{"operation":"document","citation":"CPF 520095006M","title":"ANADARKO E & P COMPANY LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-02-19","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(e)(1), 195.452(f)(5), 195.452(f)(6), 195.452(f)(7), 195.452(f)(8), 195.452(i)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095006M","body":"Notice of Amendment involving ANADARKO E & P COMPANY LP. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(f)(5),  195.452(f)(6),  195.452(f)(7),  195.452(f)(8),  195.452(i)(2). The case was opened on 2009-02-19 and is reported as closed as of 2009-04-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095006M_notice of amendment_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095006M/520095006M_notice%20of%20amendment_02192009.pdf\n\n520095006M_notice of amendment_02192009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095006M/520095006M_notice%20of%20amendment_02192009_text.pdf\n\n520095006M_operator response_03162009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095006M/520095006M_operator%20response_03162009.pdf\n\n520095006M_notice of amendment_02192009_text.pdf\n\nNOTICE OF AMENDMENT\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 5-2009-5006M\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, inspected the\nAnadarko Petroleum Corporation’s (APC) procedures for their Integrity Management Program\n(IMP) in Green River, Wyoming.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nAPC’s plans or procedures, as described below:\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\n\n\n\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(8) A process for review of integrity assessment results and information analysis\nby a person qualified to evaluate the results and information (see paragraph (h)\n(2) of this section).\nThe APC procedures are inadequate for ensuring the qualification of their integrity\nmanagement (IM) reviewer and/or evaluator. The procedures do not specify the level\nof qualifications the IM reviewer and/or evaluator must have to adequately review and\nanalyze the assessment results, e.g. in-house IM team and hydrotest engineer.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(e) What are the risk factors for establishing an assessment schedule (for both the\nbaseline and continual integrity assessments)?\n(1) An operator must establish an integrity assessment schedule that prioritizes\npipeline segments for assessment (see paragraphs (d) (1) and (j) (3) of this\nsection). An operator must base the assessment schedule on all risk factors that\nreflect the risk conditions on the pipeline segment. The factors an operator must\nconsider include, but are not limited to:\n(i) Results of the previous integrity assessment, defect type and size that the\nassessment method can detect, and defect growth rate;\n(ii) Pipe size, material, manufacturing information, coating type and condition,\nand seam type;\n(iii) Leak history, repair history and cathodic protection history;\n(iv) Product transported;\n(v) Operating stress level;\n(vi) Existing or projected activities in the area;\n(vii) Local environmental factors that could affect the pipeline (e.g., corrosivity of\nsoil, subsidence, climatic);\n(viii) geo-technical hazards; and\n(ix) Physical support of the segment such as by a cable suspension bridge.\n(2) Appendix C of this part provides further guidance on risk factors.\nThe APC has a risk based analysis process from an original framework of their IM\nprogram that was used in a Subject Matter Expert (SME) setting. The APC procedures\nare inadequate to ensure a more comprehensive and robust risk model that consider all\nrequired risk factors on their pipeline, e.g. data driven risk model.\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\n2\n\n\n\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) An operator must take prompt action to address all anomalous conditions the\noperator discovers through the integrity assessment or information analysis. In\naddressing all conditions, an operator must evaluate all anomalous conditions and\nremediate those that could reduce a pipeline's integrity. An operator must be able\nto demonstrate that the remediation of the condition will ensure the condition is\nunlikely to pose a threat to the long-term integrity of the pipeline. An operator\nmust 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.\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:\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.\n(3) Leak detection. An operator must have a means to detect leaks on its pipeline\nsystem. An operator must evaluate the capability of its leak detection means and\nmodify, as necessary, to protect the high consequence area. An operator's\nevaluation must, at least, consider, the following factors–length and size of the\npipeline, type of product carried, the pipeline's proximity to the high consequence\narea, the swiftness of leak detection, location of nearest response personnel, leak\nhistory, and risk assessment results.\n3\n\n\n\n(4) Emergency Flow Restricting Devices (EFRD). If an operator determines that\nan EFRD is needed on a pipeline segment to protect a high consequence area in\nthe event of a hazardous liquid pipeline release, an operator must install the\nEFRD. In making this determination, an operator must, at least, consider the\nfollowing factors–the swiftness of leak detection and pipeline shutdown\ncapabilities, the type of commodity carried, the rate of potential leakage, the\nvolume that can be released, topography or pipeline profile, the potential for\nignition, proximity to power sources, location of nearest response personnel,\nspecific terrain between the pipeline segment and the high consequence area, and\nbenefits expected by reducing the spill size.\n• Item 3: §195.452 (f)(6)\n• Item 3A: §195.452 (i)(2)\nThe process description to identify additional preventive and mitigative actions did not\nshow how the IM projects are integrated into the risk model process. The APC\nprocedures are inadequate to ensure a more comprehensive and robust process to\nidentify additional preventive and mitigative measures (P&MM).\n• Item 3B: §195.452 (i)(2)\nThe APC procedures are inadequate for defining and ranking P&MM for their pipeline\nin the IM program. This is important to ensure future preventive and mitigative\ndecisions are made in a consistent and risk-based manner.\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.\n(4) Variance from the 5-year intervals in limited situations-\n(i) Engineering basis. An operator may be able to justify an engineering basis for\na longer assessment interval on a segment of line pipe. The justification must be\nsupported by a reliable engineering evaluation combined with the use of other\ntechnology, such as external monitoring technology, that provides an\nunderstanding of the condition of the line pipe equivalent to that which can be\nobtained from the assessment methods allowed in paragraph (j)(5) of this section.\nAn operator must notify OPS 270 days before the end of the five-year (or less)\ninterval of the justification for a longer interval, and propose an alternative\ninterval. An operator must send the notice to the address specified in paragraph\n(m) of this section.\n(ii) Unavailable technology. An operator may require a longer assessment period\nfor a segment of line pipe (for example, because sophisticated internal inspection\ntechnology is not available). An operator must justify the reasons why it cannot\ncomply with the required assessment period and must also demonstrate the\nactions it is taking to evaluate the integrity of the pipeline segment in the interim.\nAn operator must notify OPS 180 days before the end of the five-year (or less)\ninterval that the operator may require a longer assessment interval, and provide\nan estimate of when the assessment can be completed. An operator must send a\nnotice to the address specified in paragraph (m) of this section.\n(5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n(i) Internal inspection tool or tools capable of detecting corrosion and\ndeformation anomalies including dents, gouges and grooves;\n(ii) Pressure test conducted in accordance with subpart E of this part;\n(iii) External corrosion direct assessment in accordance with § 195.588; or\n(iv) 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 OPS 90 days before conducting the assessment, by sending a notice to\nthe address or facsimile number specified in paragraph (m) of this section.\n5\n\n\n\nThe APC procedures are inadequate for addressing the pipe condition and location-\nspecific integrity threats. The procedures do not specify what additional safety\nmeasures and/or evaluation methods will be used to ensure the safety condition of their\npipeline.\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(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.\nThe APC procedures do not specify the IM program evaluations as required by Part\n195.452(f) (7) and the method to perform an effective evaluation of the IM program.\nIn addition, the procedures do not specify the collection of performance metric data at a\nfrequency that will provide timely evaluations of the IM program.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\n6\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 5-2009-5006M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen (#122216)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n7","truncated":false,"body_characters":17393}