{"operation":"document","citation":"CPF 520126014W","title":"DEVON GAS SERVICES, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-04-19","effective_on":null,"summary":"CLOSED warning letter citing 195.452(e)(1), 195.452(i)(1), 195.452(i)(3), 195.452(i)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126014w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126014w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126014w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520126014W","body":"Warning Letter involving DEVON GAS SERVICES, LP. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(i)(1),  195.452(i)(3),  195.452(i)(4). The case was opened on 2012-04-19 and is reported as closed as of 2012-04-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520126014W_warning letter_04192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126014W/520126014W_warning%20letter_04192012.pdf\n\n520126014W_warning letter_04192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126014W/520126014W_warning%20letter_04192012_text.pdf\n\n520126014W_warning letter_04192012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 19, 2012\nMr. Tracy Carter\nVice President\nDevon Gas Services, L.P.\n100 N. Broadway\nOklahoma City, OK 73102\nCPF 5-2012-6014W\nDear Mr. Carter:\nOn September 26 through September 29, 2011, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected your implementing records for Devon Gas Services’ (Devon) Integrity Management\n(IM) Program related to your Beaver Creek CO2 pipeline near Riverton, 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 the\nprobable violations are:\n1. §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 section).\nAn operator must base the assessment schedule on all risk factors that reflect the\nrisk conditions on the pipeline segment. The factors an operator must consider\ninclude, but are not limited to:\n\n\n\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, and\nseam 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.\nDevon did not adequately consider all of the risk factors associated with their pipeline when\nestablishing an assessment schedule. Devon failed to use all of the available data to represent\ntheir pipeline characteristics in the risk analysis of pipeline segments. At the time of inspection,\nit appears that the general or default values were inappropriately used where pipe data had not\nbeen collected. An accurate and up-to-date risk analysis is the basis of having an effective\nintegrity management program and must use all of the risk factors available to the operator.\n2. §195.452 Pipeline integrity management in high consequence areas.\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 mitigate\nthe consequences of a pipeline failure that could affect a high consequence area.\nThese measures include conducting a risk analysis of the pipeline segment to\nidentify additional actions to enhance public safety or environmental protection.\nSuch actions may include, but are not limited to, implementing damage prevention\nbest practices, better monitoring of cathodic protection where corrosion is a\nconcern, establishing shorter inspection intervals, installing EFRDs on the pipeline\nsegment, modifying the systems that monitor pressure and detect leaks, providing\nadditional training to personnel on response procedures, conducting drills with local\nemergency responders and adopting other management controls.\nDevon did not take additional measures to prevent and mitigate the consequences of a pipeline\nfailure that could affect a high consequence area. At the time of inspection, it was noted that\nDevon’s Integrity Management program listed several potential candidates for preventive and\nmitigative measures to reduce the consequences of a pipeline failure in an HCA. However, none\nof the candidates had been selected to assist Devon in reducing the consequences of a pipeline\nfailure. Devon needs to use the results from their risk analysis to formulate a strategy of\nimplementing their preventive and mitigative measures program.\n3. §195.452 Pipeline integrity management in high consequence areas.\n\n\n\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\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 evaluation\nmust, at least, consider, the following factors–length and size of the pipeline, type of\nproduct carried, the pipeline's proximity to the high consequence area, the swiftness\nof leak detection, location of nearest response personnel, leak history, and risk\nassessment results.\nDevon did not perform an evaluation of its leak detection capability to protect the high\nconsequence area. At the time of inspection, Section 6 of Devon’s P&MM Evaluation Form 606\nstates, “Since the CO2 line only has one HCA and it directly impacts the HCA, there would be no\nreduction in impact to HCAs. Also, additional studies were not deemed necessary by the SMEs.”\nHowever, it appears that Form 606 did not indicate a formal evaluation of their leak detection\ncapability was completed in accordance with your own IM procedures. Devon must perform an\nevaluation of its leak detection capability to protect the high consequence area.\n4. §195.452 Pipeline integrity management in high consequence areas.\n(i) What preventive and mitigative measures must an operator take to protect the\nhigh consequence area?\n(4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an\nEFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following\nfactors–the swiftness of leak detection and pipeline shutdown capabilities, the type\nof commodity carried, the rate of potential leakage, the volume that can be released,\ntopography or pipeline profile, the potential for ignition, proximity to power\nsources, location of nearest response personnel, specific terrain between the pipeline\nsegment and the high consequence area, and benefits expected by reducing the spill\nsize.\nDevon failed to perform an evaluation of its Emergency Flow Restricting Devices (EFRD)\ncapability to protect the high consequence area. At the time of inspection, Section 6 of Devon’s\nP&MM Evaluation Form 606 states, “Since the CO2 line only has one HCA and it directly\nimpacts the HCA, there would be no reduction in impact to HCAs. Also, additional studies were\nnot deemed necessary by the SMEs.” However, it appears that Form 606 did not indicate an\nevaluation of their EFRD capability was completed in accordance with your own IM procedures.\nDevon must perform an evaluation of its EFRD capability to protect the high consequence area.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\n\n\n\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result in Devon Gas Services, L.P. being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2012-6014W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Davis (#134159)","truncated":false,"body_characters":9122}