{"operation":"document","citation":"CPF 520196008W","title":"DCP MIDSTREAM — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-08-26","effective_on":null,"summary":"CLOSED warning letter citing 195.410(a)(1), 195.420(b), 195.420(c), 195.428(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520196008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520196008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520196008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520196008W","body":"Warning Letter involving DCP MIDSTREAM. PHMSA's enforcement data identifies the cited regulations as 195.410(a)(1),  195.420(b),  195.420(c),  195.428(a). The case was opened on 2019-08-26 and is reported as closed as of 2019-08-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520196008W_Warning Letter_08262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196008W/520196008W_Warning%20Letter_08262019.pdf\n\n520196008W_Warning Letter_08262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520196008W/520196008W_Warning%20Letter_08262019_text.pdf\n\n520196008W_Warning Letter_08262019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 26, 2019\nMr. Brent Backes\nGroup Vice President and General Counsel\nDCP Midstream\n370 17th Street, Suite 2500\nDenver, CO 80202-0202\nCPF 5-2019-6008W\nDear Mr. Backes:\nOn June 3 through June 7, 2019, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected your Weld County highly-volatile liquid (HVL) system in Greeley, Colorado.\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 (CFR). The items\ninspected and the probable violations are:\n1. § 195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the\ncase of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½\nmonths, but at least twice each calendar year, inspect and test each pressure\nlimiting device, relief valve, pressure regulator, or other item of pressure control\nequipment to determine that it is functioning properly, is in good mechanical\ncondition, and is adequate from the standpoint of capacity and reliability of\noperation for the service in which it is used.\n\n\n\nThe following overpressure safety devices were not inspected at the specified intervals:\n Pressure Safety Valve (PSV) 2120 was inspected on 4/25/2017 and 12/28/2017. This\nexceeded the allowed 7½ months interval for lines used to carry HVLs.\n PSV 2117 was inspected on 8/18/2016 and 8/26 /2017. This exceeded the allowed 7½\nmonths interval for lines used to carry HVLs.\n2. § 195.420 Valve maintenance.\n(a) . . .\n(b) Each operator shall, at intervals not exceeding 7½ months, but at least twice\neach calendar year, inspect each mainline valve to determine that it is functioning\nproperly.\nThe following mainline valves were not inspected at the specified intervals:\n Lucerne 6-inch line:\n(2) - 6 inch mainline valves; the Lucerne Track Rack and the Lucerne tie-in to\nWilliams were inspected on 8/24/2018 and 5/14/2019. This exceeded the allowed 7½\nmonths interval.\n BH 4-inch line:\n(1) - 4-inch mainline manual valve; the Platteville River Crossing 01-V-04-0127 is\nmissing inspection records for 2018. Only one inspection was performed on 5/08/2017\nin 2017.\n (2) - 4 inch mainline automated valves; SDV-4069 and SDV-04086 were inspected on\n1/17/2017 and 12/18/2017. This exceeded the allowed 7½ months interval.\n (2) - 4 inch mainline automated valves; KG-6 and KG-7 were inspected on 8/7/2018\nand 5/30/2019. This exceeded the allowed 7½ months interval.\n (1) - 4-inch mainline automated valve; KG -8 was inspected on 8/8/2018 and\n6/28/2019. This exceeded the allowed 7½ months interval.\n Rogen 2-inch line:\n(1) - 2-inch ball valve at the COP site; ball valve was inspected on 5/9/2017 and\n1/15/2018. This exceeded the allowed 7½ months interval.\n (1) - 2-inch ball valve at the Plains yard RR & 398; ball valve was inspected on\n5/8/2017 and 1/15/2018. This exceeded the allowed 7½ months interval.\n (1) - 2-inch ball valve at the Roggan Plant; ball valve was inspected on 10/17/2017 and\n2\n\n\n\n8/21/2018. This exceeded the allowed 7½ months interval.\n (1) - 2-inch ball valve at the Old Phillips Plant; ball valve was inspected on 5/8/2017\nand 1/15/2017. This exceeded the allowed 7½ months interval.\n Roggen 4-inch line:\n(1) - 4-inch ball valve at the Gherkin/North of I-70; ball valve was inspected on\n5/8/2017 and 1/15/2018. This exceeded the allowed 7½ months interval.\n (1) - 4-inch ball valve at the COP site; ball valve was inspected on 5/8/2017 and\n1/15/2018. This exceeded the allowed 7½ months interval.\n3. § 195.420 Valve maintenance.\n(a) . . .\n(c) Each operator shall provide protection for each valve from unauthorized\noperation and from vandalism\nThe following mainline valves are automated valves with their own Emergency Shutdown\nButton (ESB). These valves’ ESBs did not have any protections or safeguards against\nunauthorized operation.\n BH4 inch line:\nValves KG#6, KG#7, KG#8\n Roggen 4-inch line:\nValve #2\n4. § 195.410 Line markers.\n(a) Except as provided in paragraph (b) of this section, each operator shall place\nand maintain line markers over each buried pipeline in accordance with the\nfollowing:\n(1) Markers must be located at each public road crossing, and in sufficient\nnumber along the remainder of each buried line so that its location is accurately\nknown.\nOn the BH 4-inch line, the company did not have a sufficient number of pipeline markers\nbetween the 4-inch manual valve and the Platteville River crossing so that the buried line’s\nlocation was accurately known. No markers were observable in the area, or near the area, to\nindicate the pipeline’s location. Further, during the inspection, the operator’s personnel could\nnot provide the location of the pipeline between the 4-inch manual valve and the Platteville\nriver crossing.\n3\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679\nfor a related series of violations. For violation occurring on or after November 2, 2015 and\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per\nday, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to\nNovember 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with\na maximum penalty not to exceed $2,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in DCP\nMidstream 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 5-2019-6008W. 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 portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Y. Liang (#163299)\n4","truncated":false,"body_characters":7559}