# ANADARKO E & P COMPANY LP — Warning Letter

- **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:** Not available
- **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).
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- **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.

Official case documents:

520095005W_warning letter_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095005W/520095005W_warning%20letter_02192009.pdf

520095005W_warning letter_02192009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095005W/520095005W_warning%20letter_02192009_text.pdf

520095005W_warning letter_02192009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 19, 2009
Mr. Dan Rea
Sr. Vice President of Midstream
Anadarko Petroleum Corporation
1201 Lake Robbins Drive
Woodlands, TX 77380
CPF 5-2009-5005W
Dear Mr. Rea:
On September 24, 2008, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an
inspection of the Anadarko Petroleum Corporation’s (APC) Integrity Management Program
(IMP) in Green River, Wyoming.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §195.452 Pipeline integrity management in high consequence areas.
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:



(2) A baseline assessment plan meeting the requirements of paragraph (c) of this
section;
(c) What must be in the baseline assessment plan? (1) An operator must include
each of the following elements in its written baseline assessment plan:
(i) The methods selected to assess the integrity of the line pipe. An operator must
assess the integrity of the line pipe by any of the following methods. The methods
an operator selects to assess low frequency electric resistance welded pipe or lap
welded pipe susceptible to longitudinal seam failure must be capable of assessing
seam integrity and of detecting corrosion and deformation anomalies.
(A) Internal inspection tool or tools capable of detecting corrosion and
deformation anomalies including dents, gouges and grooves;
(B) Pressure test conducted in accordance with subpart E of this part;
(C) External corrosion direct assessment in accordance with §195.588; or
(D) Other technology that the operator demonstrates can provide an equivalent
understanding of the condition of the line pipe. An operator choosing this option
must notify the Office of Pipeline Safety (OPS) 90 days before conducting the
assessment, by sending a notice to the address or facsimile number specified in
paragraph (m) of this section.;
(ii) A schedule for completing the integrity assessment;
(iii) An explanation of the assessment methods selected and evaluation of risk
factors considered in establishing the assessment schedule.
(2) An operator must document, prior to implementing any changes to the plan,
any modification to the plan, and reasons for the modification.
The operator’s Baseline Assessment Plan is inadequate with respect to the Crude Oil
Pipeline system is not designed to accommodate in-line inspection (ILI) tool. The
hydrotest method was selected to assess the integrity of the line pipe. However, an
adequate technical justification was not provided during the audit to indicate that pre-
1970 LFERW or lap-welded pipe is not susceptible to the seam integrity issues.
2. §195.452 Pipeline integrity management in high consequence areas.
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:
(3) An analysis that integrates all available information about the integrity of the
entire pipeline and the consequences of a failure (see paragraph (g) of this
section);
(g) What is an information analysis? In periodically evaluating the integrity of
each pipeline segment (paragraph (j) of this section), an operator must analyze all
available information about the integrity of the entire pipeline and the
consequences of a failure. This information includes:
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(1) Information critical to determining the potential for, and preventing, damage
due to excavation, including current and planned damage prevention activities,
and development or planned development along the pipeline segment;
(2) Data gathered through the integrity assessment required under this section;
(3) Data gathered in conjunction with other inspections, tests, surveillance and
patrols required by this Part, including, corrosion control monitoring and
cathodic protection surveys; and
(4) Information about how a failure would affect the high consequence area, such
as location of the water intake.
The risk results need to be applied in a more comprehensive manner to ensure the risk
reduction efforts are prioritized on the overall highest risk areas, i.e. general or default
values were inappropriately used where the data have not been collected. In addition,
there is no documentation to indicate that their subject matter expert evaluated and
integrated various risk factors to characterize the risk of their crude oil pipeline.
3. §195.452 Pipeline integrity management in high consequence areas.
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:
(6) Identification of preventive and mitigative measures to protect the high
consequence area (see paragraph (i) of this section);
(i) What preventive and mitigative measures must an operator take to protect the
high consequence area?
(1) General requirements. An operator must take measures to prevent and
mitigate the consequences of a pipeline failure that could affect a high
consequence area. These measures include conducting a risk analysis of the
pipeline segment to identify additional actions to enhance public safety or
environmental protection. Such actions may include, but are not limited to,
implementing damage prevention best practices, better monitoring of cathodic
protection where corrosion is a concern, establishing shorter inspection intervals,
installing EFRDs on the pipeline segment, modifying the systems that monitor
pressure and detect leaks, providing additional training to personnel on response
procedures, conducting drills with local emergency responders and adopting
other management controls.
(2) Risk analysis criteria. In identifying the need for additional preventive and
mitigative measures, an operator must evaluate the likelihood of a pipeline release
occurring and how a release could affect the high consequence area. This
determination must consider all relevant risk factors, including, but not limited
to:
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(i) Terrain surrounding the pipeline segment, including drainage systems such as
small streams and other smaller waterways that could act as a conduit to the high
consequence area;
(ii) Elevation profile;
(iii) Characteristics of the product transported;
(iv) Amount of product that could be released;
(v) Possibility of a spillage in a farm field following the drain tile into a waterway;
(vi) Ditches along side a roadway the pipeline crosses;
(vii) Physical support of the pipeline segment such as by a cable suspension
bridge;
(viii) Exposure of the pipeline to operating pressure exceeding established
maximum operating pressure.
3. A. There is no documentation to indicate that the timely evaluation of preventive and
mitigative measures (P&MM) was adequately performed. In addition, the Anadarko
did not adequately document additional candidates for P&MM.
3. B. There is no documentation to indicate that all the required risk factors were
adequately considered in the P&MM evaluation process.
3. C. There is no documentation to indicate that their EFRD and leak detection were
evaluated.
4. §195.452 Pipeline integrity management in high consequence areas.
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:
(5) A continual process of assessment and evaluation to maintain a pipeline's
integrity (see paragraph (j) of this section);
(j) What is a continual process of evaluation and assessment to maintain a
pipeline's integrity?
(1) General. After completing the baseline integrity assessment, an operator must
continue to assess the line pipe at specified intervals and periodically evaluate the
integrity of each pipeline segment that could affect a high consequence area.
(2) Evaluation. An operator must conduct a periodic evaluation as frequently as
needed to assure pipeline integrity. An operator must base the frequency of
evaluation on risk factors specific to its pipeline, including the factors specified in
paragraph (e) of this section. The evaluation must consider the results of the
baseline and periodic integrity assessments, information analysis (paragraph (g)
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of this section), and decisions about remediation, and preventive and mitigative
actions (paragraphs (h) and (i) of this section).
(3) Assessment intervals. An operator must establish five-year intervals, not to
exceed 68 months, for continually assessing the line pipe's integrity. An operator
must base the assessment intervals on the risk the line pipe poses to the high
consequence area to determine the priority for assessing the pipeline segments. An
operator must establish the assessment intervals based on the factors specified in
paragraph (e) of this section, the analysis of the results from the last integrity
assessment, and the information analysis required by paragraph (g) of this
section.
4. A. Anadarko must ensure that a continual evaluation of their pipeline integrity is
being pursued. This means that all information (for instance the coating condition)
regarding a pipeline’s integrity is being continually evaluated to determine impacts on
reassessment schedules, assessment methods, and other aspects of Anadarko’s Integrity
Management Program.
4. B. Anadarko did not follow their reassessment interval procedures. Anadarko did
not complete their reassessment within the five (5) year intervals. In addition, the
Anadarko procedures did specify that it will reassess their pipeline every five (5) years;
however, the Anadarko did not consider all the relevant information, e.g. paraffin,
coating conditions, and etc…to establish the reassessment interval.
4. C. There is no documentation to indicate that the periodic evaluations were
adequately followed and/or the results were adequately documented to assure the
condition of their pipeline is not changed, e.g. the internal corrosion control program.
5. §195.452 Pipeline integrity management in high consequence areas.
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:
(4) Criteria for remedial actions to address integrity issues raised by the
assessment methods and information analysis (see paragraph (h) of this section);
(h) What actions must an operator take to address integrity issues?
(1) General requirements. An operator must take prompt action to address all
anomalous conditions the operator discovers through the integrity assessment or
information analysis. In addressing all conditions, an operator must evaluate all
anomalous conditions and remediate those that could reduce a pipeline's integrity.
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An operator must be able to demonstrate that the remediation of the condition
will ensure the condition is unlikely to pose a threat to the long-term integrity of
the pipeline. An operator must comply with § 195.422 when making a repair.
(i) Temporary pressure reduction. An operator must notify PHMSA, in
accordance with paragraph (m) of this section, if the operator cannot meet the
schedule for evaluation and remediation required under paragraph (h)(3) of this
section and cannot provide safety through a temporary reduction in operating
pressure.
(ii) Long-term pressure reduction. When a pressure reduction exceeds 365 days,
the operator must notify PHMSA in accordance with paragraph (m) of this
section and explain the reasons for the delay. An operator must also take further
remedial action to ensure the safety of the pipeline.
Anadarko did not notify the PHMSA that it cannot meet the reassessment schedule and
it cannot provide safety through a temporary reduction in operating pressure.
6. §195.452 Pipeline integrity management in high consequence areas.
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions
drawn from results of the integrity assessments, and other maintenance and
surveillance data, and evaluation of consequences of a failure on the high
consequence area. An operator must include, at minimum, each of the following
elements in its written integrity management program:
(7) Methods to measure the program's effectiveness (see paragraph (k) of this
section);
(k) What methods to measure program effectiveness must be used? An operator's
program must include methods to measure whether the program is effective in
assessing and evaluating the integrity of each pipeline segment and in protecting
the high consequence areas. See Appendix C of this part for guidance on methods
that can be used to evaluate a program's effectiveness.
6. A. The results of their IM program evaluation were not adequately communicated in
the timely manner to the company personnel who need to make use of that information,
for example: the July 15, 2008 Wamsutter Pipeline Mechanical Integrity Program
Review and Assessment
6. B. Anadarko’s root cause analysis was not adequately integrated into their IM
program. The analysis currently used by the Anadarko is not referenced in its IMP to
ensure a process for an effective root cause analysis and lessons learned.
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Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any related series of violations. 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. We advise you to correct the items
identified in this letter. Failure to do so will result in Anadarko Petroleum Corporation being
subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2009-5005W. 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,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 H. Nguyen (#122216)
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