# ORYX DELAWARE OIL TRANSPORT LLC — Corrective Action Order

- **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:** Not available
- **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.

Official case documents:

52023053CAO_Closure Letter_05212026_(23-283484).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Closure%20Letter_05212026_(23-283484).pdf

52023053CAO_Closure Letter_05212026_(23-283484)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Closure%20Letter_05212026_(23-283484)_text.pdf

52023053CAO_Corrective Action Order_08112023_(23-283484).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023053CAO/52023053CAO_Corrective%20Action%20Order_08112023_(23-283484).pdf

52023053CAO_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

52023053CAO_Closure Letter_05212026_(23-283484)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety Administration
12300 West Dakota Avenue, Suite 340
Lakewood, Colorado 80228
VIA ELECTRONIC MAIL TO: patrick.hodgins@plains.com
May 21, 2026
Patrick Hodgins
Vice President, Health, Safety, Environmental
Oryx Delaware Oil Transport LLC.
333 Clay Street, Suite 1900
Houston, TX 77002
CPF 5-2023-053-CAO
Closure Letter
Dear Mr. Hodgins,
On August 11, 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Oryx Delaware Oil Transport (ODOT), a subsidiary of the Plains Oryx Permian Basin
LLC a Corrective Action Order in the above-referenced case. This Order included a requirement
to take corrective actions on your pipeline. Based on our review of the documentation you
provided it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration



cc: PHP-60 Compliance Registry
PHP-500 J. Long (23-283484)
cc: Kevin Cunningham, HSE Regulatory Compliance, Kevin.Cunningham@plains.com

52023053CAO_Corrective Action Order_08112023_(23-283484)_text.pdf

August 11, 2023
VIA ELECTRONIC MAIL TO: patrick.hodgins@plains.com
Patrick Hodgins
Vice President, Heath, Safety, Environmental
Oryx Delaware Oil Transport LLC
333 Clay Street, Suite 1900
Houston, Texas 77002
CPF No. 5-2023-053-CAO
Dear Mr. Hodgins:
Enclosed please find a Corrective Action Order issued by the Pipeline and Hazardous Materials
Safety Administration, Office of Pipeline Safety, in the above-referenced case. It requires Oryx
Delaware Oil Transport LLC (Oryx or Respondent) to take certain corrective actions with
respect to the August 6, 2023, failure of its Southeast 12-inch Mainline pipeline located in
Reeves County, approximately 14 miles south of Grandfalls, Texas.
Service of this Order by electronic mail is deemed complete upon transmission and
acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and
conditions of this Order are effective upon completion of service.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: CAO
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Dustin Hubbard, Director, Western Region, OPS
Mr. Ngiabi Gicuhi, Managing Director, HSE Compliance, Oryx Delaware Oil Transport
LLC, ngiabi.gicuhi@plains.com
Ms. Sherri Adkins, Senior Manager, HSE, Integrity and Records, Oryx Delaware Oil
Transport, LLC, sherri.adkins@plains.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Oryx Delaware Oil Transport, LLC, )
a subsidiary Oryx Midstream, LLC, ) CPF No. 5-2023-053-CAO
)
)
)
Respondent. )
____________________________________)
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority
of 49 U.S.C. § 60112 and 49 CFR § 190.233 to require Oryx Delaware Oil Transport LLC1
(Oryx or Respondent) to take the necessary corrective actions to protect the public, property, and
the environment from potential hazards associated with the August 6, 2023 failure of the
Southeast 12-inch Mainline hazardous liquid pipeline in the South Gathering System located
approximately 14 miles south of Grandfalls, Texas (Accident).
On August 6, 2023, at approximately 11:40 am Central Daylight Time (CDT), Oryx’s control
room received a pipeline monitoring (PLM) alert indicating a product shortage prompting
Respondent to conduct a shut-in test. Oryx confirmed a failure in the pipeline at 9:06 pm CDT
after visual confirmation of spilled hazardous liquid above the buried pipeline. Initial estimates
indicated that the failed pipeline released 470 barrels (bbls) of crude oil.
Oryx has reported that the pipeline was initially shutdown after the discovery of the Accident,
but returned to service the evening of August 7, 2023, after a PLIDCO clamp was installed. The
exact cause of the failure remains unknown.
Pursuant to 49 U.S.C. § 60117, PHMSA initiated an investigation of the Accident. The
preliminary findings of the Agency’s ongoing investigation are as follows:
Preliminary Findings
• At approximately 11:40 am CDT, Oryx control room received a PLM alert indicating
a shortage in the Southeast 12-inch Mainline pipeline. The controller contacted
1 This pipeline system is part of a joint venture between Oryx Midstream, LLC and Plains All American Pipeline,
LP.



management and Respondent decided to conduct a shut-in test to confirm whether
there was a failure in the pipeline section. The pressure test was conducted at
approximately 5:35 pm CDT. During that test, there was a noticeable drop in
pressure, prompting a shutdown of the pipeline, and dispatch of aerial and ground
patrols, commencing at approximately 8:00 pm CDT on August 6, 2023.
• At 9:06 pm CDT on August 6, 2023, Oryx technicians observed, and aerial patrols
showed a 225-foot by 35-foot area over the pipeline, with a crude oil depth of 4 to 5
inches, confirming a failure.
• At 11:02 pm CDT on August 6, 2023, Oryx reported the Accident to the National
Response Center (NRC) indicating there was a release of crude oil in a non-populated
area of southwest Texas, and that it was unknown whether the Accident occurred in a
high consequence area (NRC Report No. 1375405). The Respondent reported that
there were no fire, injuries, or evacuations, and that an estimated 470 bbls of crude oil
was spilled.
• At 5:45 pm CDT on August 8, 2023, Oryx submitted a 48-hour update to the NRC
(NRC Report No. 1375610) reducing the estimated amount of crude oil released to
200 bbls.
• After identification of the Accident, Oryx isolated the pipeline section by closing the
upstream and downstream mainline block valves and vacuum trucks were dispatched
to the site. A PLIDCO clamp was installed at approximately 8:45 am on August 7,
2023.
• Maximum operating pressure (MOP) of the Southeast 12-inch Mainline pipeline is
740 psig.
• At the time of Accident, the operating pressure was approximately 240-250 psig.
• At 6:29 pm CDT on August 7, 2023, Oryx returned the Southeast 12-inch Mainline
pipeline to service.
• At 3:00 pm CDT on August 9, 2023, Oryx shut down the Southeast 12-inch Mainline
pipeline.
• The Oryx’s Southeast 12-inch Mainline pipeline is part of its South Gathering
System, a 415.07-mile system of hazardous liquid transmission and gathering lines
that runs crude oil from gathering locations in Pecos, Texas, traveling north to
tankage in Midland, Texas.
• The Southeast 12-inch Mainline pipeline spans 25.98 miles and is located in Pecos,
Texas and Reeves County, Texas.



• The Southeast 12-inch Mainline pipeline was installed in 2017 and constructed of
API 5L X-52 carbon steel, has a nominal diameter of 12-inches with a wall thickness
of 0.25 inches, with a high-frequency electric resistance weld (HF-ERW) longitudinal
seam weld, and a coating of thin-film fusion-bonded epoxy.
• The South Gathering System is a pipeline facility subject to the Pipeline Safety Laws
in 49 U.S.C. chapter 601 and 49 C.F.R. part 195.
• Oryx reported to PHMSA that it uses impressed current for cathodic protection on
the Southeast 12-inch Mainline pipeline.
• A foreign pipeline crosses the failed pipeline near the site of the Accident. According
to Respondent, no bond exists between the pipelines.
• The Southeast 12-inch Mainline pipeline is in a rural area. The failed pipeline is not
near any known water sources and is not in a high consequence area.
• A prior accident on the South Gathering System also involving piping constructed of
API 5L X-52 steel pipe with a 12-inch nominal diameter, wall thickness of 0.25
inches, coating of fusion-bonded epoxy, and a HF-ERW longitudinal seam weld
occurred on May 17, 20222
, causing a release of 1,428 bbls of crude oil. That
accident was discovered when a contractor conducting aerial patrols identified the
release on the right-of-way in Reeves County, Texas.
• The last in-line-inspection (ILI) of the Southeast 12-inch Mainline Pipeline was
completed in May 2023. To date, no integrity digs have been completed.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material is transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
2 See NRC Report Nos. 1336752 and 1336963



facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in
which the pipeline facility is located; (6) any recommendation of the National Transportation
Safety Board made under another law; and (7) any other factors PHMSA may consider as
appropriate.
After evaluating the foregoing preliminary findings of fact, and having considered the
characteristics of the pipe and other equipment used in the pipeline facility, including the age3
and physical properties (resistance to corrosion and deterioration), the hazardous nature of the
material the pipeline transports, including the corrosive and deteriorative qualities of the
material, aspects of the area in which the pipeline is located, including the crossing of foreign
lines, the accident history of the Affected System, as defined below, the operating pressure
required for transporting the material, the uncertainty of the root cause(s) of the Accident, and
the possibility that the same condition(s) that may have caused the Accident remain present in
the Affected System, PHMSA finds that continued operation of the Affected System, without
corrective measures is or would be hazardous to life, property, or the environment, and that
failure to issue this Order expeditiously would result in the likelihood of serious harm.
Accordingly, this Order mandating immediate corrective action is issued expeditiously without
prior notice and opportunity for a hearing. The terms and conditions of this Order are effective
upon issuance.
Within 10 days of issuance of this Order, Respondent may request a hearing, to be held as soon
as practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a
copy to the Director, Western Region, PHMSA. If a hearing is requested, it will be held in
accordance with 49 C.F.R. § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, PHMSA will consider amending this Order. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions
Definitions:
Affected System – The “Affected System” means the entire South Gathering System.4
3 The Southeast 12-inch Mainline Pipeline was installed in 2017.
4 PHMSA has requested more detailed information regarding the start and end points of the South Gathering
System. Respondent’s response is pending as of the issuance of this Order.



Isolated Segment – The "Isolated Segment" means the section of the Southeast 12-inch
Mainline pipeline that failed, starting Valve SEMBV-4 (tag number V-BV4A), and ending at
Valve SEMBV-2 (tag number MOV 501).
Affected Pipeline – The “Affected Pipeline” means the entire Southeast 12-inch Mainline
pipeline,, which starts at Valve SEMBV-4 west of Highway 18 and ends at Reeves Station.
Director – The Director, Western Region, PHMSA, OPS.
Pursuant to 49 U.S.C. 60112, I hereby order Respondent to immediately take the following
corrective actions:
1. 2. 3. 4. 5. Shutdown of the Isolated Segment. Respondent must shutdown the Isolated Segment
immediately upon issuance of this Order. The Isolated Segment must remain shut-in and
may not be operated until authorized to be restarted by the Director in accordance with the
terms of this Order.
Records Verification. Respondent must verify the records for the Isolated Segment that
were used to establish the MOP. Respondent must submit documentation of this record
verification to the Director within 45 days of issuance of this Order.
Review of Prior Inline Inspection Results. Within 90 days of issuance of this Order,
Respondent must conduct a review of any previous inline inspection (ILI) results of the
Affected Pipeline. In its review, Respondent must re-evaluate all ILI results since 2017,
including a review of the ILI vendors' raw data and analysis. Respondent must determine
whether any features were present near the Accident site. Respondent must also determine
if any features with similar characteristics are present elsewhere on the Affected Pipeline.
Respondent must submit documentation of this ILI review to the Director within 90 days of
issuance of this Order as follows:
a. b. c. d. List all ILI tool runs, tool types, and the calendar years of the tool runs.
List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features present in the failed joint and other pipe removed.
List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features with similar characteristics present elsewhere on the Affected Pipeline.
Explain the process used to review the ILI results and the results of the reevaluation.
In-Line Assessment. Within 180 days of issuance of this Order, subject to the approval of
the Director of its Restart Plan, Oryx must conduct an ILI of the Affected Pipeline using a
geometry tool, a high-resolution axial magnetic flux leakage (MFL) tool and a transverse
MFL tool and must follow all the applicable requirements set forth in 49 CFR § 195.452.
Mechanical and Metallurgical Testing. Within 45 days of issuance of this Order,
Respondent must complete mechanical and metallurgical testing and failure analysis of the
failed pipe, an analysis of representative soil samples from the Accident location and
product transported in pipe at the time of failure, and any foreign materials. The testing



must be conducted by an independent third-party acceptable to the Director. Respondent
must complete the testing and analysis as follows:
a. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the Accident site.
6. b. Within 10 days of issuance of this Order, develop and submit the testing protocol and
the proposed testing laboratory to the Director for prior approval.
c. Prior to beginning the mechanical and metallurgical testing, provide the Director with
the scheduled date, time, and location of the testing to allow for an OPS
representative to witness the testing.
d. Ensure the testing laboratory distributes all reports whether draft or final in their
entirety to the Director at the same time they are made available to Respondent.
Root Cause Failure Analysis. Within 90 days following issuance of this Order, complete a
root cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.
The RCFA must be supplemented or facilitated by an independent third-party acceptable to
the Director and must document the decision-making process and all factors contributing to
the Accident, including potentially corrosive properties of the product or environment. The
final report must include findings and any lessons learned and whether the findings and
lessons learned are applicable to other locations within Respondent’s pipeline system.
7. Remedial Work Plan.
a. b. c. Within 90 days following issuance of this Order, Respondent must submit a remedial
work plan (RWP) to the Director for approval.
The Director may approve the RWP incrementally without approving the entire RWP.
Once approved by the Director, the RWP will be incorporated by reference into this
Order.
d. e. The RWP must specify the tests, inspections, assessments, evaluations, and remedial
measures Respondent will use to verify the integrity of the Affected Pipeline. It must
address all known or suspected factors and causes of the Accident. Respondent must
consider the risks and consequences of another failure to develop a prioritized
schedule for RWP-related work along the Affected Pipeline.
The RWP must include a procedure or process to:
i. Identify pipe in the Affected Pipeline with characteristics similar to the
contributing factors identified for the Accident.
ii. Gather all data necessary to review the failure history (in service and pressure test
failures) of the Affected Pipeline and to prepare a written report containing all the
available information such as the locations, dates, and causes of leaks and
failures.
iii. Integrate the results of the metallurgical testing, root cause failure analysis, and
other corrective actions required by this Order with all relevant pre-existing
operational and assessment data for the Affected Pipeline. Pre-existing
operational data includes, but is not limited to, design, construction, operations,



f. g. iv. v. maintenance, testing, repairs, prior metallurgical analyses, and any third-party
consultation information. Pre-existing assessment data includes, but is not limited
to, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval
surveys, and DCVG/ACVG surveys.
Determine if conditions similar to those contributing to the Accident are likely to
exist elsewhere on the Affected System.
Conduct additional field tests, inspections, assessments, and evaluations to
determine whether, and to what extent, the conditions associated with the
Accident and other failures from the failure history (see (e)(ii) above) or any other
integrity threats are present elsewhere on the Affected System. At a minimum, this
process must consider all failure causes and specify the use of one or more of the
following:
1) ILI tools that are technically appropriate for assessing the pipeline system
based on the cause of Accident and that can reliably detect and identify
anomalies;
2) Hydrostatic pressure testing;
3) Close-interval surveys;
4) Cathodic protection surveys, to include interference surveys in coordination
with other utilities/pipelines in the area;
5) Coating surveys;
6) Stress corrosion cracking surveys;
7) Selective seam corrosion surveys; and
8) Other tests, inspections, assessments, and evaluations appropriate for the
failure causes.
vi. Describe the inspection and repair criteria Respondent will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other identified
integrity threats. Include a description of how any defects will be graded and a
schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Pipeline, describe the
methods Respondent will use to repair, replace, or take other corrective measures
to remediate the conditions associated with the Accident and to address other
known integrity threats along the Affected Pipeline. The repair, replacement, or
other corrective measures must meet the criteria specified in (e)(vi) above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Pipeline
considering the results of the analyses, inspections, evaluations, and corrective
measures undertaken pursuant to the Order.
Include a proposed schedule for completion of the RWP.
Respondent must revise the RWP as necessary to incorporate new information obtained
during the failure investigation and remedial activities, to incorporate the results of
actions undertaken pursuant to this Order, and to incorporate modifications required by



8. 9. the Director.
h. Submit any plan revisions to the Director for prior approval.
i. ii. The Director may approve plan revisions incrementally.
All revisions to the RWP after it has been approved and incorporated by reference
into this Order will be fully described and documented in the CAO
Documentation Report.
i. Implement the RWP as it is approved by the Director, including any revisions to the
plan.
Restart Plan. Prior to resuming operation of the Isolated Segment, develop and submit a
written Restart Plan to the Director for prior approval.
a. b. The Director may approve the Restart Plan incrementally without approving the
entire plan, but the Isolated Segment cannot resume operation until the Restart Plan is
approved in its entirety.
Once approved by the Director, the Restart Plan will be incorporated by reference
into this Order.
c. The Restart Plan must provide for adequate patrolling of the Isolated Segment during
the restart process and must include incremental pressure increases during start up,
with each increment to be held for at least two hours.
d. The Restart Plan must include sufficient surveillance of the pipeline during each
pressure increment to ensure that no leaks are present when operation of the line
resumes.
e. The Restart Plan must specify a daylight restart and include advance communications
with local emergency response officials.
f. The Restart Plan must provide for a review of the Isolated Segment for conditions
similar to those of the Accident including a review of construction, operating and
maintenance (O&M) and integrity management records such as ILI results,
hydrostatic tests, root cause failure analysis of prior failures, aerial and ground
patrols, corrosion, cathodic protection, excavations, and pipe replacements.
Respondent must address any findings that require remedial measures to be
implemented prior to restart.
g. The Restart Plan must also include documentation of the completion of all mandated
actions, and a management of change plan to ensure that all procedural modifications
are incorporated into Respondent’s O&M procedures manual.
h. The Restart Plan must provide for hydrostatic pressure testing of the Isolated
Segment.
Return to Service. After the Director approves the Restart Plan, Respondent may return
the Isolated Segment to service in accordance with the approved Restart Plan, but the
operating pressure must not exceed the pressure restrictions in accordance with Item 10.



10. Operating Pressure Restriction. In accordance with the terms of this Order, Respondent
must reduce and maintain no less than a twenty percent (20%) pressure reduction in the
actual operating pressure along the entire length of the Isolated Segment such that the
operating pressure along the Isolated Segment will not exceed eighty percent (80%) of the
actual operating pressure in effect immediately prior to the Accident.
i. This pressure restriction is to remain in effect until written approval to increase the
pressure or return the pipeline to its pre-failure operating pressure is obtained from the
Director in accordance with the terms of this order.
j. When determining the pressure restriction set-points, Respondent must take into
account any ILI features or anomalies present in the Isolated Segment to provide for
continued safe operation while further corrective actions are completed.
k. Respondent must review the pressure restriction monthly by analyzing the operating
pressure data, taking into account any ILI features or anomalies present in the Isolated
Segment. Respondent must immediately reduce the operating pressure further to
maintain the safe operations of the Isolated Segment, if warranted by the monthly
review. Further, Respondent must submit the results of the monthly review to the
Director including, at a minimum, the current discharge set-points (including any
additional pressure reductions), and any pressure exceedance at discharge set-points.
Submittals must be made quarterly, in accordance with the terms of this Order.
11. Removal of Pressure Restriction.
a. The Director may allow the removal or modification of the pressure restriction upon a
written request from Respondent demonstrating that restoring the pipeline to its pre-
failure operating pressure is justified based on a reliable engineering analysis showing
that the pressure increase is safe considering all known defects, anomalies, and
operating parameters of the pipeline.
b. The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from Respondent demonstrating that temporary
mitigative and preventive measures are implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director's
determination will be based on the failure cause and evidence that preventative and
mitigative actions taken by the operator provide for the safe operation of the Isolated
Segment during the temporary removal or modification of the pressure restriction.
Appeals to determinations of the Director in this regard will be decided by the
Associate Administrator for Pipeline Safety.
12. Emergency Response Plan and Training Review. Within 90 days following issuance of
this Order, Respondent must review and assess the effectiveness of its emergency response
plan with regards to the failure. Respondent must include in the review and assessment the
on-scene response and support, coordination, and communication with emergency
responders and public officials. Also, Respondent must include a review and assessment of
the effectiveness of its emergency training program. Respondent must amend its
emergency response plan and emergency training, if necessary, to reflect the results of this
review. Further, Respondent must review controller response to all alarms prior to, and
following, confirmation of the Accident. Respondent must also review the controllers’



coordination and communications prior to and throughout the Accident response. The
documentation of this Emergency Response Plan and Training Review must be available
for inspection by OPS or provided to the Director, if requested.
13. Leakage Survey. Respondent must perform an aerial and ground leakage survey of the
Affected System. Respondent must investigate all leak indications from the survey and
remedy all leaks discovered upon discovery. The Leakage Survey must be conducted as
follows:
a. Within 30 days of issuance of this Order, Respondent must perform a leakage
survey of the Affected System.
b. Within 24 hours of return to service per the terms of this Order, Respondent must
perform a leakage survey of the Affected Pipeline.
c. Respondent must submit documentation of this survey to the Director within 10
days of performance of the survey.
14. CAO Documentation Report. Respondent must create and revise, as necessary, a CAO
Documentation Report (CDR). When Respondent has concluded all the items in this Order
it will submit the final CDR in its entirety to the Director. This will allow the Director to
complete a thorough review of all actions taken by Respondent with regards to this Order
prior to approving the closure of this Order. The intent is for the CDR to summarize all
activities and documentation associated with this Order in one document.
a. b. The Director may approve the CDR incrementally without approving the entire CDR.
Once approved by the Director, the CDR will be incorporated by reference into this
Order.
c. The CDR must include, but is not necessarily limited to, the following:
i. Table of Contents;
ii. iii. Summary of the Accident and the response activities;
Summary of pipe data, material properties and all prior assessments of the
Affected Pipeline;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis required
by the Order;
v. vi. vii. Summary of the Mechanical and Metallurgical Testing as required by the Order;
Summary of the RCFA with all root causes as required by the Order;
Documentation of all actions taken by Respondent to implement the RWP, the
results of those actions, and the inspection and repair criteria used;
viii. Documentation of any revisions to the RWP including those necessary to
incorporate the results of actions undertaken pursuant to this Order and whenever
necessary to incorporate new information obtained during the failure investigation
and remedial activities;



ix. x. Lessons learned while completing this Order;
A path forward describing specific actions Respondent will take on its entire
pipeline system as a result of the lessons learned from work on this Order; and
xi. Appendices (if required).
Other Requirements:
15. Approvals. With respect to each submission that under this Order requires the approval of
the Director, the Director may: (a) approve, in whole or part, the submission; (b) approve
the submission on specified conditions; (c) modify the submission to cure any deficiencies;
(d) disapprove in whole or in part, the submission, directing that Respondent modify the
submission, or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission as approved or modified by the Director. If the Director
disapproves all or any portion of the submission, Respondent must correct all deficiencies
within the time specified by the Director and resubmit it for approval.
16. Extensions of Time. The Director may grant an extension of time for compliance with any
of the terms of this Order upon a written request timely submitted demonstrating good
cause for an extension.
17. Reporting. Submit quarterly reports to the Director that: (1) include all available data and
results of the testing and evaluations required by this Order; and (2) describe the progress
of the repairs or other remedial actions being undertaken. The first quarterly report is due
on November 9, 2023. The Director may change the interval for the submission of these
reports.
18. Documentation of the Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Corrective Action Order.
Include in each monthly report submitted, the to-date total costs associated with: (1)
preparation and revision of procedures, studies, and analyses; (2) physical changes to
pipeline infrastructure, including repairs, replacements, and other modifications; and (3)
environmental remediation, if applicable.
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).
In your correspondence on this matter, please refer to “CPF No. 5-2023-053-CAO” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Order are in addition to and do not waive any requirements that apply to
Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order



issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of
Federal or State law.
Respondent may appeal in writing any decision of the Director to the Associate Administrator
for Pipeline Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.
§ 190.5.
August 11, 2023
_________________________________ ________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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