{"operation":"document","citation":"CPF 52023053CAO","title":"ORYX DELAWARE OIL TRANSPORT LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-08-11","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023053cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023053cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023053cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52023053CAO","body":"Corrective Action Order involving ORYX DELAWARE OIL TRANSPORT LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2023-08-11 and is reported as closed as of 2026-05-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52023053CAO_Closure Letter_05212026_(23-283484).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Closure%20Letter_05212026_(23-283484).pdf\n\n52023053CAO_Closure Letter_05212026_(23-283484)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Closure%20Letter_05212026_(23-283484)_text.pdf\n\n52023053CAO_Corrective Action Order_08112023_(23-283484).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Corrective%20Action%20Order_08112023_(23-283484).pdf\n\n52023053CAO_Corrective Action Order_08112023_(23-283484)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Corrective%20Action%20Order_08112023_(23-283484)_text.pdf\n\n52023053CAO_Closure Letter_05212026_(23-283484)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n12300 West Dakota Avenue, Suite 340\nLakewood, Colorado 80228\nVIA ELECTRONIC MAIL TO: patrick.hodgins@plains.com\nMay 21, 2026\nPatrick Hodgins\nVice President, Health, Safety, Environmental\nOryx Delaware Oil Transport LLC.\n333 Clay Street, Suite 1900\nHouston, TX 77002\nCPF 5-2023-053-CAO\nClosure Letter\nDear Mr. Hodgins,\nOn August 11, 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Oryx Delaware Oil Transport (ODOT), a subsidiary of the Plains Oryx Permian Basin\nLLC a Corrective Action Order in the above-referenced case. This Order included a requirement\nto take corrective actions on your pipeline. Based on our review of the documentation you\nprovided it has been determined that you have complied with the terms of this Order.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n\n\ncc: PHP-60 Compliance Registry\nPHP-500 J. Long (23-283484)\ncc: Kevin Cunningham, HSE Regulatory Compliance, Kevin.Cunningham@plains.com\n\n52023053CAO_Corrective Action Order_08112023_(23-283484)_text.pdf\n\nAugust 11, 2023\nVIA ELECTRONIC MAIL TO: patrick.hodgins@plains.com\nPatrick Hodgins\nVice President, Heath, Safety, Environmental\nOryx Delaware Oil Transport LLC\n333 Clay Street, Suite 1900\nHouston, Texas 77002\nCPF No. 5-2023-053-CAO\nDear Mr. Hodgins:\nEnclosed please find a Corrective Action Order issued by the Pipeline and Hazardous Materials\nSafety Administration, Office of Pipeline Safety, in the above-referenced case. It requires Oryx\nDelaware Oil Transport LLC (Oryx or Respondent) to take certain corrective actions with\nrespect to the August 6, 2023, failure of its Southeast 12-inch Mainline pipeline located in\nReeves County, approximately 14 miles south of Grandfalls, Texas.\nService of this Order by electronic mail is deemed complete upon transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Dustin Hubbard, Director, Western Region, OPS\nMr. Ngiabi Gicuhi, Managing Director, HSE Compliance, Oryx Delaware Oil Transport\nLLC, ngiabi.gicuhi@plains.com\nMs. Sherri Adkins, Senior Manager, HSE, Integrity and Records, Oryx Delaware Oil\nTransport, LLC, sherri.adkins@plains.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nOryx Delaware Oil Transport, LLC, )\na subsidiary Oryx Midstream, LLC, ) CPF No. 5-2023-053-CAO\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority\nof 49 U.S.C. § 60112 and 49 CFR § 190.233 to require Oryx Delaware Oil Transport LLC1\n(Oryx or Respondent) to take the necessary corrective actions to protect the public, property, and\nthe environment from potential hazards associated with the August 6, 2023 failure of the\nSoutheast 12-inch Mainline hazardous liquid pipeline in the South Gathering System located\napproximately 14 miles south of Grandfalls, Texas (Accident).\nOn August 6, 2023, at approximately 11:40 am Central Daylight Time (CDT), Oryx’s control\nroom received a pipeline monitoring (PLM) alert indicating a product shortage prompting\nRespondent to conduct a shut-in test. Oryx confirmed a failure in the pipeline at 9:06 pm CDT\nafter visual confirmation of spilled hazardous liquid above the buried pipeline. Initial estimates\nindicated that the failed pipeline released 470 barrels (bbls) of crude oil.\nOryx has reported that the pipeline was initially shutdown after the discovery of the Accident,\nbut returned to service the evening of August 7, 2023, after a PLIDCO clamp was installed. The\nexact cause of the failure remains unknown.\nPursuant to 49 U.S.C. § 60117, PHMSA initiated an investigation of the Accident. The\npreliminary findings of the Agency’s ongoing investigation are as follows:\nPreliminary Findings\n• At approximately 11:40 am CDT, Oryx control room received a PLM alert indicating\na shortage in the Southeast 12-inch Mainline pipeline. The controller contacted\n1 This pipeline system is part of a joint venture between Oryx Midstream, LLC and Plains All American Pipeline,\nLP.\n\n\n\nmanagement and Respondent decided to conduct a shut-in test to confirm whether\nthere was a failure in the pipeline section. The pressure test was conducted at\napproximately 5:35 pm CDT. During that test, there was a noticeable drop in\npressure, prompting a shutdown of the pipeline, and dispatch of aerial and ground\npatrols, commencing at approximately 8:00 pm CDT on August 6, 2023.\n• At 9:06 pm CDT on August 6, 2023, Oryx technicians observed, and aerial patrols\nshowed a 225-foot by 35-foot area over the pipeline, with a crude oil depth of 4 to 5\ninches, confirming a failure.\n• At 11:02 pm CDT on August 6, 2023, Oryx reported the Accident to the National\nResponse Center (NRC) indicating there was a release of crude oil in a non-populated\narea of southwest Texas, and that it was unknown whether the Accident occurred in a\nhigh consequence area (NRC Report No. 1375405). The Respondent reported that\nthere were no fire, injuries, or evacuations, and that an estimated 470 bbls of crude oil\nwas spilled.\n• At 5:45 pm CDT on August 8, 2023, Oryx submitted a 48-hour update to the NRC\n(NRC Report No. 1375610) reducing the estimated amount of crude oil released to\n200 bbls.\n• After identification of the Accident, Oryx isolated the pipeline section by closing the\nupstream and downstream mainline block valves and vacuum trucks were dispatched\nto the site. A PLIDCO clamp was installed at approximately 8:45 am on August 7,\n2023.\n• Maximum operating pressure (MOP) of the Southeast 12-inch Mainline pipeline is\n740 psig.\n• At the time of Accident, the operating pressure was approximately 240-250 psig.\n• At 6:29 pm CDT on August 7, 2023, Oryx returned the Southeast 12-inch Mainline\npipeline to service.\n• At 3:00 pm CDT on August 9, 2023, Oryx shut down the Southeast 12-inch Mainline\npipeline.\n• The Oryx’s Southeast 12-inch Mainline pipeline is part of its South Gathering\nSystem, a 415.07-mile system of hazardous liquid transmission and gathering lines\nthat runs crude oil from gathering locations in Pecos, Texas, traveling north to\ntankage in Midland, Texas.\n• The Southeast 12-inch Mainline pipeline spans 25.98 miles and is located in Pecos,\nTexas and Reeves County, Texas.\n\n\n\n• The Southeast 12-inch Mainline pipeline was installed in 2017 and constructed of\nAPI 5L X-52 carbon steel, has a nominal diameter of 12-inches with a wall thickness\nof 0.25 inches, with a high-frequency electric resistance weld (HF-ERW) longitudinal\nseam weld, and a coating of thin-film fusion-bonded epoxy.\n• The South Gathering System is a pipeline facility subject to the Pipeline Safety Laws\nin 49 U.S.C. chapter 601 and 49 C.F.R. part 195.\n• Oryx reported to PHMSA that it uses impressed current for cathodic protection on\nthe Southeast 12-inch Mainline pipeline.\n• A foreign pipeline crosses the failed pipeline near the site of the Accident. According\nto Respondent, no bond exists between the pipelines.\n• The Southeast 12-inch Mainline pipeline is in a rural area. The failed pipeline is not\nnear any known water sources and is not in a high consequence area.\n• A prior accident on the South Gathering System also involving piping constructed of\nAPI 5L X-52 steel pipe with a 12-inch nominal diameter, wall thickness of 0.25\ninches, coating of fusion-bonded epoxy, and a HF-ERW longitudinal seam weld\noccurred on May 17, 20222\n, causing a release of 1,428 bbls of crude oil. That\naccident was discovered when a contractor conducting aerial patrols identified the\nrelease on the right-of-way in Reeves County, Texas.\n• The last in-line-inspection (ILI) of the Southeast 12-inch Mainline Pipeline was\ncompleted in May 2023. To date, no integrity digs have been completed.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material is transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\n2 See NRC Report Nos. 1336752 and 1336963\n\n\n\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider as\nappropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age3\nand physical properties (resistance to corrosion and deterioration), the hazardous nature of the\nmaterial the pipeline transports, including the corrosive and deteriorative qualities of the\nmaterial, aspects of the area in which the pipeline is located, including the crossing of foreign\nlines, the accident history of the Affected System, as defined below, the operating pressure\nrequired for transporting the material, the uncertainty of the root cause(s) of the Accident, and\nthe possibility that the same condition(s) that may have caused the Accident remain present in\nthe Affected System, PHMSA finds that continued operation of the Affected System, without\ncorrective measures is or would be hazardous to life, property, or the environment, and that\nfailure to issue this Order expeditiously would result in the likelihood of serious harm.\nAccordingly, this Order mandating immediate corrective action is issued expeditiously without\nprior notice and opportunity for a hearing. The terms and conditions of this Order are effective\nupon issuance.\nWithin 10 days of issuance of this Order, Respondent may request a hearing, to be held as soon\nas practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a\ncopy to the Director, Western Region, PHMSA. If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nDefinitions:\nAffected System – The “Affected System” means the entire South Gathering System.4\n3 The Southeast 12-inch Mainline Pipeline was installed in 2017.\n4 PHMSA has requested more detailed information regarding the start and end points of the South Gathering\nSystem. Respondent’s response is pending as of the issuance of this Order.\n\n\n\nIsolated Segment – The \"Isolated Segment\" means the section of the Southeast 12-inch\nMainline pipeline that failed, starting Valve SEMBV-4 (tag number V-BV4A), and ending at\nValve SEMBV-2 (tag number MOV 501).\nAffected Pipeline – The “Affected Pipeline” means the entire Southeast 12-inch Mainline\npipeline,, which starts at Valve SEMBV-4 west of Highway 18 and ends at Reeves Station.\nDirector – The Director, Western Region, PHMSA, OPS.\nPursuant to 49 U.S.C. 60112, I hereby order Respondent to immediately take the following\ncorrective actions:\n1. 2. 3. 4. 5. Shutdown of the Isolated Segment. Respondent must shutdown the Isolated Segment\nimmediately upon issuance of this Order. The Isolated Segment must remain shut-in and\nmay not be operated until authorized to be restarted by the Director in accordance with the\nterms of this Order.\nRecords Verification. Respondent must verify the records for the Isolated Segment that\nwere used to establish the MOP. Respondent must submit documentation of this record\nverification to the Director within 45 days of issuance of this Order.\nReview of Prior Inline Inspection Results. Within 90 days of issuance of this Order,\nRespondent must conduct a review of any previous inline inspection (ILI) results of the\nAffected Pipeline. In its review, Respondent must re-evaluate all ILI results since 2017,\nincluding a review of the ILI vendors' raw data and analysis. Respondent must determine\nwhether any features were present near the Accident site. Respondent must also determine\nif any features with similar characteristics are present elsewhere on the Affected Pipeline.\nRespondent must submit documentation of this ILI review to the Director within 90 days of\nissuance of this Order as follows:\na. b. c. d. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nList, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present in the failed joint and other pipe removed.\nList, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Pipeline.\nExplain the process used to review the ILI results and the results of the reevaluation.\nIn-Line Assessment. Within 180 days of issuance of this Order, subject to the approval of\nthe Director of its Restart Plan, Oryx must conduct an ILI of the Affected Pipeline using a\ngeometry tool, a high-resolution axial magnetic flux leakage (MFL) tool and a transverse\nMFL tool and must follow all the applicable requirements set forth in 49 CFR § 195.452.\nMechanical and Metallurgical Testing. Within 45 days of issuance of this Order,\nRespondent must complete mechanical and metallurgical testing and failure analysis of the\nfailed pipe, an analysis of representative soil samples from the Accident location and\nproduct transported in pipe at the time of failure, and any foreign materials. The testing\n\n\n\nmust be conducted by an independent third-party acceptable to the Director. Respondent\nmust complete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the Accident site.\n6. b. Within 10 days of issuance of this Order, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director with\nthe scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to Respondent.\nRoot Cause Failure Analysis. Within 90 days following issuance of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\nThe RCFA must be supplemented or facilitated by an independent third-party acceptable to\nthe Director and must document the decision-making process and all factors contributing to\nthe Accident, including potentially corrosive properties of the product or environment. The\nfinal report must include findings and any lessons learned and whether the findings and\nlessons learned are applicable to other locations within Respondent’s pipeline system.\n7. Remedial Work Plan.\na. b. c. Within 90 days following issuance of this Order, Respondent must submit a remedial\nwork plan (RWP) to the Director for approval.\nThe Director may approve the RWP incrementally without approving the entire RWP.\nOnce approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nd. e. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures Respondent will use to verify the integrity of the Affected Pipeline. It must\naddress all known or suspected factors and causes of the Accident. Respondent must\nconsider the risks and consequences of another failure to develop a prioritized\nschedule for RWP-related work along the Affected Pipeline.\nThe RWP must include a procedure or process to:\ni. Identify pipe in the Affected Pipeline with characteristics similar to the\ncontributing factors identified for the Accident.\nii. Gather all data necessary to review the failure history (in service and pressure test\nfailures) of the Affected Pipeline and to prepare a written report containing all the\navailable information such as the locations, dates, and causes of leaks and\nfailures.\niii. Integrate the results of the metallurgical testing, root cause failure analysis, and\nother corrective actions required by this Order with all relevant pre-existing\noperational and assessment data for the Affected Pipeline. Pre-existing\noperational data includes, but is not limited to, design, construction, operations,\n\n\n\nf. g. iv. v. maintenance, testing, repairs, prior metallurgical analyses, and any third-party\nconsultation information. Pre-existing assessment data includes, but is not limited\nto, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval\nsurveys, and DCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the Accident are likely to\nexist elsewhere on the Affected System.\nConduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nAccident and other failures from the failure history (see (e)(ii) above) or any other\nintegrity threats are present elsewhere on the Affected System. At a minimum, this\nprocess must consider all failure causes and specify the use of one or more of the\nfollowing:\n1) ILI tools that are technically appropriate for assessing the pipeline system\nbased on the cause of Accident and that can reliably detect and identify\nanomalies;\n2) Hydrostatic pressure testing;\n3) Close-interval surveys;\n4) Cathodic protection surveys, to include interference surveys in coordination\nwith other utilities/pipelines in the area;\n5) Coating surveys;\n6) Stress corrosion cracking surveys;\n7) Selective seam corrosion surveys; and\n8) Other tests, inspections, assessments, and evaluations appropriate for the\nfailure causes.\nvi. Describe the inspection and repair criteria Respondent will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded and a\nschedule for repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipeline, describe the\nmethods Respondent will use to repair, replace, or take other corrective measures\nto remediate the conditions associated with the Accident and to address other\nknown integrity threats along the Affected Pipeline. The repair, replacement, or\nother corrective measures must meet the criteria specified in (e)(vi) above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipeline\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Order.\nInclude a proposed schedule for completion of the RWP.\nRespondent must revise the RWP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of\nactions undertaken pursuant to this Order, and to incorporate modifications required by\n\n\n\n8. 9. the Director.\nh. Submit any plan revisions to the Director for prior approval.\ni. ii. The Director may approve plan revisions incrementally.\nAll revisions to the RWP after it has been approved and incorporated by reference\ninto this Order will be fully described and documented in the CAO\nDocumentation Report.\ni. Implement the RWP as it is approved by the Director, including any revisions to the\nplan.\nRestart Plan. Prior to resuming operation of the Isolated Segment, develop and submit a\nwritten Restart Plan to the Director for prior approval.\na. b. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Isolated Segment cannot resume operation until the Restart Plan is\napproved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment during\nthe restart process and must include incremental pressure increases during start up,\nwith each increment to be held for at least two hours.\nd. The Restart Plan must include sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\ne. The Restart Plan must specify a daylight restart and include advance communications\nwith local emergency response officials.\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those of the Accident including a review of construction, operating and\nmaintenance (O&M) and integrity management records such as ILI results,\nhydrostatic tests, root cause failure analysis of prior failures, aerial and ground\npatrols, corrosion, cathodic protection, excavations, and pipe replacements.\nRespondent must address any findings that require remedial measures to be\nimplemented prior to restart.\ng. The Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications\nare incorporated into Respondent’s O&M procedures manual.\nh. The Restart Plan must provide for hydrostatic pressure testing of the Isolated\nSegment.\nReturn to Service. After the Director approves the Restart Plan, Respondent may return\nthe Isolated Segment to service in accordance with the approved Restart Plan, but the\noperating pressure must not exceed the pressure restrictions in accordance with Item 10.\n\n\n\n10. Operating Pressure Restriction. In accordance with the terms of this Order, Respondent\nmust reduce and maintain no less than a twenty percent (20%) pressure reduction in the\nactual operating pressure along the entire length of the Isolated Segment such that the\noperating pressure along the Isolated Segment will not exceed eighty percent (80%) of the\nactual operating pressure in effect immediately prior to the Accident.\ni. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is obtained from the\nDirector in accordance with the terms of this order.\nj. When determining the pressure restriction set-points, Respondent must take into\naccount any ILI features or anomalies present in the Isolated Segment to provide for\ncontinued safe operation while further corrective actions are completed.\nk. Respondent must review the pressure restriction monthly by analyzing the operating\npressure data, taking into account any ILI features or anomalies present in the Isolated\nSegment. Respondent must immediately reduce the operating pressure further to\nmaintain the safe operations of the Isolated Segment, if warranted by the monthly\nreview. Further, Respondent must submit the results of the monthly review to the\nDirector including, at a minimum, the current discharge set-points (including any\nadditional pressure reductions), and any pressure exceedance at discharge set-points.\nSubmittals must be made quarterly, in accordance with the terms of this Order.\n11. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from Respondent demonstrating that restoring the pipeline to its pre-\nfailure operating pressure is justified based on a reliable engineering analysis showing\nthat the pressure increase is safe considering all known defects, anomalies, and\noperating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Respondent demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on the failure cause and evidence that preventative and\nmitigative actions taken by the operator provide for the safe operation of the Isolated\nSegment during the temporary removal or modification of the pressure restriction.\nAppeals to determinations of the Director in this regard will be decided by the\nAssociate Administrator for Pipeline Safety.\n12. Emergency Response Plan and Training Review. Within 90 days following issuance of\nthis Order, Respondent must review and assess the effectiveness of its emergency response\nplan with regards to the failure. Respondent must include in the review and assessment the\non-scene response and support, coordination, and communication with emergency\nresponders and public officials. Also, Respondent must include a review and assessment of\nthe effectiveness of its emergency training program. Respondent must amend its\nemergency response plan and emergency training, if necessary, to reflect the results of this\nreview. Further, Respondent must review controller response to all alarms prior to, and\nfollowing, confirmation of the Accident. Respondent must also review the controllers’\n\n\n\ncoordination and communications prior to and throughout the Accident response. The\ndocumentation of this Emergency Response Plan and Training Review must be available\nfor inspection by OPS or provided to the Director, if requested.\n13. Leakage Survey. Respondent must perform an aerial and ground leakage survey of the\nAffected System. Respondent must investigate all leak indications from the survey and\nremedy all leaks discovered upon discovery. The Leakage Survey must be conducted as\nfollows:\na. Within 30 days of issuance of this Order, Respondent must perform a leakage\nsurvey of the Affected System.\nb. Within 24 hours of return to service per the terms of this Order, Respondent must\nperform a leakage survey of the Affected Pipeline.\nc. Respondent must submit documentation of this survey to the Director within 10\ndays of performance of the survey.\n14. CAO Documentation Report. Respondent must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Respondent has concluded all the items in this Order\nit will submit the final CDR in its entirety to the Director. This will allow the Director to\ncomplete a thorough review of all actions taken by Respondent with regards to this Order\nprior to approving the closure of this Order. The intent is for the CDR to summarize all\nactivities and documentation associated with this Order in one document.\na. b. The Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the Accident and the response activities;\nSummary of pipe data, material properties and all prior assessments of the\nAffected Pipeline;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis required\nby the Order;\nv. vi. vii. Summary of the Mechanical and Metallurgical Testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by Respondent to implement the RWP, the\nresults of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and whenever\nnecessary to incorporate new information obtained during the failure investigation\nand remedial activities;\n\n\n\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions Respondent will take on its entire\npipeline system as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\nOther Requirements:\n15. Approvals. With respect to each submission that under this Order requires the approval of\nthe Director, the Director may: (a) approve, in whole or part, the submission; (b) approve\nthe submission on specified conditions; (c) modify the submission to cure any deficiencies;\n(d) disapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director and resubmit it for approval.\n16. Extensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Order upon a written request timely submitted demonstrating good\ncause for an extension.\n17. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first quarterly report is due\non November 9, 2023. The Director may change the interval for the submission of these\nreports.\n18. Documentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action Order.\nInclude in each monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies, and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements, and other modifications; and (3)\nenvironmental remediation, if applicable.\nBe advised 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 for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust 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 information\nqualifies for confidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 5-2023-053-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\n\n\n\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nFederal or State law.\nRespondent may appeal in writing any decision of the Director to the Associate Administrator\nfor Pipeline Safety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nAugust 11, 2023\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":34575}