{"operation":"document","citation":"CPF 520176007W","title":"WESTERN MIDSTREAM PARTNERS, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-04","effective_on":null,"summary":"CLOSED warning letter citing 195.412(a), 195.420(b), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520176007W","body":"Warning Letter involving WESTERN MIDSTREAM PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 195.412(a),  195.420(b),  195.583(a). The case was opened on 2017-04-04 and is reported as closed as of 2017-04-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520176007W_Warning Letter_04042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176007W/520176007W_Warning%20Letter_04042017.pdf\n\n520176007W_Warning Letter_04042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176007W/520176007W_Warning%20Letter_04042017_text.pdf\n\n520176007W_Warning Letter_04042017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 4, 2017\nMr. Al Walker\nPresident\nAnadarko Petroleum Corporation\n1201 Lake Robbins Drive\nThe Woodlands, TX 77380\nCPF 5-2017-6007W\nDear Mr. Walker:\nOn October 26 through 30, 2016, and November 14 through 18, 2016, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601\nof 49 United States Code, inspected your Chipeta Pipelines and Granger-Mapco Pipeline in\nVernal, Utah and Granger, Wyoming, respectively.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §195.412 Inspection of rights-of-way and crossings under navigable waters.\n(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times\neach calendar year, inspect the surface conditions on or adjacent to each pipeline\nright-of-way. Methods of inspection include walking, driving, flying or other\nappropriate means of traversing the right-of-way.\n\n\n\nAnadarko Petroleum Corporation (APC) failed to inspect the surface conditions on or\nadjacent to each pipeline right-of-way (ROW) for the Chipeta Pipelines and Granger-Mapco\nPipeline, at intervals not exceeding three (3) weeks, in accordance with §195.412(a). During\nthe records review of APC’s ROW inspection program, it was noted that APC exceeded the\nthree-week requirements between January 10, 2015 and February 6, 2015 for the Chipeta\nPipelines. In addition, APC exceeded the three-week requirements between August 10, 2015\nand September 3, 2015, between October 30, 2015 and November 24, 2015, and between\nDecember 9, 2015 and February 9, 2016 for the Granger-Mapco Pipeline.\n2. §195.420 Valve maintenance.\n(b) Each operator shall, at intervals not exceeding 7 ½ months, but at least twice\neach calendar year, inspect each mainline valve to determine that it is functioning\nproperly.\nAPC failed to inspect each mainline valve for Granger-Mapco Pipeline, at intervals not\nexceeding 7 ½ months, in accordance with §195.420(b). During the records review of APC’s\nvalve maintenance program, it was noted that APC failed to demonstrate that they performed\nvalve inspections on the mainline valves for the second part of 2014. Additionally, APC\nexceeded the 7 ½-month requirements between August 18, 2015 and April 18, 2016.\n3. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nOnshore – At least once every 3 calendar years, but with intervals not exceeding\n39 months.\nAPC failed to inspect each pipeline or portion of pipeline that is exposed to the atmosphere\nfor evidence of atmospheric corrosion for Granger-Mapco Pipeline at least every 3 calendar\nyears, but with intervals not exceeding 39 months, in accordance with §195.583(a). During\nthe records review of APC’s atmospheric control program, it was noted that APC exceeded\nthe 39-month requirement for conducting their atmospheric corrosion monitoring program.\nThe period of monitoring was between January 25, 2012 and July 15, 2015. This interval\nexceeded the maximum allowable interval by 3 months.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\n2\n\n\n\nthis time. We advise you to correct the item(s) identified in this letter. Failure to do so will\nresult in Anadarko Petroleum Corporation being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-6007W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong 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\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#153720 and #153718)\n3","truncated":false,"body_characters":5848}