{"operation":"document","citation":"CPF 52022018NOA","title":"WESTERN MIDSTREAM PARTNERS, LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-03-07","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(e)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022018noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022018noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022018noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022018NOA","body":"Notice of Amendment involving WESTERN MIDSTREAM PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(e)(2). The case was opened on 2022-03-07 and is reported as closed as of 2022-05-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022018NOA_Closure Letter_05312022_(21-201443).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022018NOA/52022018NOA_Closure%20Letter_05312022_(21-201443).pdf\n\n52022018NOA_Closure Letter_05312022_(21-201443)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022018NOA/52022018NOA_Closure%20Letter_05312022_(21-201443)_text.pdf\n\n52022018NOA_Notice of Amendment_03072022_(21-201443).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022018NOA/52022018NOA_Notice%20of%20Amendment_03072022_(21-201443).pdf\n\n52022018NOA_Notice of Amendment_03072022_(21-201443)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022018NOA/52022018NOA_Notice%20of%20Amendment_03072022_(21-201443)_text.pdf\n\n52022018NOA_Operator Response to Notice_04062022_(21-201443).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022018NOA/52022018NOA_Operator%20Response%20to%20Notice_04062022_(21-201443).pdf\n\n52022018NOA_Notice of Amendment_03072022_(21-201443)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MR. CRAIG COLLINS\nMarch 7, 2022\nMr. Craig Collins\nChief Operations Officer and\nSenior Vice President\nWestern Midstream Partners, LP\n9950 Woodloch Forest Dr., Suite 2800\nThe Woodlands, TX 77380\nCPF 5-2022-018-NOA\nDear Mr. Collins:\nFrom November 1 through 5, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, reviewed\nthe written control room management plan, procedures, and records of Western Midstream\nPartners, LP (Western) in Platteville, Colorado.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within\nWestern’s control room management procedures, as described below:\n1. § 195.446 - Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. The procedures required by this section must be integrated, as\nappropriate, with the operator’s written procedures required by § 195.402. …\n\n\n\nWestern’s written procedures were inadequate to assure safe operation of a pipeline facility.\nSpecifically, Western did not have and follow written control room management procedures that\nimplemented the requirements set forth in § 195.446. Pursuant to § 195.446(c)(2), each operator\nmust provide its controllers with the information, tools, processes and procedures necessary for\nthe controllers to carry out the roles and responsibilities the operator has defined by conducting a\npoint-to-point verification between SCADA displays and related field equipment when certain\nconditions are met. In order to conduct a point-to-point verification, an operator must first define\nand identify Safety Related Points (SRP) for the SCADA system.1 In practice, Western\nMidstream maintains a list of Safety Related Points. However, the Western Midstream DOT\nPipeline Compliance Control Room Management Plan 4.0 (CRMP) does not indicate how\nWestern defines SRP nor does it include a written procedure that guides the selection of SRPs.\n2. § 195.446 - Control room management.\n(a)…\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1)…\n(2) Identify at least once each calendar month points affecting safety that have been\ntaken off scan in the SCADA host, have had alarms inhibited, generated false alarms,\nor that have had forced or manual values for periods of time exceeding that required\nfor associated maintenance or operating activities;…\nWestern’s written procedures were inadequate to assure safe operation of a pipeline facility.\nSpecifically, Western’s written alarm management plan, CRMP Section 5-Alarm Management,\ndid not provide for effective controller response to alarms because it failed to include procedures\nfor identifying points affecting safety that have been taken off scan in the SCADA host, have had\nalarms inhibited, generated false alarms, or that have had forced or manual values for periods of\ntime exceeding that required for associated maintenance or operating activities once each\ncalendar month. During the inspection, the Western Midstream control room team was not able\nto articulate how the review was conducted. Although the Western Midstream SCADA subject\nmatter expert articulated the process the SCADA group is expected to use to review and analyze\nAlarms and other SCADA data, the CRMP does not contain a written procedure to conduct the\nreview.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings.\n1 See PHMSA Control Room Management Frequently Asked Questions A.16 and C.01 (Rev. Jan. 2018), available\nat https://www.phmsa.dot.gov/pipeline/control-room-management/control-room-management-faqs (last accessed\nFeb. 7, 2022).\n2\n\n\n\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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 of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Westerm Midstream Partners, LP maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Dustin Hubbard, Director,\nWestern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 5-2022-018-NOA and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#21-201443)\n3\n\n52022018NOA_Closure Letter_05312022_(21-201443)_text.pdf\n\nVIA E-MAIL TO MR. CRAIG COLLINS\nMay 31, 2022\nMr. Craig Collins\nChief Operations Officer and\nSenior Vice President\nWestern Midstream Partners, LP\n9950 Woodloch Forest Dr., Suite 2800\nThe Woodlands, TX 77380\nCPF 5-2022-018-NOA\nClosure Letter\nDear Mr. Collins:\nFrom November 1 through 5, 2021, representatives 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 the written control room management plan, procedures, and\nrecords of Western Midstream Partners, LP (Western) in Platteville, Colorado. As a result of the\ninspection, Western was issued a Notice of Amendment on March 7, 2022, which proposed\namendment of your procedures.\nWestern submitted its amended procedures on April 6, 2022. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#21-201443)","truncated":false,"body_characters":9198}