{"operation":"document","citation":"CPF 520095005W","title":"ANADARKO E & P COMPANY LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-02-19","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(2), 195.452(f)(3), 195.452(f)(4), 195.452(f)(5), 195.452(f)(6), 195.452(f)(7).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095005W","body":"Warning Letter involving ANADARKO E & P COMPANY LP. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(2),  195.452(f)(3),  195.452(f)(4),  195.452(f)(5),  195.452(f)(6),  195.452(f)(7). The case was opened on 2009-02-19 and is reported as closed as of 2009-02-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095005W_warning letter_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095005W/520095005W_warning%20letter_02192009.pdf\n\n520095005W_warning letter_02192009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095005W/520095005W_warning%20letter_02192009_text.pdf\n\n520095005W_warning letter_02192009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 19, 2009\nMr. Dan Rea\nSr. Vice President of Midstream\nAnadarko Petroleum Corporation\n1201 Lake Robbins Drive\nWoodlands, TX 77380\nCPF 5-2009-5005W\nDear Mr. Rea:\nOn September 24, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an\ninspection of the Anadarko Petroleum Corporation’s (APC) Integrity Management Program\n(IMP) in Green River, Wyoming.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n\n\n\n(2) A baseline assessment plan meeting the requirements of paragraph (c) of this\nsection;\n(c) What must be in the baseline assessment plan? (1) An operator must include\neach of the following elements in its written baseline assessment plan:\n(i) The methods selected to assess the integrity of the line pipe. An operator must\nassess the integrity of the line pipe by any of the following methods. The methods\nan operator selects to assess low frequency electric resistance welded pipe or lap\nwelded pipe susceptible to longitudinal seam failure must be capable of assessing\nseam integrity and of detecting corrosion and deformation anomalies.\n(A) Internal inspection tool or tools capable of detecting corrosion and\ndeformation anomalies including dents, gouges and grooves;\n(B) Pressure test conducted in accordance with subpart E of this part;\n(C) External corrosion direct assessment in accordance with §195.588; or\n(D) Other technology that the operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option\nmust notify the Office of Pipeline Safety (OPS) 90 days before conducting the\nassessment, by sending a notice to the address or facsimile number specified in\nparagraph (m) of this section.;\n(ii) A schedule for completing the integrity assessment;\n(iii) An explanation of the assessment methods selected and evaluation of risk\nfactors considered in establishing the assessment schedule.\n(2) An operator must document, prior to implementing any changes to the plan,\nany modification to the plan, and reasons for the modification.\nThe operator’s Baseline Assessment Plan is inadequate with respect to the Crude Oil\nPipeline system is not designed to accommodate in-line inspection (ILI) tool. The\nhydrotest method was selected to assess the integrity of the line pipe. However, an\nadequate technical justification was not provided during the audit to indicate that pre-\n1970 LFERW or lap-welded pipe is not susceptible to the seam integrity issues.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this\nsection);\n(g) What is an information analysis? In periodically evaluating the integrity of\neach pipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the\nconsequences of a failure. This information includes:\n2\n\n\n\n(1) Information critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities,\nand development or planned development along the pipeline segment;\n(2) Data gathered through the integrity assessment required under this section;\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and\ncathodic protection surveys; and\n(4) Information about how a failure would affect the high consequence area, such\nas location of the water intake.\nThe risk results need to be applied in a more comprehensive manner to ensure the risk\nreduction efforts are prioritized on the overall highest risk areas, i.e. general or default\nvalues were inappropriately used where the data have not been collected. In addition,\nthere is no documentation to indicate that their subject matter expert evaluated and\nintegrated various risk factors to characterize the risk of their crude oil pipeline.\n3. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(6) Identification of preventive and mitigative measures to protect the high\nconsequence area (see paragraph (i) of this section);\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(1) General requirements. An operator must take measures to prevent and\nmitigate the consequences of a pipeline failure that could affect a high\nconsequence area. These measures include conducting a risk analysis of the\npipeline segment to identify additional actions to enhance public safety or\nenvironmental protection. Such actions may include, but are not limited to,\nimplementing damage prevention best practices, better monitoring of cathodic\nprotection where corrosion is a concern, establishing shorter inspection intervals,\ninstalling EFRDs on the pipeline segment, modifying the systems that monitor\npressure and detect leaks, providing additional training to personnel on response\nprocedures, conducting drills with local emergency responders and adopting\nother management controls.\n(2) Risk analysis criteria. In identifying the need for additional preventive and\nmitigative measures, an operator must evaluate the likelihood of a pipeline release\noccurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited\nto:\n3\n\n\n\n(i) Terrain surrounding the pipeline segment, including drainage systems such as\nsmall streams and other smaller waterways that could act as a conduit to the high\nconsequence area;\n(ii) Elevation profile;\n(iii) Characteristics of the product transported;\n(iv) Amount of product that could be released;\n(v) Possibility of a spillage in a farm field following the drain tile into a waterway;\n(vi) Ditches along side a roadway the pipeline crosses;\n(vii) Physical support of the pipeline segment such as by a cable suspension\nbridge;\n(viii) Exposure of the pipeline to operating pressure exceeding established\nmaximum operating pressure.\n3. A. There is no documentation to indicate that the timely evaluation of preventive and\nmitigative measures (P&MM) was adequately performed. In addition, the Anadarko\ndid not adequately document additional candidates for P&MM.\n3. B. There is no documentation to indicate that all the required risk factors were\nadequately considered in the P&MM evaluation process.\n3. C. There is no documentation to indicate that their EFRD and leak detection were\nevaluated.\n4. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(5) A continual process of assessment and evaluation to maintain a pipeline's\nintegrity (see paragraph (j) of this section);\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(1) General. After completing the baseline integrity assessment, an operator must\ncontinue to assess the line pipe at specified intervals and periodically evaluate the\nintegrity of each pipeline segment that could affect a high consequence area.\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified in\nparagraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments, information analysis (paragraph (g)\n4\n\n\n\nof this section), and decisions about remediation, and preventive and mitigative\nactions (paragraphs (h) and (i) of this section).\n(3) Assessment intervals. An operator must establish five-year intervals, not to\nexceed 68 months, for continually assessing the line pipe's integrity. An operator\nmust base the assessment intervals on the risk the line pipe poses to the high\nconsequence area to determine the priority for assessing the pipeline segments. An\noperator must establish the assessment intervals based on the factors specified in\nparagraph (e) of this section, the analysis of the results from the last integrity\nassessment, and the information analysis required by paragraph (g) of this\nsection.\n4. A. Anadarko must ensure that a continual evaluation of their pipeline integrity is\nbeing pursued. This means that all information (for instance the coating condition)\nregarding a pipeline’s integrity is being continually evaluated to determine impacts on\nreassessment schedules, assessment methods, and other aspects of Anadarko’s Integrity\nManagement Program.\n4. B. Anadarko did not follow their reassessment interval procedures. Anadarko did\nnot complete their reassessment within the five (5) year intervals. In addition, the\nAnadarko procedures did specify that it will reassess their pipeline every five (5) years;\nhowever, the Anadarko did not consider all the relevant information, e.g. paraffin,\ncoating conditions, and etc…to establish the reassessment interval.\n4. C. There is no documentation to indicate that the periodic evaluations were\nadequately followed and/or the results were adequately documented to assure the\ncondition of their pipeline is not changed, e.g. the internal corrosion control program.\n5. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(4) Criteria for remedial actions to address integrity issues raised by the\nassessment methods and information analysis (see paragraph (h) of this section);\n(h) What actions must an operator take to address integrity issues?\n(1) General requirements. An operator must take prompt action to address all\nanomalous conditions the operator discovers through the integrity assessment or\ninformation analysis. In addressing all conditions, an operator must evaluate all\nanomalous conditions and remediate those that could reduce a pipeline's integrity.\n5\n\n\n\nAn operator must be able to demonstrate that the remediation of the condition\nwill ensure the condition is unlikely to pose a threat to the long-term integrity of\nthe pipeline. An operator must comply with § 195.422 when making a repair.\n(i) Temporary pressure reduction. An operator must notify PHMSA, in\naccordance with paragraph (m) of this section, if the operator cannot meet the\nschedule for evaluation and remediation required under paragraph (h)(3) of this\nsection and cannot provide safety through a temporary reduction in operating\npressure.\n(ii) Long-term pressure reduction. When a pressure reduction exceeds 365 days,\nthe operator must notify PHMSA in accordance with paragraph (m) of this\nsection and explain the reasons for the delay. An operator must also take further\nremedial action to ensure the safety of the pipeline.\nAnadarko did not notify the PHMSA that it cannot meet the reassessment schedule and\nit cannot provide safety through a temporary reduction in operating pressure.\n6. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n(k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting\nthe high consequence areas. See Appendix C of this part for guidance on methods\nthat can be used to evaluate a program's effectiveness.\n6. A. The results of their IM program evaluation were not adequately communicated in\nthe timely manner to the company personnel who need to make use of that information,\nfor example: the July 15, 2008 Wamsutter Pipeline Mechanical Integrity Program\nReview and Assessment\n6. B. Anadarko’s root cause analysis was not adequately integrated into their IM\nprogram. The analysis currently used by the Anadarko is not referenced in its IMP to\nensure a process for an effective root cause analysis and lessons learned.\n6\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in Anadarko Petroleum Corporation being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2009-5005W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen (#122216)\n7","truncated":false,"body_characters":17441}