CPF 520175010M
CPF 520175010M
party submissionOfficial PDF520175010M_Operator Response to Notice_07242017.pdf#
520175010M_Closure Letter_10062017_text.pdf, page 1Official PDFVIA FED EX – TRACKING NO. 7704 3810 0713 October 6, 2017 Mr. Jerry Barnhill Senior Vice President EHS and Pipeline Services DCP Operating Company, LP (Formerly named DCP Midstream, LP) 370 17th Street Denver, CO 80202 CPF 5-2017-5010M Closure Letter Dear Mr. Barhill: From September 2016 through March 2017, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of DCP Operating Company’s (DCP) procedures in Colorado and Kansas. As a result of the inspection, DCP was issued a Notice of Amendment on June 26, 2017, which proposed amendment of your procedures. DCP submitted its amended procedures on July 24, 2017. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Dustin Hubbard Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 C. Allen (#152397)#
520175010M_Notice of Amendment_06262017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED June 26, 2017 Mr. Jerry Barnhill Senior Vice President EHS and Pipeline Services DCP Midstream 370 17th Street Denver, CO 80202 CPF 5-2017-5010M Dear Mr. Barnhill: From September 2016 through March 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected DCP Midstream’s (DCPM) procedures for the Wattenberg to Bushton HVL System in Colorado and Kansas. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within DCPM’s plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. DCP Midstream (DCPM) did not establish adequate written external corrosion control procedures to address the circumstances in which is a close-interval survey or comparable technology is practicable in accordance with §195.573(a)(2). At the time of the inspection, it was noted that DCPM’s external corrosion control procedures for identifying a close-interval survey (CIS) or comparable technology#
520175010M_Notice of Amendment_06262017_text.pdf, page 2only apply for the new pipeline construction within 2 years or the preventive and mitigative measures activities for segments that could affect a high-consequence area. Therefore, DPCM must modify their procedure to describe the circumstances in which a close-interval survey or comparable technology is practicable and necessary to accomplish the objectives of paragraph 10.1.1.3 of NACE SP 0169 for all the pipelines in accordance with §195.573(a)(2). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that DCP Midstream maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Acting Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5- 2017-5010M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dustin Hubbard Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 C. Allen (#152397)#
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