{"operation":"document","citation":"CPF 520176011M","title":"WESTERN MIDSTREAM PARTNERS, LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-04-04","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176011m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176011m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520176011m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520176011M","body":"Notice of Amendment involving WESTERN MIDSTREAM PARTNERS, LP. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2017-04-04 and is reported as closed as of 2017-06-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520176011M_Closure Letter_06282017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Closure%20Letter_06282017.pdf\n\n520176011M_Closure Letter_06282017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Closure%20Letter_06282017_text.pdf\n\n520176011M_Notice of Amendment_04042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Notice%20of%20Amendment_04042017.pdf\n\n520176011M_Notice of Amendment_04042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Notice%20of%20Amendment_04042017_text.pdf\n\n520176011M_Operator Response to Notice_05042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Operator%20Response%20to%20Notice_05042017.pdf\n\n520176011M_Notice of Amendment_04042017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 4, 2017\nMr. Al Walker\nPresident\nAnadarko Petroleum Corporation\n1201 Lake Robbins Drive\nThe Woodlands, TX 77380\nCPF 5-2017-6011M\nDear Mr. Walker:\nOn October 26 through 30, 2016, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Anadarko Petroleum Corporation’s procedures for atmospheric corrosion control,\nand rectifiers and other devices inspections in Vernal, Utah.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nAnadarko’s plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nAnadarko Petroleum Corporation (APC) did not establish adequate written atmospheric\ncorrosion control procedures to give particular attention to pipe at soil-to-air interfaces, under\nthermal insulation, under bonded coatings, at pipe supports, in splash zones, at deck\n\n\n\npenetrations, and in spans over water in accordance with §195.583(b). At the time of the\ninspection, it was noted that the procedure in the APC Manual does not provide sufficient\nguidance for performing the inspection of aboveground pipelines exposed to the atmosphere,\nespecially pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, or\nat pipe supports. Therefore, APC must modify their procedure to provide specific details on\nhow to inspect the above ground pipelines for atmospheric corrosion as required by\n§195.583(b).\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nAPC did not establish adequate written procedure for performing inspections of rectifiers,\ninterference bonds, diodes, or reverse current switches in accordance with §195.573(c). At the\ntime of the inspection, it was noted that the procedure in the APC Manual only specifies the\ninspection frequency for checking rectifiers and other devices in accordance with\n§195.573(c). Therefore, APC must modify their procedure to provide details on how to\nperform inspections of rectifiers, interference bonds, diodes, or reverse current switches as\nrequired by §195.573(c).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended\n2\n\n\n\nby written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Anadarko Petroleum Corporation maintain documentation\nof the safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2017-6011M and, for each document you\nsubmit, 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 D. Fehling (#153720)\n3\n\n520176011M_Closure Letter_06282017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 28, 2017\nMr. Al Walker\nPresident\nAnadarko Petroleum Corporation\n1201 Lake Robbins Drive\nThe Woodlands, TX 77380\nCPF 5-2017-6011M\nClosure Letter\nDear Mr. Walker:\nOn October 26 through 30, 2016, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Anadarko Petroleum Company’s procedures in Vernal, Utah.\nAs a result of the inspection, Anadarko Petroleum Company was issued a Notice of Amendment\non April 4, 2017, which proposed amendment of your procedures.\nAnadarko Petroleum Corporation submitted its amended procedures on May 4, 2017. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nHuy Nguyen\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#153720)","truncated":false,"body_characters":7836}