# WESTERN MIDSTREAM PARTNERS, LP — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 195.402(c)(3).
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- **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.

Official case documents:

520176011M_Closure Letter_06282017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Closure%20Letter_06282017.pdf

520176011M_Closure Letter_06282017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Closure%20Letter_06282017_text.pdf

520176011M_Notice of Amendment_04042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Notice%20of%20Amendment_04042017.pdf

520176011M_Notice of Amendment_04042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Notice%20of%20Amendment_04042017_text.pdf

520176011M_Operator Response to Notice_05042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176011M/520176011M_Operator%20Response%20to%20Notice_05042017.pdf

520176011M_Notice of Amendment_04042017_text.pdf

NOTICE 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



penetrations, 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



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 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

CERTIFIED 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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