{"operation":"document","citation":"CPF 42024038NOA","title":"TRANSWESTERN PIPELINE COMPANY LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-08-19","effective_on":null,"summary":"CLOSED notice of amendment citing 192.615(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024038noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024038noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42024038noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42024038NOA","body":"Notice of Amendment involving TRANSWESTERN PIPELINE COMPANY LLC. PHMSA's enforcement data identifies the cited regulation as 192.615(a). The case was opened on 2024-08-19 and is reported as closed as of 2024-10-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42024038NOA_Closure Letter_10222024_(23-267490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Closure%20Letter_10222024_(23-267490).pdf\n\n42024038NOA_Closure Letter_10222024_(23-267490)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Closure%20Letter_10222024_(23-267490)_text.pdf\n\n42024038NOA_Notice of Amendment_08192024_(23-267490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Notice%20of%20Amendment_08192024_(23-267490).pdf\n\n42024038NOA_Notice of Amendment_08192024_(23-267490)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Notice%20of%20Amendment_08192024_(23-267490)_text.pdf\n\n42024038NOA_Notice of Amendment_08192024_(23-267490)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nAugust 19, 2024\nThomas Long\nChief Executive Officer\nEnergy Transfer, LP\nTranswestern Pipeline Company, LLC\n8111 Westchester Drive\nDallas, Texas 75225\nCPF 4-2024-038-NOA\nDear Mr. Long:\nFrom April 11 through September 29, 2023, of the onsite inspection, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Transwestern Pipeline\nCompany, LLC’s (Transwestern) procedures for Operations and Maintenance in Arizona,\nColorado, New Mexico, and Texas.1\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nTranswestern’s plans or procedures. The items inspected and the inadequacies are described\nbelow:\n1. § 192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the\nhazard resulting from a gas pipeline emergency. At a minimum, the\nprocedures must provide for the following:\n(1) . . . .\n(12) Each operator must develop written rupture identification\nprocedures to evaluate and identify whether a notification of potential\nrupture, as defined in § 192.3, is an actual rupture event or a non-rupture\nevent. These procedures must, at a minimum, specify the sources of\n1 Transwestern is a subsidiary of Energy Transfer, LP.\n\n\n\ninformation, operational factors, and other criteria that operator\npersonnel use to evaluate a notification of potential rupture and identify\nan actual rupture. For operators installing valves in accordance with §\n192.179(e), § 192.179(f), or that are subject to the requirements in §\n192.634, those procedures must provide for rupture identification as soon\nas practicable.\nTranswestern’s written procedures to minimize the hazard resulting from a gas pipeline emergency\nwere inadequate to evaluate and identify whether a notification of potential rupture, as defined in\n§ 192.3, is an actual rupture event or non-rupture event in accordance with § 192.615(a)(12).\nSpecifically, Transwestern’s Standard Operating Procedure (SOP), Rupture Mitigation Valves,\nM.07 (Rev. July 11, 2023) failed to specify sources of information, operational factors, and other\ncriteria that operator personnel use to evaluate a notification of potential rupture and identify an\nactual rupture.\nTherefore, Transwestern must revise its procedure to require specifying sources of information,\noperational factors, and other criteria that operator personnel use to evaluate a notification of\npotential rupture and identify an actual rupture in accordance with § 192.615(a)(12).\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.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Transwestern Pipeline Company, LLC, maintain documentation\n\n\n\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director,\nSouthwest Region, Office of Pipeline Safety, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 4-2024-038-NOA\nand, for each document you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP,\ngreg.mcilwain@energytransfer.com\nEric Amundsen, Senior Vice President, Operations, Energy Transfer LP,\nEric.Amundsen@energytransfer.com\nTodd Stamm, Senior Vice President, Operations, Energy Transfer LP,\ntodd.stamm@energytransfer.com\nJennifer Street, Senior Vice President, Operations Services, Energy Transfer LP,\njennifer.street@energytransfer.com\nKeegan Pieper, Assistant General Counsel, Energy Transfer LP,\nkeegan.pieper@energytransfer.com\nMatthew Stork, Vice President, Technical Services, Energy Transfer LP,\nmatthew.stork@energytransfer.com\nTodd Nardozzi, Director – DOT Compliance, Energy Transfer LP,\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director – DOT Compliance, Energy Transfer LP,\nsusie.sjulin@energytransfer.com\n\n42024038NOA_Closure Letter_10222024_(23-267490)_text.pdf\n\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nOctober 22, 2024\nThomas Long\nChief Executive Officer\nEnergy Transfer, LP\nTranswestern Pipeline Company, LLC\n8111 Westchester\nDallas, Texas 75225\nRE: CPF 4-2024-038-NOA\nDear Mr. Long:\nFrom April 11 through September 29, 2023, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to chapter\n601 of 49 United States Code (U.S.C.), conducted an on-site pipeline safety inspection of\nTranswestern Pipeline Company, LLC’s (Transwestern) procedures for Operations and\nMaintenance in Arizona, Colorado, New Mexico, and Texas. As a result of the inspection,\nTranswestern was issued a Notice of Amendment (Notice) on August 19, 2024, requiring\namendment to its written emergency plans.\nTranswestern submitted its amended procedure on September 11, 2024. My staff has reviewed\nthe amended procedure, and it appears that the inadequacy outlined in the Notice has 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,\nBryan Lethcoe\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP,\ngreg.mcilwain@energytransfer.com\nEric Amundsen, Senior Vice President, Operations, Energy Transfer LP,\n\n\n\neric.Amundsen@energytransfer.com\nTodd Stamm, Senior Vice President, Operations, Energy Transfer LP,\ntodd.stamm@energytransfer.com\nJennifer Street, Senior Vice President, Operations Services, Energy Transfer LP,\njennifer.street@energytransfer.com\nKeegan Pieper, Assistant General Counsel, Energy Transfer LP,\nkeegan.pieper@energytransfer.com\nMatthew Stork, Vice President, Technical Services, Energy Transfer LP,\nmatthew.stork@energytransfer.com\nTodd Nardozzi, Director – DOT Compliance, Energy Transfer LP,\ntodd.nardozzi@energytransfer.com\nSusie Sjulin, Director – DOT Compliance, Energy Transfer LP,\nsusie.sjulin@energytransfer.com","truncated":false,"body_characters":9253}