreement, Respondent acknowledges that it
received proper notice of PHMSA’s action in this proceeding and that the Notice states claims
upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq., and the regulations and
orders issued thereunder.
2. Respondent neither admits nor denies any allegations or conclusions in the Notice
or this Agreement, but agrees, for purposes of this Agreement, to complete the actions specified in
Section II of this Agreement (Corrective Measures) and to abide by the terms of this Agreement.
3. After Respondent returns this signed Agreement to PHMSA, the Agency’s
representative will present it to the Associate Administrator for Pipeline Safety, recommending
that the Associate Administrator adopt the terms of this Agreement by issuing an administrative
order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement
constitute an offer of settlement until accepted by the Associate Administrator. Once accepted,
the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement.
4. Respondent consents to the issuance of the Consent Order, and hereby waives any
further procedural requirements with respect to its issuance. Respondent waives all rights to
contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including
all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution
provisions set forth herein.
5. This Agreement shall apply to and be binding upon PHMSA and Respondent, its
officers, directors, and employees, and its successors, assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
6. For all transfers of ownership or operating responsibility of Respondent’s pipeline
system referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice of the
transfer to the Director no later than 60 days after the transfer occurs.
1 The Director agrees to close CPF 4-2019-5004 after the Consent Order and Agreement is executed.



7. This Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this Agreement.
The Parties acknowledge that there are no representations, agreements or understandings relating
to settlement other than those expressly contained in this Agreement, except that the terms of this
Agreement may be construed by reference to the Notice.
8. Nothing in this Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,
et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters
PHMSA’s right of access, entry, inspection, and information gathering or PHMSA’s authority to
bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.
9. This Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a
permit, or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
10. This Agreement does not create rights in, or grant any cause of action to, any third
party not party to this Agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this Agreement. Respondent
agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents,
and representatives from any and all causes of action arising from any acts or omissions of
Respondent or its contractors in carrying out any work required by this Agreement.
11. This Agreement does not constitute a finding of violation of any Federal law or
regulation and may not be used in any civil or administrative proceeding of any kind as evidence
or proof of any fact, fault, or liability, or as evidence of the violation of any law, rule, regulation,
or requirement, except in a proceeding to enforce the provisions of this Agreement.
II. Corrective Measures:
12. Upon issuance of the Consent Order, Respondent agrees to perform the
Corrective Measures set forth below.
13. Plains must perform a review of its Operator Qualification (OQ) program required
by 49 CFR Part 195, Subpart G, and identify any covered tasks for inclusion in its OQ program,
including but not limited to tasks associated with:
a) b) c) d) Ensuring adequate pipeline support during excavation;
Welding and welding inspection on an existing in-service pipeline;
Visual inspection of pipe and components prior to installation;
Visual inspection for internal corrosion;
e) Measuring internal corrosion; and



f) Installation of steel pipe in a ditch.
A report detailing the evaluation, including covered tasks that were identified during the review
for inclusion in Plains’ OQ Plan, must be submitted to the Director, Southwest Region, PHMSA
(Director) within 90 days of issuance of the Order. Plains must submit its OQ Plan and Covered
Task List revised in accordance with Corrective Measure 13 (a) – (f) within 90 days of submission
of the report to the Director.
14. Plains must identify all personnel involved in each of the dig sites where cutouts
were performed as detailed in the Notice, OQ records for the identified personnel, and the tasks
performed, and provide this information to the Director within 30 days of issuance of the Order.
15. Plains must: evaluate the work performed associated with the cutouts and repair
work identified to Plains by the PHMSA inspectors and detailed in the Notice based on the
considerations below and repair records maintained pursuant to applicable Plains procedures;
review procedures for any deficiencies and identify revisions needed in operating and maintenance
procedures; and submit a report to the Director within 90 days of issuance of the Order, detailing
the findings and proposed revisions to the procedures and training needed to remedy any identified
deficiencies. Plains may rely on previous evaluations and/or procedural revisions provided they
were undertaken after the cutouts and repair work and were based on one or more of the
considerations below.
The evaluation and report submitted to the Director must consider whether Plains
completed the following:
a) b) c) d) e) f) g) h) i) Properly purge and isolate the pipeline;
Ensure pipeline repairs were made in a safe manner;
Ensure welding was completed according to the requirements of the qualified
welding procedure and Plains’ operating and maintenance procedures;
Measure residual magnetism and take the appropriate measures to degauss the
pipeline prior to welding;
Receive written approval or generate design drawings prior to installing temporary
vents on the pipeline;
Inspect the inside surface of the pipeline for internal corrosion;
Measure and document the internal corrosion as required by Plains’ procedures;
Document the repair work as required by Plains’ procedures; and
Properly document the destructive testing results for Plains’ recordkeeping
purposes.
16. Plains must develop and implement an internal weld inspection program, including
written procedures, for the Cotton Draw Pipeline to inspect the integrity of the girth welds and
identify action thresholds requiring mitigative measures. The program must use an inline
inspection tool capable of:
a) b) Detecting and sizing cracks and crack growth;
Identifying and sizing any other integrity-threatening defects in the girth welds; and



c) Identifying increases in strain that may threaten the integrity of the girth welds.
Plains must submit its internal weld inspection program and procedures developed in accordance
with the above for approval to the Director within 90 days of issuance of the Order. Plains must
perform the first assessment within 3 years from the date Plains receives approval for its internal
weld inspection program and procedures from Director, perform one reassessment with an inline
inspection tool at an interval determined based on the results of the first assessment, and provide
the final results of both assessments to the Director for approval within 60 days of completing each
of the assessments. This Corrective Measure shall be deemed satisfied upon the completion of the
initial assessment (as specified in the weld inspection program and procedures approved by
PHMSA) and one reassessment with an inline inspection tool at an interval determined based on
the results of the first assessment under the terms of this Corrective Measure. Any further
reassessment is outside of this Agreement and will be conducted in accordance with the intervals
prescribed by Plains’ Integrity Management Plan.
17. Plains must:
a) b) c) d) Perform an effectiveness review of its internal corrosion control program for the
Cotton Draw Pipeline;
Determine the severity and extent of the existing internal corrosion;
Perform testing to determine the specific cause of the internal corrosion; and
Implement the appropriate monitoring, testing, and mitigative measures to ensure
the integrity of the pipeline.
Plains may use previous tests, inspections, assessments, evaluations, monitoring, and/or
mitigative measures provided that they were related to addressing, monitoring, testing, and/or
mitigating internal corrosion on the Cotton Draw Pipeline. Plains must submit a report to the
Director within 60 days of issuance of the Order, providing details of the internal corrosion control
program effectiveness review, the specific cause(s) of the internal corrosion, the procedures that
Plains will implement to test and monitor the effectiveness of the internal corrosion control
program, and the preventative and mitigative measures that will be implemented.
18. Extensions of Time. The Director may grant an extension of time for compliance
with any of the terms of the Agreement upon a written request timely submitted demonstrating
good cause for the extension. The Director shall respond in writing to any such request.
III. Review and Approval Process:
19. With respect to any submission under Section II (Corrective Measures) of this
Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or
in part, the submission; (b) approve the submission on specified, reasonable conditions; (c)
disapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the
Director approves, approves in part, or approves with conditions, Respondent will take all
actions as approved by the Director, subject to Respondent’s right to invoke the dispute
resolution procedures, including but not limited to any conditions the Director identifies. If the
Director disapproves all or any portion of the submission, the Director will provide Respondent a
written notice of the deficiencies and a reasonable period of time to correct them. Respondent



will correct all deficiencies within the time specified by the Director and resubmit it for approval.
If the Director does not act on a submission or any document or plan submitted under this
paragraph within 60 days of submission, it will be deemed to be approved unless the Director
provides written notice during the 60-day period which includes an estimated date of completion
of its review.
IV. Dispute Resolution:
20. The Director and Respondent will informally attempt to resolve any disputes
arising under this Agreement, including but not limited to any decision of the Director under the
terms of Sections II (Corrective Measures) and III (Review and Approval Process) . If
Respondent and the Director are unable to informally resolve the dispute within 15 calendar days
after Respondent invokes the dispute resolution provision in writing, to the Director, Respondent
may submit a written request for a determination resolving the dispute from the Associate
Administrator for Pipeline Safety. Such request must be made in writing and provided to the
Director, counsel for the Southwest Region, and to the Associate Administrator, no later than 10
calendar days from the 15-day deadline for informal resolution referenced in this paragraph.
Along with its request, Respondent must provide the Associate Administrator with all
information Respondent believes is relevant to the dispute. If the request is submitted as
provided herein, the Associate Administrator will issue a final determination in writing.
Decisions of the Associate Administrator under this paragraph will constitute final agency
action. The existence of a dispute and PHMSA’s consideration of matters placed in dispute will
not excuse, toll, or suspend any term or timeframe for completion of any work to be performed
under this Agreement during the pendency of the dispute resolution process except as agreed by
the Director or Associate Administrator in writing.
V. Enforcement:
21. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties
under 49 U.S.C. § 60122, of up to $266,015 per violation for each day the violation continues and
referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that
Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil
penalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All work plans and
associated schedules set forth or referenced in Section II are automatically incorporated into this
Agreement and are enforceable in the same manner.
VI. Effective Date:
22. The term “Effective Date,” as used herein, is the date on which the Consent Order
is issued by the Associate Administrator incorporating the terms of this Agreement. Respondent
shall be furnished with a copy of the Consent Order within two (2) business days of the Effective
Date.
VII. Recordkeeping and Information Disclosure:



23. Unless otherwise required in this Agreement, Respondent agrees to maintain
records demonstrating compliance with all requirements of this Agreement for a period of at
least five (5) years following completion of all work to be performed, unless a longer period of
time is required pursuant to 49 CFR Parts 190-199. For any reports, plans, or other deliverables
required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim
of business confidentiality or other protections applicable to the release of information by
PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to
this Agreement in accordance with 49 CFR Part 7. Respondent must mark the claim of
confidentiality in writing on each page, and include a statement specifying the grounds for each
claim of confidentially. PHMSA determines release of any information submitted pursuant to
this Agreement in accordance with 49 CFR Part 7, the Freedom of Information Act, 5 U.S.C. §
552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.
VIII. Modification:
24. The terms of this Agreement may be modified by mutual agreement of the Parties.
Such modifications must be in writing and signed by both parties.
IX. Termination:
25. This Agreement will remain in effect until the Corrective Measures in Section II
are satisfied, as determined by the Director. The Agreement shall not terminate until the
Director confirms, in writing, that the Agreement is terminated in accordance with this
paragraph. Respondent may request written confirmation from PHMSA when this Consent
Agreement is terminated, and the Director will provide such confirmation. Nothing in this
Agreement prevents Respondent from completing any of the obligations earlier than the
deadlines provided for in this Agreement.
X. Ratification:
26. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Agreement and to execute and legally bind such party
to this document.
27. The Parties hereby agree to all conditions and terms of this Agreement.
[Signature Lines on Following Page]



For Plains All American Pipeline, L.P.:
___________________________________
Pat Hodgins, Vice President, Health, Safety and Environmental
________________________
Date
For PHMSA:
________________________________________
Director, Southwest Region, Office of Pipeline Safety
________________________
Date

42024029NOPSO_Closure Letter_01222026_(24-302881)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
VIA ELECTRONIC MAIL TO: ceo@Plains.com
12300 W. Dakota Ave., Suite 340
Lakewood, CO 80228
January 22, 2026
Mr. Willie Chiang
Chief Executive Officer
Plains All American Pipeline, L.P.
333 Clay St. Suite 1600
Houston, TX 77002
CPF 4-2024-029-NOPSO
Closure Letter
Dear Mr. Chang:
On July 8, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Plains All American Pipeline, L.P., a Consent Agreement and Order in the above-referenced
case. This Order included a requirement to take corrective actions on your pipeline. Based on
our review of the documentation you provided, it has been determined that you have complied
with the terms of this 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,
For Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 M. Mulligan (#24-302881)

42024029NOPSO_Notice of Proposed Safety Order_05172024_(24-302881)_text.pdf

VIA ELECTRONIC MAIL TO: hpefanis@paalp.com
May 17, 2024
Harry Pefanis
President
Plains All American Pipeline, LP
333 Clay Street, Suite 1900
Houston, Texas 77002
CPF 4-2024-029-NOPSO
Dear Mr. Pefanis:
Enclosed is a Notice of Proposed Safety Order (Notice) issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-
referenced case. The Notice proposes that Plains Pipeline, LP1 (Plains), take certain measures to
ensure facility safety with respect to the Plains Basin System Cotton Draw Pipeline that includes
over 800 miles of crude oil pipeline originating in Jal, New Mexico, and terminating in Cushing,
Oklahoma. Your options for responding are set forth in the Notice. Service of this Notice by
electronic mail is deemed effective upon the date of transmission, or as otherwise provided under
49 C.F.R. § 190.5.
We look forward to a successful resolution to ensure the safety and integrity of the Cotton Draw
Pipeline system. Please direct any questions on this matter to me at (713) 773-7215.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Notice of Proposed Safety Order
cc: Alan K. Mayberry, Associate Administrator for Pipeline Safety, OPS, PHMSA
Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS, PHMSA
1 Plains Pipeline, LP, is a subsidiary of Plains All American Pipeline, LP.



Dustin Hubbard, Director, Western Region, OPS, PHMSA
Patrick Hodgins, Vice President, Health, Safety, and Environment, NA, Plains Pipeline
L.P., pdhodgins@paalp.com
Ngiabi Gicuhi, Director, Environmental & Regulatory Compliance, Plains Pipeline L.P.,
ngicuhi@paalp.com
Kevin Cunningham, HSE Regulatory Compliance Programs, Plains Pipeline L.P.,
khcunningham@paalp.com



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
SOUTHWEST REGION
HOUSTON, TX 77074
____________________________________
)
In the Matter of )
)
Plains Pipeline, LP ) CPF No. 4-2024-029-NOPSO
a subsidiary of Plains All American )
Pipeline, LP, )
)
Respondent. )
____________________________________)
NOTICE OF PROPOSED SAFETY ORDER
Background and Purpose
This Notice of Proposed Safety Order (NOPSO or Notice) is being issued by the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the
authority of 49 U.S.C. § 60117. Pursuant to § 60117, PHMSA performed inspections of the work
required by the Compliance Order in CPF No. 4-2019-5004 on the Cotton Draw Pipeline, operated
by Plains Pipeline, LP (Plains). The Final Order in CPF No. 4-2019-5004 determined that Plains
had failed to properly qualify the welding procedure used to construct the pipeline. The Final
Order included a Compliance Order that required, among other actions, ten girth welds be cut out
and destructively tested to determine whether they possessed the required strength and mechanical
properties consistent with the design of the pipeline. The Compliance Order also required the
pipeline be properly repaired according to the requirements of 49 C.F.R. Part 195 and Plains’
operating and maintenance procedures. Below is a timeline of relevant events:
• On June 7, 2016, Plains began operating the Cotton Draw Pipeline.
• From August 7 through 11, 2017, representatives of PHMSA conducted an on-site pipeline
safety inspection of the facilities and records of Plains in Midland, Texas.
• On January 31, 2019, PHMSA issued a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (NOPV), associated with the 2017 PHMSA
inspection (CPF No. 4-2019-5004). Item 1 of the NOPV alleged that Plains violated 49
C.F.R. § 195.214(a) by failing to perform welding in accordance with welding procedures
qualified under section 5, section 12, or Appendix A or B of API Std 1104. Item 2 of the
NOPV alleged that Plains violated 49 C.F.R. § 195.222(a) by failing to use qualified



welders during welding activities. The NOPV included a Proposed Compliance Order for
Item 1 and a Proposed Civil Penalty of $75,600 for Item 2.2
• On October 6, 2020, the Associate Administrator for Pipeline Safety issued the Final Order,
which found that Plains failed to construct the Cotton Draw Pipeline in accordance with 49
C.F.R. § 195.214(a) by using an unqualified welding procedure (Item 1). The Final Order
also found that Plains failed to ensure that production welds made on the Cotton Draw
Pipeline were made by welders who were not properly qualified in accordance with 49
C.F.R. § 195.222(a) (Item 2). The Final Order included the Compliance Order and assessed
a $75,600 civil penalty.
• The Final Order included a Compliance Order that required Plains to replicate the welding
used to construct the Cotton Draw Pipeline in the laboratory and destructively test the
welds according to API Std 1104 requirements to determine if the welds had the required
strength and mechanical properties for the application. The Final Order provided Plains
the opportunity to demonstrate that the welds have the required strength and mechanical
properties for the application without having to perform cutouts of production welds. The
Compliance Order stated that if any of the welding procedure tests could not be
destructively qualified in a laboratory setting per API Std 1104 Plains must then perform
destructive testing on 10 girth welds on the Cotton Draw Pipeline at locations where
external forces may occur (e.g. slopes, road crossings) to show that the welds have the
required strength and mechanical properties for the application.
• On November 17, 2020, Plains submitted the proposed weld procedure qualification plan
and paid the civil penalty of $75,600.
• On February 19, 2021, PHMSA sent a letter to Plains that identified additional
requirements, clarifications, and information needed for the weld procedure qualification
plan.
• On April 15, 2021, Plains submitted a revised weld procedure qualification plan.
• From July 12 through 23, 2021, Plains prepared weld procedure qualification test sample
rings that were the same standard and had the same characteristics as the pipe used to
construct the Cotton Draw Pipeline. Plains stated that it completed qualification of three
welders designated to weld the test samples, then completed welding the three test samples,
and transferred the three test samples to the laboratory for weld procedure qualification.
• From August 2 through 4, 2021, the three test samples were tested in a laboratory at Team
Industrial Services, Inc. in Pasadena, Texas. One PHMSA inspector witnessed the testing.
• On August 11, 2021, Plains provided the API 1104 Weld Procedure Qualification Test
Report, in addition to other information requested by PHMSA while observing the testing.
2 The NOPV included four total items, but Items 3 and 4 are unrelated to the integrity risks identified in this
NOPSO.



• On October 6, 2021, in summarizing the above events (July through August 2021), Plains
requested closure of the Compliance Order.
• On March 24, 2022, PHMSA issued a letter to Plains stating that the Compliance Order
was not completed because Plains was unable to complete welds in the laboratory using
the same written procedure in use at the time of construction, leaving the adequacy of the
actual construction welds uncertain. PHMSA noted that during the July 2021 welding
qualification, welders were unable complete the weld using the travel speed specified in
the procedure used to construct the pipeline (CS-G4265M211). PHMSA clarified that the
Compliance Order required destructive testing on 10 girth welds on the Cotton Draw
Pipeline at locations where external forces may occur (e.g., slopes, road crossings) to show
that the welds have the required strength and mechanical properties for the application if
any of the welding procedure tests cannot be destructively qualified in a laboratory setting
per API Std 1104.
• On May 18, 2022, Plains submitted its girth weld cutout and test plan.
• On August 2, 2022, PHMSA requested additional requirements and clarifications to the
proposed girth weld cutout and test plan.
• On August 15, 2022, Plains submitted a revised girth weld cutout and test plan. On the
same day, PHMSA indicated it was satisfied with the revised plan.
• On February 2, 2023, Plains submitted its dig plan.
• From March 13, 2023, through April 21, 2023, Plains performed cutouts and repairs of the
Cotton Draw Pipeline. During this time, PHMSA was unable to conclude that the
requirements of the Compliance Order had been met and identified significant safety
concerns regarding Plains’ welding practices and procedures.
• On April 7, 2023, PHMSA issued a letter to Plains clarifying the remaining requirements
in the Compliance Order after PHMSA inspectors observed activities the week of March
13.
• On May 22, 2023, Plains requested that CPF 4-2019-5004 be closed. For the reasons
described below, the case remains open.
In March and April of 2023, PHMSA conducted multiple inspections of Plains’ corrective actions
taken pursuant to the Compliance Order issued in CPF No. 4-2019-5004, including the cutout of
test welds, pipe repairs, and reviewing welding procedures and welder qualifications. As a result
of numerous safety concerns identified during those inspections, existing integrity concerns related
to the issues identified in CPF No. 4-2019-5004, and PHMSA’s preliminary investigation, it
appears that conditions exist on the Cotton Draw Pipeline that pose a pipeline integrity risk to
public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(m), PHMSA issues
this Notice of Proposed Safety Order, notifying you of the preliminary findings of the



investigation, and proposing that you take measures to ensure that the public, property, and the
environment are protected from the potential risks.
Preliminary Findings
The preliminary findings of PHMSA’s ongoing investigation are as follows:
• Cotton Draw Pipeline is a segment of the Plains Basin System. The Cotton Draw segment
includes twelve (12) miles of 12-inch API SL X-52 Grade pipe originating at an existing
field gathering lease in Eddy County, New Mexico, traversing through Lea County, New
Mexico, and terminating at Plains, Cotton Draw Injection Station in Loving County, Texas.
The Cotton Draw Pipeline expansion was constructed in 2016 and includes a 40,000-barrel
breakout tank located at Cotton Draw Station near El Mar, Texas.
• From March 13, 2023, through April 21, 2023, Plains employed a contractor, Dean
Services, to perform cutouts and repairs of the Cotton Draw Pipeline. Inspections of this
work identified additional issues including: (1) failure to follow the qualified welding
procedures according to the requirements of 49 C.F.R. § 195.214; (2) failure to follow
operating and maintenance repair procedures required by 49 C.F.R. §195.402; (3) failure
to properly identify covered tasks and perform the work using personnel qualified under
49 C.F.R. Part 195, Subpart G; (4) failure to inspect the internal surface of the pipeline for
corrosion as required by 49 C.F.R. § 195.579(c); and (5) failure to properly complete
destructive testing of the welds as required by the Compliance Order and 49 C.F.R. §
195.214.
• (1) - The Compliance Order in CPF No. 4-2019-5004 required Plains to cut out and
destructively test production welds on the Cotton Draw Pipeline. It also required that
repairs to the pipeline resulting from the cutouts be completed according to Part 195 and
Plains’ operating and maintenance procedures. During PHMSA’s inspection on March 13,
2023, a review of the welding inspectors daily log discovered that welders making repairs
to the Cotton Draw Pipeline welded outside of the parameters specified on the welding
procedure (CS-G60M224 - Rev. 6) after cutting out the pipe spools containing the girth
welds to be tested. The welders were outside the specified range for amperage and voltage
for all passes on the tie-in segment at dig site #4. Additionally, the welding inspector failed
to document the travel speed to confirm that the welders were following the welding
procedure as required by 49 C.F.R. § 195.214. Therefore, it could not be determined if
Plains followed the welding procedure (CS-G60M224 - Rev. 6) used to weld the
replacement pipe segments for repair of the Cotton Draw Pipeline. After PHMSA
identified this issue to Plains, the welds were cut out and re-welded. Given that this
welding was being performed pursuant to corrective actions related to a prior welding
violation, Plains’ failure to follow the qualified welding procedure indicates the continued
presence of significant issues with the welding performed by Plains.
• (2) - On April 11, 2023, at dig site #5, a PHMSA inspector observed that Plains welded an
assembly of fittings onto a pre-tested segment of pipeline that was used to repair the Cotton
Draw Pipeline after a girth weld cutout. The assembly consisted of a thread-o-let, a pipe



nipple, and threaded cap. While the segment of replacement pipe was pre-tested, 49 C.F.R.
§ 195.305(a) requires all pipe and attac
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