SANDOVA」 COUN丁Y ADM!N霊STRATIVE OFFICES

February 22, 2018

Dwight Pa請erson, Board Member

Las Placitas Associa血on

BOARD OF COUNTY COMMISSIONERS

DAVID J. HEIL

District 4, Chai「man

F. KENNETH EICHWALDDistrict 5, Vice Chairman

Dr. JF HOLDEN-RHODES

Dist「ict l

JAY C. BLOCK

Dist「ict 2

DON G. CHAPMAN

Dis(「i億3

DIANNE MAES

County Manage「

Dear. Mr. Patterson,

Thank you for your letter regarding血e Placitas Pipelines on February l, 2018. The Sandoval

County Commission is dedicated to addressing the issues regarding the pipelines that you have

identi宜ed.

Concem #1-

After all too many years, We CamOt get a Straight answer as to what agency has the charter for

pipeline safety in Placitas. Is it the U.S. Department ofTransportation or is it the Bureau ofLand

Management?

The Now Mexico PubIic Regulation Commission PipeIine Safety Bureau:

e Is ch紺ged wit掴he task oferfercing Federal and S紙e Pipeline Safety RegulatiofiS ifi

order to provide for the safe operation ofnatural gas and hazardous liquid facilities;

● Is responsible for investigating intrastate pipeline incidents and accidents wi址n New

Mexico;

・ Enforces the State Excavation Damage Prevention Law; and

● Is responsible for licensing crude oil∴natural gas, and oil and gas product pipe血es.

T血ough its 60 1 05 Agreement with the U.S. Department of Transportation the Pipeline Safety

Bureau is responsible for conducting safety compliance inspections and enforcing state and

federal pipeline safety regulations for intrastate gas亘azardous liquid事and CO2 pipeline

facilities. These include private and municipal gas distribution systems, master meter gaS

systems, LPG systems, tranSmission systems and jurisdictional gathering lines. The U.S.

Department of Transportation Pipeline and Hazardous Safety Administration (PHMSA) conducts

an肌al program evaluations used primarily to detemine perfomance (e・g., OPerating practices,

quality of State agency inspections, investigations, COmPliance actions and adequacy of

1500 1DALIA RD. BUILDING D. P.O. BOX40. BERNAL肥LO, NEW MEXICO 87004. (505) 867-7500. FAX867-7600. wvw.sandoval∞untynm.gOV

recordkeeping). The Pipeline Safety Bureau perfomance is血e m勾or factor considered in

allocation grant-in-aid funds宜om the Federal Goverrme血each yean

Concem#2-

How did the Bureau of Land Management at the Famington O触ce obtain the authority to be the

only enforcer of也e USDOT-PHMSA Regulations. for Inter-State pipelines mming through

Plactias?

We will be sending a letter to that血e Bureau of Land Management Famington O能ce asking for

this information.

Concem#3-

The 201 1 ESCAFA Engineering report indicates 1 6 saftrty violations in血e pipelines thatrmthrou如

Las Huertas Creek. Today, 7 years later, a心solutely no血ing has been done to address those

Violatioas. Who is respensible to address也ose violatiofiS?

Can you provide血e Sandoval County Commission with a copy of血e violation report? We wi11

be able to identify the appropriate enforcement agency based on the type of safety violations.

Concem#4-

Did the Enterprise’s MAPCO integrity Management Plan Mr. Montoya, NMPRC言ust audited,

take into consideration the 1 6 engineering safety recommendations of201 1?

We will be sending a letter to Entexprise asking them for the status ofthe 1 6 safety violationsfrom 201 1 and ifthey are contained in the MAPCO Integrity Manageme血Plan.

Concem #5-

BLM recently granted higher pressure limits on one ofthe Enterprise NGL-60years old-Pipelines

in Las Huertas Creek. Who au血orized BLMto do this?

We will be sending a le請er to Enterprise to obtain infomation about the history ofthe

虹gher pressure limits.

Concem #6

We do not know if any of the t血ee highly flanmal’le Ente]Prise pipelines in Las Huertas

Creek have automated valves or electronic leak detection. Can Enterprise Partners be required

to address this issue?

We will be sending a letter to Enteaprise asking them whether they have automated valves ofleak detection present on their pipelines in Placitas.

Concem #7-