{"operation":"document","citation":"CPF 520205003W","title":"WESTERN MIDSTREAM PARTNERS, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-04-09","effective_on":null,"summary":"CLOSED warning letter citing 195.302(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520205003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520205003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520205003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520205003W","body":"Warning Letter involving WESTERN MIDSTREAM PARTNERS, LP. PHMSA's enforcement data identifies the cited regulation as 195.302(a). The case was opened on 2020-04-09 and is reported as closed as of 2020-04-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520205003W_Warning Letter (REVISED)_04092020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205003W/520205003W_Warning%20Letter%20(REVISED)_04092020.pdf\n\n520205003W_Warning Letter (REVISED)_04092020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205003W/520205003W_Warning%20Letter%20(REVISED)_04092020_text.pdf\n\n520205003W_Warning Letter_02282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205003W/520205003W_Warning%20Letter_02282020.pdf\n\n520205003W_Warning Letter_02282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205003W/520205003W_Warning%20Letter_02282020_text.pdf\n\n520205003W_Warning Letter (REVISED)_04092020_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. CRAIG COLLINS\nApril 9, 2020\nMr. Craig Collins\nSenior Vice President and Chief Operating Officer\nAnadarko Petroleum Corporation\n5 Greenway Plaza, Suite 110\nHouston, TX 77046\nCPF 5-2020-5003W\nDear Mr. Collins:\nOn July 18, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an accident\ninvestigation of an incident involving your pipeline facilities near Red Desert, Wyoming that was\ndiscovered on July 15, 2019.\nAs a result of the investigation, it is alleged that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable\nviolation is:\n1. § 195.302 General requirements.\n(a) Except as otherwise provided in this section and in §195.305(b), no operator may\noperate a pipeline unless it has been pressure tested under this subpart without leakage. In\naddition, no operator may return to service a segment of pipeline that has been replaced,\nrelocated, or otherwise changed until it has been pressure tested under this subpart without\nleakage.\n\n\n\nAnadarko Petroleum Corporation transported product through an abandoned pipeline, Wamsutter Trunk\n“C” mainline, prior to pressure testing it without leakage under Part 195, Subpart E.\nSpecifically, on May 14, 2003, the Wamcutter Trunk “C” Mainline was abandoned (see Exhibit A). In\nDecember 2018, operator personnel were performing maintenance on Wamsutter Trunk “B” Mainline,\nwhen an inline inspection tool became stuck inside. The operator decided to reroute the product stuck in\nTrunk B through the abandoned Trunk “C” Mainline. Based on conversations with the operator’s\npersonnel, Trunk “C” Mainline was not hydrotested prior to the product being rerouted.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series\nof violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed\n$2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the\nmaximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed\n$2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed\n$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of\nviolations. We have reviewed the circumstances and supporting documents involved in this case, and\nhave decided not to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the item identified in this letter. Failure to do so will result in Anadarko\nPetroleum Corporation being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 5-\n2020-5003W. Be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 S. Perkins (#166350)\n\n520205003W_Warning Letter_02282020_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 28, 2020\nMr. Al Walker\nPresident\nAnadarko Petroleum Corporation\n5 Greenway Plaza, Suite 110\nHouston, TX 77046\nCPF 5-2020-5003W\nDear Mr. Walker:\nOn July 18, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an accident\ninvestigation of an incident involving your pipeline facilities near Red Desert, Wyoming that was\ndiscovered on July 15, 2019.\nAs a result of the investigation, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 195.302 General requirements.\n(a) Except as otherwise provided in this section and in §195.305(b), no operator may\noperate a pipeline unless it has been pressure tested under this subpart without\nleakage. In addition, no operator may return to service a segment of pipeline that has\nbeen replaced, relocated, or otherwise changed until it has been pressure tested under\nthis subpart without leakage.\nAnadarko Petroleum Corporation transported product through an abandoned pipeline, Wamsutter\nTrunk “C” mainline, prior to pressure testing it without leakage under Part 195, Subpart E.\nSpecifically, on May 14, 2003, the Wamcutter Trunk “C” Mainline was abandoned (see Exhibit\nA). In December 2018, operator personnel were performing maintenance on Wamsutter Trunk\n\n\n\n“B” Mainline, when an inline inspection tool became stuck inside. The operator decided to reroute\nthe product stuck in Trunk B through the abandoned Trunk “C” Mainline. Based on conversations\nwith the operator’s personnel, Trunk “C” Mainline was not hydrotested prior to the product being\nrerouted.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. 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 day,\nwith a maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2,\n2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to conduct\nadditional enforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item identified in this letter. Failure to do so will result in Anadarko Petroleum\nCorporation being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2020-5003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 S. Perkins (#166350)\n2","truncated":false,"body_characters":8715}