{"operation":"document","citation":"CPF 520126015M","title":"DEVON GAS SERVICES, LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-04-19","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(e)(1), 195.452(f)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126015m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126015m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126015m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520126015M","body":"Notice of Amendment involving DEVON GAS SERVICES, LP. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(1),  195.452(f)(6). The case was opened on 2012-04-19 and is reported as closed as of 2012-07-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520126015M_closure letter_07092012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126015M/520126015M_closure%20letter_07092012.pdf\n\n520126015M_closure letter_07092012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126015M/520126015M_closure%20letter_07092012_text.pdf\n\n520126015M_notice of amendment_04192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126015M/520126015M_notice%20of%20amendment_04192012.pdf\n\n520126015M_notice of amendment_04192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126015M/520126015M_notice%20of%20amendment_04192012_text.pdf\n\n520126015M_operator response_05232012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126015M/520126015M_operator%20response_05232012.pdf\n\n520126015M_notice of amendment_04192012_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 19, 2012\nMr. Tracy Carter\nVice President\nDevon Gas Services, LP\n100 N. Broadway\nOklahoma City, OK 73102\nCPF 5-2012-6015M\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 Devon Gas Services’ (Devon) integrity management program (IMP) procedures for their\nBeaver Creek CO2 Pipeline. The IM program review was conducted at your field office near Riverton,\nWyoming.\nOn the basis of the inspection, PHMSA identified apparent inadequacies within Devon’s IMP\nprocedures, as described below:\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 baseline\nand continual integrity assessments)?\n(1) An operator must establish an integrity assessment schedule that prioritizes pipeline\nsegments for assessment (see paragraphs (d)(1) and (j)(3) of this section). An operator\nmust base the assessment schedule on all risk factors that reflect the risk conditions on the\npipeline segment. The factors an operator must consider include, but are not limited to:\n(i) Results of the previous integrity assessment, defect type and size that the assessment\nmethod can detect, and defect growth rate;\n(ii) Pipe size, material, manufacturing information, coating type and condition, and seam\ntype;\n(iii) Leak history, repair history and cathodic protection history;\n\n\n\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 soil,\nsubsidence, climatic);\n(viii) geo-technical hazards; and\n(ix) Physical support of the segment such as by a cable suspension bridge.\nDevon’s Integrity Management Program (IMP) is inadequate because the risk analysis program does\nnot properly address the nine (9) threat categories listed above. At the time of inspection, Devon’s risk\nanalysis had not assigned risk factors for the pipeline defects found in the past. Each defect must, at a\nminimum, be evaluated to see if they can be attributed to the listed threat categories. Devon is also\nrequired to see if there are other threat factors beyond the nine prescribed ones that may be unique to\nthe Beaver Creek pipeline. A defect associated with a specific threat factor may indicate a future\nsystemic risk that could occur on other parts of the pipeline unless that threat factor is mitigated.\nDevon must amend their IMP Manual to include all relevant important risk factors that might\nconstitute a threat to the Beaver Creek pipeline’s integrity as required by §195.452(e) so they can\ndevelop a proper pipeline assessment schedule.\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 continually\nchange the program to reflect operating experience, conclusions drawn from results of the\nintegrity assessments, and other maintenance and surveillance data, and evaluation of\nconsequences of a failure on the high consequence area. An operator must include, at\nminimum, each of the following elements in its written integrity management program:\n(6) Identification of preventive and mitigative measures to protect the high consequence\narea (see paragraph (i) of this section);\nDevon’s IMP does not have an adequate risk analysis process that properly addresses the potential risk\nto human health and the environment. §195.452(i)(2) Risk analysis criteria states, “In identifying the\nneed for additional preventive and mitigative measures, an operator must evaluate the likelihood of a\npipeline release occurring and how a release could affect the high consequence area. This\ndetermination must consider all relevant risk factors, including, but not limited to:\n(i) Terrain surrounding the pipeline segment, including drainage systems such as small streams\nand other smaller waterways that could act as a conduit to the high consequence 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 bridge;\n(viii) Exposure of the pipeline to operating pressure exceeding established maximum operating\npressure.”\n\n\n\nAt the time of inspection, Devon’s risk analysis did not include consequence risk factors for how a\npipeline release would affect human safety and protected species, e.g. protected raptors. Therefore,\nDevon must amend their risk analysis criteria to include consequence risk factors for human safety and\nprotected species as required by Part §195.452(i)(2).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the document\nwith the 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. 552(b). If you\ndo not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to\ncontest the allegations 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.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 60 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in your\namended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Devon Gas Services, LP maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous\nMaterials Safety Administration.\nIn correspondence concerning this matter, please refer to CPF 5-2012-6015M and, for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 G. Davis (#134159)\n\n520126015M_closure letter_07092012_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 9, 2012\nMr. Tracy Carter\nRegional Vice-President\nDevon Energy Corporation\n333 W. Sheridan Ave.\nOklahoma City, OK 73102\nCPF 5-2012-6015M\nDear Mr. Carter:\nOn September 26 through 29, 2011, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted\nan on-site pipeline safety inspection of Devon Gas Service’s (Devon) integrity management\nprogram procedures in Riverton, Wyoming. As a result of the inspection, Devon was issued a\nNotice of Amendment on April 19, 2012, which proposed amendment of your procedures.\nDevon responded to the Notice of Amendment on May 23, 2012. In its response, Devon\ncontested the alleged inadequacies outlined in the Notice and explained how its procedures\naddress them. My staff has reviewed Devon’s response and procedures, and it appears that they\nadequately address the allegations.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\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":9897}