# WESTERN MIDSTREAM PARTNERS, LP — Warning Letter

- **operation:** document
- **citation:** CPF 520095032W
- **title:** WESTERN MIDSTREAM PARTNERS, LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-08-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.402(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095032w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095032w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095032w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520095032W
**body:**

Warning Letter involving WESTERN MIDSTREAM PARTNERS, LP. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2009-08-21 and is reported as closed as of 2009-08-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095032W_warning letter_08212009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095032W/520095032W_warning%20letter_08212009.pdf

520095032W_warning letter_08212009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095032W/520095032W_warning%20letter_08212009_text.pdf

520095032W_warning letter_08212009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 21, 2009
Mr. Danny Rea
Vice President of Midstream
Anadarko Petroleum Corporation
1201 Lake Robbin Dr.
The Woodlands, TX 77380
CPF 5-2009-5032W
Dear Mr. Rea:
On June 29 – July 2, 2009, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Wamsutter Crude Oil Pipe Line near Wamsutter, Wyoming.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the
probable violation is:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline commence, and
appropriate parts shall be kept at locations where operations and maintenance
activities are conducted.



Per §195.402(a), the operator must conduct a review and update their Operations and Maintenance
(O&M) manual at least once each calendar year and at intervals not exceeding 15 months. During
the inspection, Anadarko Petroleum Corporation did not have records to indicate that their Operations
and Maintenance manual was reviewed during the 2008 calendar year.
2006 O&M
Manual
Review
195.402(a)
2007 O&M
Manual
Review
195.402(a)
2008 O&M
Manual
Review
Due Date
(15 months)
2009 O&M
Manual
Review
195.402(a)
3-13-2006 January, 2007
3-02-2008
But not
reviewed
5-1-2009
The exact day of the 2007 O&M review was not noted; therefore, the 15-month interval must
default to January 2, 2007 and the due date for the 2008 O&M review should have been
March 2, 2008.
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 item(s) 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 5-2009-5032W. 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 B. Brown (#123989)
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