CPF 520176011M
CPF 520176011M
party submissionOfficial PDF520176011M_Operator Response to Notice_05042017.pdf#
520176011M_Notice of Amendment_04042017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED April 4, 2017 Mr. Al Walker President Anadarko Petroleum Corporation 1201 Lake Robbins Drive The Woodlands, TX 77380 CPF 5-2017-6011M Dear Mr. Walker: On October 26 through 30, 2016, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Anadarko Petroleum Corporation’s procedures for atmospheric corrosion control, and rectifiers and other devices inspections in Vernal, Utah. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Anadarko’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. Anadarko Petroleum Corporation (APC) did not establish adequate written atmospheric corrosion control procedures to give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under bonded coatings, at pipe supports, in splash zones, at deck#
520176011M_Notice of Amendment_04042017_text.pdf, page 2penetrations, and in spans over water in accordance with §195.583(b). At the time of the inspection, it was noted that the procedure in the APC Manual does not provide sufficient guidance for performing the inspection of aboveground pipelines exposed to the atmosphere, especially pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, or at pipe supports. Therefore, APC must modify their procedure to provide specific details on how to inspect the above ground pipelines for atmospheric corrosion as required by §195.583(b). 2. §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. APC did not establish adequate written procedure for performing inspections of rectifiers, interference bonds, diodes, or reverse current switches in accordance with §195.573(c). At the time of the inspection, it was noted that the procedure in the APC Manual only specifies the inspection frequency for checking rectifiers and other devices in accordance with §195.573(c). Therefore, APC must modify their procedure to provide details on how to perform inspections of rectifiers, interference bonds, diodes, or reverse current switches as required by §195.573(c). 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 2#
520176011M_Notice of Amendment_04042017_text.pdf, page 3by 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 Anadarko Petroleum Corporation maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2017-6011M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal 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 D. Fehling (#153720) 3#
520176011M_Closure Letter_06282017_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED June 28, 2017 Mr. Al Walker President Anadarko Petroleum Corporation 1201 Lake Robbins Drive The Woodlands, TX 77380 CPF 5-2017-6011M Closure Letter Dear Mr. Walker: On October 26 through 30, 2016, 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 Anadarko Petroleum Company’s procedures in Vernal, Utah. As a result of the inspection, Anadarko Petroleum Company was issued a Notice of Amendment on April 4, 2017, which proposed amendment of your procedures. Anadarko Petroleum Corporation submitted its amended procedures on May 4, 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, Huy Nguyen Acting Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 D. Fehling (#153720)#
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