# WESTERN MIDSTREAM PARTNERS, LP — Warning Letter

- **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:** Not available
- **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.

Official case documents:

520176007W_Warning Letter_04042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176007W/520176007W_Warning%20Letter_04042017.pdf

520176007W_Warning Letter_04042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176007W/520176007W_Warning%20Letter_04042017_text.pdf

520176007W_Warning Letter_04042017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 4, 2017
Mr. Al Walker
President
Anadarko Petroleum Corporation
1201 Lake Robbins Drive
The Woodlands, TX 77380
CPF 5-2017-6007W
Dear Mr. Walker:
On October 26 through 30, 2016, and November 14 through 18, 2016, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601
of 49 United States Code, inspected your Chipeta Pipelines and Granger-Mapco Pipeline in
Vernal, Utah and Granger, Wyoming, respectively.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §195.412 Inspection of rights-of-way and crossings under navigable waters.
(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times
each calendar year, inspect the surface conditions on or adjacent to each pipeline
right-of-way. Methods of inspection include walking, driving, flying or other
appropriate means of traversing the right-of-way.



Anadarko Petroleum Corporation (APC) failed to inspect the surface conditions on or
adjacent to each pipeline right-of-way (ROW) for the Chipeta Pipelines and Granger-Mapco
Pipeline, at intervals not exceeding three (3) weeks, in accordance with §195.412(a). During
the records review of APC’s ROW inspection program, it was noted that APC exceeded the
three-week requirements between January 10, 2015 and February 6, 2015 for the Chipeta
Pipelines. In addition, APC exceeded the three-week requirements between August 10, 2015
and September 3, 2015, between October 30, 2015 and November 24, 2015, and between
December 9, 2015 and February 9, 2016 for the Granger-Mapco Pipeline.
2. §195.420 Valve maintenance.
(b) Each operator shall, at intervals not exceeding 7 ½ months, but at least twice
each calendar year, inspect each mainline valve to determine that it is functioning
properly.
APC failed to inspect each mainline valve for Granger-Mapco Pipeline, at intervals not
exceeding 7 ½ months, in accordance with §195.420(b). During the records review of APC’s
valve maintenance program, it was noted that APC failed to demonstrate that they performed
valve inspections on the mainline valves for the second part of 2014. Additionally, APC
exceeded the 7 ½-month requirements between August 18, 2015 and April 18, 2016.
3. §195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed to the
atmosphere for evidence of atmospheric corrosion, as follows:
Onshore – At least once every 3 calendar years, but with intervals not exceeding
39 months.
APC failed to inspect each pipeline or portion of pipeline that is exposed to the atmosphere
for evidence of atmospheric corrosion for Granger-Mapco Pipeline at least every 3 calendar
years, but with intervals not exceeding 39 months, in accordance with §195.583(a). During
the records review of APC’s atmospheric control program, it was noted that APC exceeded
the 39-month requirement for conducting their atmospheric corrosion monitoring program.
The period of monitoring was between January 25, 2012 and July 15, 2015. This interval
exceeded the maximum allowable interval by 3 months.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a
related series of violations. For violation occurring between January 4, 2012 to August 1,
2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum
penalty not to exceed $2,000,000 for a related series of violations. For violations occurring
prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per
day, with a maximum penalty not to exceed $1,000,000 for a 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
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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 5-2017-6007W. 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 D. Fehling (#153720 and #153718)
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