# TRANSWESTERN PIPELINE COMPANY LLC — Notice of Amendment - **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:** Not available - **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. Official case documents: 42024038NOA_Closure Letter_10222024_(23-267490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Closure%20Letter_10222024_(23-267490).pdf 42024038NOA_Closure Letter_10222024_(23-267490)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Closure%20Letter_10222024_(23-267490)_text.pdf 42024038NOA_Notice of Amendment_08192024_(23-267490).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024038NOA/42024038NOA_Notice%20of%20Amendment_08192024_(23-267490).pdf 42024038NOA_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 42024038NOA_Notice of Amendment_08192024_(23-267490)_text.pdf NOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com August 19, 2024 Thomas Long Chief Executive Officer Energy Transfer, LP Transwestern Pipeline Company, LLC 8111 Westchester Drive Dallas, Texas 75225 CPF 4-2024-038-NOA Dear Mr. Long: From April 11 through September 29, 2023, of the onsite inspection, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Transwestern Pipeline Company, LLC’s (Transwestern) procedures for Operations and Maintenance in Arizona, Colorado, New Mexico, and Texas.1 As a result of the inspection, PHMSA has identified the apparent inadequacies found within Transwestern’s plans or procedures. The items inspected and the inadequacies are described below: 1. § 192.615 Emergency plans. (a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following: (1) . . . . (12) Each operator must develop written rupture identification procedures to evaluate and identify whether a notification of potential rupture, as defined in § 192.3, is an actual rupture event or a non-rupture event. These procedures must, at a minimum, specify the sources of 1 Transwestern is a subsidiary of Energy Transfer, LP. information, operational factors, and other criteria that operator personnel use to evaluate a notification of potential rupture and identify an actual rupture. For operators installing valves in accordance with § 192.179(e), § 192.179(f), or that are subject to the requirements in § 192.634, those procedures must provide for rupture identification as soon as practicable. Transwestern’s written procedures to minimize the hazard resulting from a gas pipeline emergency were inadequate to evaluate and identify whether a notification of potential rupture, as defined in § 192.3, is an actual rupture event or non-rupture event in accordance with § 192.615(a)(12). Specifically, Transwestern’s Standard Operating Procedure (SOP), Rupture Mitigation Valves, M.07 (Rev. July 11, 2023) failed to specify sources of information, operational factors, and other criteria that operator personnel use to evaluate a notification of potential rupture and identify an actual rupture. Therefore, Transwestern must revise its procedure to require specifying sources of information, operational factors, and other criteria that operator personnel use to evaluate a notification of potential rupture and identify an actual rupture in accordance with § 192.615(a)(12). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Transwestern Pipeline Company, LLC, maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2024-038-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP, greg.mcilwain@energytransfer.com Eric Amundsen, Senior Vice President, Operations, Energy Transfer LP, Eric.Amundsen@energytransfer.com Todd Stamm, Senior Vice President, Operations, Energy Transfer LP, todd.stamm@energytransfer.com Jennifer Street, Senior Vice President, Operations Services, Energy Transfer LP, jennifer.street@energytransfer.com Keegan Pieper, Assistant General Counsel, Energy Transfer LP, keegan.pieper@energytransfer.com Matthew Stork, Vice President, Technical Services, Energy Transfer LP, matthew.stork@energytransfer.com Todd Nardozzi, Director – DOT Compliance, Energy Transfer LP, todd.nardozzi@energytransfer.com Susie Sjulin, Director – DOT Compliance, Energy Transfer LP, susie.sjulin@energytransfer.com 42024038NOA_Closure Letter_10222024_(23-267490)_text.pdf VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com October 22, 2024 Thomas Long Chief Executive Officer Energy Transfer, LP Transwestern Pipeline Company, LLC 8111 Westchester Dallas, Texas 75225 RE: CPF 4-2024-038-NOA Dear Mr. Long: From April 11 through September 29, 2023, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to chapter 601 of 49 United States Code (U.S.C.), conducted an on-site pipeline safety inspection of Transwestern Pipeline Company, LLC’s (Transwestern) procedures for Operations and Maintenance in Arizona, Colorado, New Mexico, and Texas. As a result of the inspection, Transwestern was issued a Notice of Amendment (Notice) on August 19, 2024, requiring amendment to its written emergency plans. Transwestern submitted its amended procedure on September 11, 2024. My staff has reviewed the amended procedure, and it appears that the inadequacy outlined in the Notice has been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Bryan Lethcoe Director, Southwest Region Pipeline and Hazardous Materials Safety Administration cc: Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP, greg.mcilwain@energytransfer.com Eric Amundsen, Senior Vice President, Operations, Energy Transfer LP, eric.Amundsen@energytransfer.com Todd Stamm, Senior Vice President, Operations, Energy Transfer LP, todd.stamm@energytransfer.com Jennifer Street, Senior Vice President, Operations Services, Energy Transfer LP, jennifer.street@energytransfer.com Keegan Pieper, Assistant General Counsel, Energy Transfer LP, keegan.pieper@energytransfer.com Matthew Stork, Vice President, Technical Services, Energy Transfer LP, matthew.stork@energytransfer.com Todd Nardozzi, Director – DOT Compliance, Energy Transfer LP, todd.nardozzi@energytransfer.com Susie Sjulin, Director – DOT Compliance, Energy Transfer LP, susie.sjulin@energytransfer.com - **truncated:** false - **body characters:** 9253