# ELLSJET TERMINAL — Notice of Probable Violation

**Citation:** CPF 320186004  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-05-15

CLOSED notice of probable violation citing 195.402(a), 195.404(b)(1), 195.404(c)(3), 195.420(b), 195.428(a), 195.452(b)(1), 195.49, 195.509(a), 195.509(b), 195.573(a)(1), 195.573(c), 195.573(d), 195.583(a), 195.64(a).

## Document text

Notice of Probable Violation involving ELLSJET TERMINAL. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.404(b)(1),  195.404(c)(3),  195.420(b),  195.428(a),  195.452(b)(1),  195.49,  195.509(a),  195.509(b),  195.573(a)(1),  195.573(c),  195.573(d),  195.583(a),  195.64(a). The case was opened on 2018-05-15 and is reported as closed as of 2019-09-10. Proposed civil penalty: $293,600. Assessed civil penalty: $293,600. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320186004_Closure Letter_09102019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_Closure%20Letter_09102019.pdf

320186004_Closure Letter_09102019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_Closure%20Letter_09102019_text.pdf

320186004_Final Order_10302018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_Final%20Order_10302018.pdf

320186004_Final Order_10302018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_Final%20Order_10302018_text.pdf

320186004_NOPV PCP PCO_05152018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_NOPV%20PCP%20PCO_05152018.pdf

320186004_NOPV PCP PCO_05152018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_NOPV%20PCP%20PCO_05152018_text.pdf

320186004_Operator Response to Notice_06152018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320186004/320186004_Operator%20Response%20to%20Notice_06152018.pdf

320186004_NOPV PCP PCO_05152018_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 15, 2018
Mr. Barry McFarland
Vice President, Environmental, Health, Safety, and Operational Risk
Par Pacific Holdings (dba Ellsjet Terminal)
800 Gessner Road, 8th Floor
Houston, TX 77024
CPF 3-2018-6004
Dear Mr. McFarland:
On November 9-10, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49
United States Code inspected your Ellsjet Terminal facilities and records in Rapid City, South
Dakota and Newcastle, Wyoming.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:



1. §195.49 Annual report.
Each operator must annually complete and submit DOT Form PHMSA F 7000-
1.1 for each type of hazardous liquid pipeline facility operated at the end of the
previous year. An operator must submit the annual report by June 15 each year,
except that for the 2010 reporting year the report must be submitted by August
15, 2011. A separate report is required for crude oil, HVL (including anhydrous
ammonia), petroleum products, carbon dioxide pipelines, and fuel grade ethanol
pipelines. For each state a pipeline traverses, an operator must separately
complete those sections on the form requiring information to be reported for each
state.
Ellsjet Terminal (ET) did not annually complete and submit DOT Form PHMSA F
7000-1.1 for each type of hazardous liquid pipeline facility operated at the end of the
previous year. On July 1, 2016, PHMSA received ET’s first annual report, although it
had been operating continuously for over 40 years. A review of operator records
determined that they did not complete and submit reports for 2013, 2014 and 2015.
2. §195.64 National Registry of Pipeline and LNG Operators.
(a) OPID Request. Effective January 1, 2012, each operator of a hazardous liquid
or carbon dioxide pipeline or pipeline facility must obtain from PHMSA an
Operator Identification Number (OPID). An OPID is assigned to an operator for
the pipeline or pipeline system for which the operator has primary responsibility.
To obtain an OPID or a change to an OPID, an operator must complete an OPID
Assignment Request DOT Form PHMSA F 1000.1 through the National Registry
of Pipeline and LNG Operators in accordance with §195.58.
ET did not obtain an Operator Identification Number (OPID) from PHMSA as
required by January 1, 2012. ET had been operating their pipeline for over 40 years
but did not obtain an OPID until November 2015 as shown on its OPID Assignment
Request. ET’s 2016 Annual Report lists the decade installed as 1950-1959.
2



3. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall
be reviewed at intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a pipeline
system commence, and appropriate parts shall be kept at locations where
operations and maintenance activities are conducted.
ET failed to prepare all written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies for its
system to meet the requirements of 49 C.F.R. Part 195 before initial operations of the
pipeline system commenced. During the inspection on November 9-10, 2015, ET
informed PHMSA staff that procedural manuals for operations, maintenance and
emergencies were not complete; therefore, no manuals were available for inspection.
ET has been continuously operating the pipeline for over 40 years and did not have a
procedural manual. ET had not identified itself as an operator until PHMSA became
aware of its operations in late 2015 and requested that it report itself as an operator.
ET’s failure to have procedural manuals is a violation of §192.402(a).
4. §195.404 Maps and Records.
(a)…
(b) Each operator shall maintain for at least 3 years daily operating records that
indicate-
(1) The discharge pressure at each pump station;
ET did not maintain daily discharge pressure records at its pump station for at least 3
years. ET stated during PHMSA’s inspection that these records began being kept in
October 2015. Therefore, ET had no historical operating pressure records prior to
October 1, 2015.
3



5. §195.404 Maps and Records.
(a)…
(c) Each operator shall maintain the following records for the periods specified;
(3) A record of each inspection and test required by this subpart shall be
maintained for at least 2 years or until the next inspection or test is
performed, whichever is longer.
§195.420 Valve maintenance.
(b) Each operator shall, at intervals not exceeding 7 1/2 months, but at least twice
each calendar year, inspect each mainline valve to determine that it is functioning
properly.
ET had no valve inspection records prior to October 2015 to demonstrate that
inspections had occurred twice each calendar year at intervals not exceeding 7 ½
months for the years 2013, 2014, and up to the inspection in 2015. The pipeline
system contains three mainline safety valves which had no inspection records prior to
October 2015.
6. §195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section, each operator shall, at
intervals not exceeding 15 months, but at least once each calendar year, or in the
case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½
months, but at least twice each calendar year, inspect and test each pressure
limiting device, relief valve, pressure regulator, or other item of pressure control
equipment to determine that it is functioning properly, is in good mechanical
condition, and is adequate from the standpoint of capacity and reliability of
operation for the service in which it is used.
ET did not inspect and test the overpressure safety device on its non-HVL pipeline at
intervals not to exceed 15 months, but at least once each calendar year. ET informed
PHMSA that inspecting and testing of its overpressure safety device began October
2015 but no record was kept. ET did not inspect its overpressure protection devices to
ensure that they were operational in 2013 or 2014. Therefore, no inspection was
performed on the safety devices for over 3 years prior to October 2015.
4



7. §195.452 Pipeline integrity management in high consequence areas.
(a)…
(b) What program and practices must operators use to manage pipeline
integrity? Each operator of a pipeline covered by this section must:
(1) Develop a written integrity management program that addresses the risks on
each segment of pipeline in the first column of the following table not later
than the date in the second column:
Pipeline Date
Category 1 March 31, 2002
Category 2 February 18, 2003.
Category 3 1 year after the date the pipeline begins operation.
ET did not have an integrity management (IM) program in high consequence areas,
even though it had been operating the pipeline continuously since February 18, 2003.
ET informed PHMSA that its pipeline meets the classification Category 2 on April 30,
2016; therefore, it was required to have an IM program by February 18, 2003.
8. §195.509 General.
(a) Operators must have a written qualification program by April 27, 2001. The
program must be available for review by the Administrator or by a state agency
participating under 49 U.S.C. Chapter 601 if the program is under the authority
of that state agency.
ET did not have a written operator qualification (OQ) program by April 27, 2001,
although it operated the pipeline continuously since that date. Its OQ program was
created after PHMSA’s inspection on November 9-10, 2015.
9. §195.509 General.
(a)…
(b) Operators must complete the qualification of individuals performing covered
tasks by October 28, 2002.
5



10. ET did not complete the qualification of individuals performing covered tasks by
October 28, 2002. ET had operated the pipeline continuously since that date, but had
not completed the qualifications of its individuals as of the November 9-10, 2015,
inspection.
Specifically, personnel were performing the following covered tasks for ET without
being qualified:
Covered tasks:
 Valve Maintenance
 Inspect Valves
 Repair Valves
 Inspect, Test and Calibrate Pressure Limiting Devices
 Shutdown of a Pipeline
 Monitor Pressures, Flows, Communications and Line Integrity, Maintain
within Allowable Limits
 Manually or Remotely Open or Close Valves or Other Equipment
 Start-up of a Pipeline
 Visually Inspect Surface Conditions of Right of Way
 Routine Inspection of Breakout Tanks
 API 653 Inspection of In-Service Breakout Tanks
 Locate Line
 Install, Inspect, and Maintain Permanent Marker
 Install, Inspect, and Maintain Temporary Marker
 Check for Proper Operation of a Rectifier
 Obtain a Voltage and Current Output Reading from a Rectifier
 Adjustment of Rectifiers
§195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine
whether cathodic protection required by this subpart complies with
Sec. 195.571:
(1) Conduct tests on the protected pipeline at least once each
calendar year, but with intervals not exceeding 15 months.
However, if tests at those intervals are impractical for separately
protected short sections of bare or ineffectively coated pipelines,
testing may be done at least once every 3 calendar years, but with
intervals not exceeding 39 months.
6



11. 12. ET did not conduct cathodic protection pipe-to-soil potential tests on the
pipeline at least once each calendar year, but with intervals not exceeding
15 months. Specifically, ET did not conduct tests in 2014 at 13 test
stations. The last tests were taken in 2013 prior to the cathodic protection
technician leaving.
§195.573 What must I do to monitor external corrosion control?
(a)…
(c) Rectifiers and other devices. You must electrically check for proper
performance each device in the first column at the frequency stated in the second
column.
Device Check frequency
Rectifier................................. At least six times each calendar year, but with
intervals not exceeding 2 1/2 months.
ET did not conduct electrical checks for proper performance on its one rectifiers at
least six times each calendar year but with intervals not exceeding 2-1/2 months in
2014 and 2015.
§195.573 What must I do to monitor external corrosion control?
(a)…
(d) Breakout tanks. You must inspect each cathodic protection system used to
control corrosion on the bottom of an aboveground breakout tank to ensure that
operation and maintenance of the system are in accordance with API RP 651
(incorporated by reference, see § 195.3). However, this inspection is not required
if you note in the corrosion control procedures established under §195.402(c)(3)
why complying with all or certain operation and maintenance provisions of API
RP 651 is not necessary for the safety of the tank.
API RP 651 reference:
11.3.1.2 Annual cathodic protection surveys are recommended to ensure the
effectiveness of cathodic protection. The electrical measurements used in the
survey may include one or more of the measurements listed in 11.3.1.1.
7



ET did not inspect its cathodic protection system on its three above ground breakout
tanks to ensure that its operation and maintenance was in accordance with API RP 651.
Annual cathodic protection surveys are required by PHMSA to ensure the
effectiveness of cathodic protection. ET did not conduct the annual surveys on its
breakout tank bottom as required.
13. §195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed to the
atmosphere for evidence of atmospheric corrosion, as follows:
If the pipeline is located: Then the frequency of inspection is:
Onshore At least once every 3 calendar years, but with
intervals not exceeding 39 months
ET did not inspect its pipeline that was exposed to the atmosphere for evidence of
atmospheric corrosion at least every 3 calendar years, but with intervals not exceeding
39 months. ET informed PHMSA that no atmospheric corrosions inspections had been
performed prior to May 2016.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022
for a related series of violations. For violations occurring prior to November 2, 2015, the
maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 for a related series of violations. The Compliance Officer has
reviewed the circumstances and supporting documentation involved in the above probable
violation(s) and has recommended that you be preliminarily assessed a civil penalty of
$293,600 as follows:
8



Item number
PENALTY
1
$ 19,100
$ 18,700
$ 36,000
$ 17,200
$ 13,900
$ 37,000
$ 36,000
$ 36,000
10
$ 21,300
11
$ 20,600
12
$ 19,100
13
$ 18,700
Warning Items
With respect to item 9 we have reviewed the circumstances and supporting documents
involved in this case and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to promptly correct these items). Failure
to do so may result in additional enforcement action.
Proposed Compliance Order
With respect to items 3, 7 and 12 pursuant to 49 United States Code § 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Ellsjet
Terminal. Please refer to the Proposed Compliance Order, which is enclosed and made a part
of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the response
options. All material you submit in response to this enforcement action may be 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). If you do not respond within 30 days of receipt
of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this
Notice without further notice to you and to issue a Final Order.
9



In your correspondence on this matter, please refer to CPF 3-2018-6004 and for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
10



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Ellsjet Terminal (ET) a Compliance Order
incorporating the following remedial requirements to ensure the compliance of ET with the
pipeline safety regulations:
1. 2. 3. In regard to Item Number 3 of the Notice pertaining to written procedural
manuals, ET must prepare a manual of written procedures for conducting
normal operations and maintenance activities and handling abnormal
operations and emergencies as required by 49 CFR Part 195. A schedule for
completion of this manual is to be submitted to the Director, Central Region
within 30 days of the final order. Completion of this manual shall not exceed 6
months from the issuance of the final order.
In regard to Item Number 7 of the Notice pertaining to an integrity
management program, ET must develop a written integrity in accordance with
49 CFR Part 195.452. management. A schedule for completion of this manual
is to be submitted to the Director, Central Region within 30 days of the final
order. Completion of this manual shall not exceed 6 months from the issuance
of the final order.
In regard to Item Number 12 of the Notice pertaining to monitoring external
corrosion control at its breakout tank, ET must monitor external corrosion
control at its breakout tank and remediate any deficiencies. Monitoring of its
breakout tanks must begin within 30 days of the final order. Records of the
initial monitor readings and any remediation must be submitted to the Director,
Central Region within 30 days of completion.
4. It is requested (not mandated) that ET maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit
the total to Allan Beshore, Director, Central Region, Pipeline and Hazardous
Materials Safety Administration. It is requested that these costs be reported in
two categories: 1) total cost associated with preparation/revision of plans,
procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
11

320186004_Closure Letter_09102019_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 10, 2019
Mr. William Pate
President and Chief Executive Officer
Par Pacific Holdings, Inc. (d.b.a. Ellsjet Terminal Operations)
825 Town and Country Lane
Suite 1500
Houston, TX 77024
Re: CPF 3-2018-6004
Dear Mr. Pate:
On November 9-10, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49
United States Code inspected your Ellsjet Terminal Operations (Ellsjet) facilities and records
in Rapid City, South Dakota and Newcastle, Wyoming. As a result of the inspection, the
Director, Central Region, OPS issued a Notice of Probable Violation, Proposed Civil Penalty
and Proposed Compliance Order (Notice) on May 15, 2018. On October 30, 2018, PHMSA
issued a Final Order, which made findings of violation, assessed a civil penalty, and ordered
Ellsjet to take certain compliance measures.
The record shows that Ellsjet paid the civil penalty, in addition to submitting items for the
Compliance Order. As your submission of these documents meets the terms of the
Compliance Order, this case is now closed. A review of the documents will be made during
PHMSA’s inspections and, if necessary, a separate case will be opened. Thank you for your
cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

320186004_Final Order_10302018_text.pdf

October 30, 2018
Mr. William Pate
President and Chief Executive Officer
Par Pacific Holdings, Inc. (d/b/a Ellsjet Terminal Operations)
One Memorial Plaza
800 Gessner Road, Suite 875
Houston, TX 77024
Re: CPF No. 3-2018-6004
Dear Mr. Pate:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and assesses a civil penalty of $293,600. This is to acknowledge receipt of payment of
the full penalty amount, by wire transfer, dated June 12, 2018. When the terms of the
compliance order have been completed, as determined by the Director, Central Region, this
enforcement action will be closed. Service of the Final Order by certified mail is effective upon
the date of mailing as provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Alan C. Beshore, Director, Central Region, Office of Pipeline Safety, PHMSA
Mr. Barry McFarland, Vice President – Environmental, Health, Safety, and Operational
Risk, Par Pacific Holdings, Inc. (d/b/a Ellsjet Terminal)
Mr. Mathew P. Ellman, Logistics Manager, Ellsjet Terminal Operations, 10 Stampede
St., Newcastle, WY, 82701
CERTIFIED MAIL - RETURN 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 )
Par Pacific Holdings, Inc., ) CPF No. 3-2018-6004
formerly Wyoming Refining Company, )
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From November 9 through November 10, 2015, pursuant to 49 U.S.C. § 60117, a representative
of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline
Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Par
Pacific Holdings, LLC, d/b/a Ellsjet Terminal Operations1 (ET, Par Pacific, or Respondent), in
Rapid City, South Dakota, and Newcastle, Wyoming. Par Pacific owns and operates a seven-
mile jet-fuel pipeline running from the Ellsjet tank farm in east Rapid City, South Dakota, to
Ellsworth Air Force Base, and three breakout tanks fed by a quarter-mile pipeline running from
the Magellan terminal.2
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated May 15, 2018, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R.
§ 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Par Pacific
had committed 13 violations of 49 C.F.R. Part 195 and proposed assessing a civil penalty of
$293,600 for the alleged violations. The Notice also proposed ordering Respondent to take
certain measures to correct the alleged violations. The warning item required no further action
but warned the operator to correct the probable violation or face possible future enforcement
action.
ET responded to the Notice by letter dated June 15, 2018 (Response). Respondent did not
contest the allegations of violation and paid the proposed civil penalty of $293,600. In
accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate
Administrator to make findings of violation and to issue this final order without further
1 Par Pacific Holdings, LLC, acquired Wyoming Refining Company, the operator of the Ellsjet Terminal, in July
2016. Pipeline Safety Violation Report (Violation Report), (January 18, 2018) (on file with PHMSA), at 1.
2 Violation Report, at 1.



CPF No. 3-2018-6004
Page 2
proceedings. For purposes of this Final Order, the terms “ET,” “Par Pacific” and "Respondent"
are used interchangeably.
FINDINGS OF VIOLATION
In its Response, Par Pacific did not contest the allegations in the Notice that it violated 49 C.F.R.
Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.49, which states:
§ 195.49 Annual report.
Each operator must annually complete and submit DOT Form PHMSA
F 7000-1.1 for each type of hazardous liquid pipeline facility operated at the
end of the previous year. An operator must submit the annual report by
June 15 each year, except that for the 2010 reporting year the report must
be submitted by August 15, 2011. A separate report is required for crude
oil, HVL (including anhydrous ammonia), petroleum products, carbon
dioxide pipelines, and fuel grade ethanol pipelines. For each state a pipeline
traverses, an operator must separately complete those sections on the form
requiring information to be reported for each state.
The Notice alleged that Respondent violated 49 C.F.R. § 195.49 by failing to annually complete
and submit DOT Form 7000-1.1 for each type of hazardous liquid pipeline facility operated at
the end of the previous year. Specifically, the Notice alleged that ET failed to complete and
submit annual reports for 2013-2015. PHMSA received ET’s first annual report on June 1, 2016,
despite the fact that ET had operated this pipeline continuously for over 40 years.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.49 by failing to annually
complete and submit DOT Form 7000-1.1 for the years 2013-2015.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.64(a), which states:
§ 195.64 National Registry of Pipeline and LNG Operators.
(a) OPID Request. Effective January 1, 2012, each operator of a
hazardous liquid or carbon dioxide pipeline or pipeline facility must obtain
from PHMSA an Operator Identification Number (OPID). An OPID is
assigned to an operator for the pipeline or pipeline system for which the
operator has primary responsibility. To obtain an OPID or a change to an
OPID, an operator must complete an OPID Assignment Request DOT Form
PHMSA F 1000.1 through the National Registry of Pipeline and LNG
Operators in accordance with § 195.58.
The Notice alleged that Respondent violated 49 C.F.R. § 195.64(a) by failing to obtain an OPID
from PHMSA as required by the regulation. Specifically, the Notice alleged that ET had been



CPF No. 3-2018-6004
Page 3
operating its pipeline for over 40 years but did not obtain an OPID until November 2015, as
shown on its OPID Assignment Request. According to the Notice, ET’s 2016 Annual Report
filed with PHMSA listed the decade of installation as 1950-1959.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.64(a) by failing to obtain an
OPID for its hazardous liquids pipeline.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 402(a), which states:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations
and maintenance activities and handling abnormal operations and
emergencies. This manual shall be reviewed at intervals not exceeding 15
months, but at least once each calendar year, and appropriate changes made
as necessary to insure that the manual is effective. This manual shall be
prepared before initial operations of a pipeline system commence, and
appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to prepare and
follow written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies for its system prior to the commencement of
initial operations. Specifically, the Notice alleged that ET staff informed the PHMSA inspector
that its procedural manuals were incomplete and therefore unavailable for inspection. It further
alleged that ET had not identified itself as a pipeline operator until PHMSA became aware of its
operations in late 2015 and requested the company to report itself as a pipeline operator.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) by failing to prepare all
written procedures required by the regulation before initial operations of the pipeline system
commenced.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.404(b)(1), which states, in
relevant part:
§ 195.404 Maps and records.
(a) …
(b) Each operator shall maintain for at least 3 years daily operating
records that indicate—
(1) The discharge pressure at each pump station; . . . .
The Notice alleged that Respondent violated 49 C.F.R. § 195.404(b)(1) by failing to maintain
daily discharge pressure records at its pump station for at least three years. Specifically, the



CPF No. 3-2018-6004
Page 4
Notice alleged that during the PHMSA inspection, ET stated that daily discharge pressure
records were not kept until October 2015.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.404(b)(1) for failing to maintain
for at least three years daily operating records that indicate discharge pressure at each pump
station.
Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.404(c)(3), which states:
§ 195.404 Maps and records.
(a) …
(c) Each operator shall maintain the following records for the periods
specified;
(1) …
(3) A record of each inspection and test required by this subpart shall
be maintained for at least 2 years or until the next inspection or test is
performed, whichever is longer.
The Notice alleged that Respondent violated 49 C.F.R. § 195.404(c)(3) by failing to maintain a
record of each inspection and test required by Subpart F of 49 C.F.R. Part 195 for at least two
years or until the next inspection or test is performed, whichever is longer. Specifically, the
Notice alleged that ET had no valve-inspection records prior to October 2015 to demonstrate that
it had performed mainline valve inspections twice each calendar year at intervals not exceeding
7½ months, pursuant to 49 C.F.R. § 195.420(b), for the years 2013, 2014, and up to the time of
the PHMSA inspection in 2015. According to the Notice, ET’s pipeline system has three
mainline safety valves that are required to be inspected pursuant to § 195.420, which is contained
in Subpart F.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.404(c)(3) by failing to maintain
valve-inspection records prior to October 2015 for the three mainline safety valves on its pipeline
system.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states:
§ 195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section,
each operator shall, at intervals not exceeding 15 months, but at least once
each calendar year, or in the case of pipelines used to carry highly volatile
liquids, at intervals not to exceed 7½ months, but at least twice each
calendar year, inspect and test each pressure limiting device, relief valve,
pressure regulator, or other item of pressure control equipment to determine
that it is functioning properly, is in good mechanical condition, and is
adequate from the standpoint of capacity and reliability of operation for the
service in which it is used.



CPF No. 3-2018-6004
Page 5
The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a) by failing to inspect and test
the overpressure safety devices on its non-highly-volatile-liquids (non-HVL) pipeline at intervals
not to exceed 15 months, but at least once each calendar year. Specifically, the Notice alleged
that ET did not inspect its overpressure protection devices to ensure that they were operational in
2013 or 2014.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.428(a) by failing to inspect and
test the overpressure safety devices on its non-HVL pipeline at intervals not to exceed 15
months, but at least once each calendar year.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(b)(1), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) …
(b) What programs and practices must operators use to manage
pipeline integrity? Each operator of a pipeline covered by this section must:
(1) Develop a written integrity management program that addresses the
risks on each segment of pipeline in the first column of the following table
not later than the date in the second column:
Pipeline Date
Category 1……………………… Category 2……………………… Category 3……………………… March 31, 2002.
February 18, 2003.
1 year after the date the pipeline
begins operation.
The Notice alleged that Respondent violated 49 C.F.R. § 195.452(b)(1) by failing to have an
integrity management (IM) program for its High Consequence Areas. Specifically, the Notice
alleged that ET informed PHMSA on April 30, 2016, that its pipeline had been in continuous
operation since 2003 and that it met the classification for Category 2 pipelines; therefore, it was
required to have an IM program by February 18, 2003.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(b)(1) by failing to develop a
written IM program for its Category 2 pipeline by February 18, 2003.
Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 195.509(a), which states:
§ 195.509 General.
(a) Operators must have a written qualification program by April 27,
2001. The program must be available for review by the Administrator or
by a state agency participating under 49 U.S.C. Chapter 601 if the program



CPF No. 3-2018-6004
Page 6
is under the authority of that state agency.
The Notice alleged that Respondent violated 49 C.F.R. § 195.509(a) by failing to have a written
operator qualification (OQ) program by April 27, 2001, despite operating continuously since that
date. Specifically, the Notice alleged that ET did not have an operator qualification program at
the time of the PHMSA inspection, and did not create one after November 10, 2015, when the
inspection was completed.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.509(a) by failing to have a
written operator qualification (OQ) program by April 27, 2001.
Item 10: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1), which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine
whether cathodic protection required by this subpart complies with
§ 195.571:
(1) Conduct tests on the protected pipeline at least once each calendar
year, but with intervals not exceeding 15 months. However, if tests at those
intervals are impractical for separately protected short sections of bare or
ineffectively coated pipelines, testing may be done at least once every 3
years, but with intervals not exceeding 39 months.
The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct
cathodic-protection pipe-to-soil tests on the pipeline at least once each calendar year, but with
intervals not exceeding 15 months. Specifically, the Notice alleged that ET did not conduct tests
in 2014 at 13 test stations.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing in 2014 to
conduct cathodic-protection pipe-to-soil tests at 13 test stations on the pipeline at least once each
calendar year, but with intervals not exceeding 15 months.
Item 11: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(c), which states, in
relevant part:
§ 195.573 What must I do to monitor external corrosion control?
(a) …
(c) Rectifiers and other devices. You must electrically check for proper
performance each device in the first column at the frequency stated in the
second column.



CPF No. 3-2018-6004
Page 7
Device Check Frequency
Rectifier …………………………… At least six times each calendar
year, but with intervals not
exceeding 2½ months.
The Notice alleged that Respondent violated 49 C.F.R. § 195.573(c) by failing to conduct
electrical checks on rectifiers for proper performance at the intervals required by the regulation.
Specifically, the Notice alleged that ET did not conduct the required checks in 2014 and 2015.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.573(c) by failing to conduct
electrical checks on rectifiers for proper performance at the intervals required by the regulation.
Item 12: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(d), which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) …
(d) Breakout tanks. You must inspect each cathodic protection system
used to control corrosion on the bottom of an aboveground breakout tank to
ensure that operation and maintenance of the system are in accordance with
API RP 651 (incorporated by reference, see § 195.3). However, this
inspection is not required if you note in the corrosion control protection
procedures established under § 195.402(c)(3) why complying with all or
certain operation and maintenance provisions of [American Petroleum
Institute Recommended Practice (API RP)] 651 is not necessary for the
safety of the tank.
The Notice alleged that Respondent violated 49 C.F.R. § 195.573(d) by failing to inspect its
cathodic-protection system on its three above-ground breakout tanks to ensure that its operation
and maintenance was in accordance with API RP 651. Specifically, the Notice alleged that ET
did not conduct the annual surveys on its breakout-tank bottoms, as required under API RP 651.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.573(d) by failing to inspect its
cathodic-protection system on its three above-ground breakout tanks to ensure that its operation
and maintenance was in accordance with API RP 651.
Item 13: The Notice alleged that Respondent violated 49 C.F.R. § 195.583(a), which states, in
relevant part:
§ 195.583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed
to the atmosphere for evidence of atmospheric corrosion, as follows:



CPF No. 3-2018-6004
Page 8
If the pipeline is located: Then the frequency of inspection
is:
Onshore …………………………… At least once every 3 calendar
years, but with intervals not
exceeding 39 months.
The Notice alleged that Respondent violated 49 C.F.R. § 195.583(a) by failing to inspect its
pipeline that was exposed to the atmosphere for evidence of atmospheric corrosion at least every
3 years, but with intervals not exceeding 39 months. Specifically, the Notice alleged that ET
informed PHMSA that no atmospheric corrosion inspections had been performed prior to May
2016.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.583(a) by failing to inspect its
pipeline that was exposed to the atmosphere for evidence of atmospheric corrosion at least every
3 years, but with intervals not exceeding 39 months.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.3
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; and any effect that the penalty may have on its ability to continue
doing business; and the good faith of Respondent in attempting to comply with the pipeline
safety regulations. In addition, I may consider the economic benefit gained from the violation
without any reduction because of subsequent damages, and such other matters as justice may
require. The Notice proposed a total civil penalty of $293,600 for the violations cited above.
It appears that Par Pacific acquired the pipeline facilities in question in July 2016, roughly eight
months after the November 2015 PHMSA inspection of the previous owner, Wyoming Refining
Company.4 The record is unclear why Wyoming Refining Company had failed to satisfy its
3 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum
Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).
4 E.g., Robert Brelsford, Par Pacific inks deal for Wyoming refinery, related assets, Oil & Gas Journal (June 15,
2016), available at https://www.ogj.com/articles/2016/06/par-pacific-inks-deal-for-wyoming-refinery-related-
assets.html (last visited September 26, 2018).



CPF No. 3-2018-6004
Page 9
basic legal obligation to file annual reports and comply with other important pipeline safety
regulations, but PHMSA holds operators fully responsible for compliance with these obligations.
Penalties for the violations cited above are set forth as follows:
Item 1: The Notice proposed a civil penalty of $19,100 for Respondent’s violation of 49 C.F.R.
§ 195.49, for failing to annually complete and submit DOT Form 7000-1.1 for the years 2013-
2015. ET neither contested the allegation nor presented any evidence or argument justifying a
reduction in or elimination of the proposed penalty. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Respondent a civil penalty of $19,100 for
violation of 49 C.F.R. § 195.49.
Item 2: The Notice proposed a civil penalty of $18,700 for Respondent’s violation of 49 C.F.R.
§ 195.64(a), for failing to obtain an OPID for its hazardous liquids pipeline. ET neither
contested the allegation nor presented any evidence or argument justifying a reduction
in or elimination of the proposed penalty. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Par Pacific a civil penalty of $18,700 for violation of
49 C.F.R. § 195.64(a).
Item 3: The Notice proposed a civil penalty of $36,000 for Respondent’s violation of 49 C.F.R.
§ 195.402(a), for failing to prepare and follow written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies for its
system prior to the commencement of initial operations. ET neither contested the allegation nor
presented any evidence or argument justifying a reduction in or elimination of the proposed
penalty. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Par Pacific a civil penalty of $36,000 for violation of 49 C.F.R. § 195.402(a).
Item 4: The Notice proposed a civil penalty of $17,200 for Respondent’s violation of 49 C.F.R.
§ 195.404(b)(1), for failing to maintain daily discharge pressure records at its pump station for at
least three years. ET neither contested the allegation nor presented any evidence or argument
justifying a reduction in or elimination of the proposed penalty. Accordingly, having reviewed
the record and considered the assessment criteria, I assess Par Pacific a civil penalty of $17,200
for violation of 49 C.F.R. § 195.404(b)(1).
Item 5: The Notice proposed a civil penalty of $13,900 for Respondent’s violation of 49 C.F.R.
§ 195.404(c)(3), for failing to maintain valve-inspection records to demonstrate that it had
performed valve inspections twice each calendar year, at intervals not exceeding 7½ months for
the years 2013, 2014, and up to the date of the PHMSA inspection in 2015. ET neither contested
the allegation nor presented any evidence or argument justifying a reduction in or elimination of
the proposed penalty. Accordingly, having reviewed the record and considered the assessment
criteria, I assess Par Pacific a civil penalty of $13,900 for violation of 49 C.F.R. § 195.404(c)(3).
Item 6: The Notice proposed a civil penalty of $37,000 for Respondent’s violation of 49 C.F.R.
§ 195.428(a), for failing to inspect and test the overpressure safety devices on its non-HVL
pipeline at intervals not to exceed 15 months, but at least once each calendar year. ET neither
contested the allegation nor presented any evidence or argument justifying a reduction in or



CPF No. 3-2018-6004
Page 10
elimination of the proposed penalty. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Par Pacific a civil penalty of $37,000 for violation of 49 C.F.R.
§ 195.428(a).
Item 7: The Notice proposed a civil penalty of $36,000 for Respondent’s violation of 49 C.F.R.
§ 195.452(b)(1), for failing to have an IM program in High Consequence Areas. ET neither
contested the allegation nor presented any evidence or argument justifying a reduction in or
elimination of the proposed penalty. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Par Pacific a civil penalty of $36,000 for violation of 49 C.F.R.
§ 195.452(b)(1).
Item 8: The Notice proposed a civil penalty of $36,000 for Respondent’s violation of 49 C.F.R.
§ 195.509(a), for failing to have a written OQ program by April 27, 2001, despite having
operated continuously since that date. ET neither contested the allegation nor presented any
evidence or argument justifying a reduction in or elimination of the proposed penalty.
Accordingly, having reviewed the record and considered the assessment criteria, I assess Par
Pacific a civil penalty of $36,000 for violation of 49 C.F.R. § 195.509(a).
Item 10: The Notice proposed a civil penalty of $21,300 for Respondent’s violation of 49
C.F.R. § 195.573(a)(1), for failing to conduct cathodic-protection pipe-to-soil tests on the
pipeline at least once each calendar year, but with intervals not exceeding 15 months. ET neither
contested the allegation nor presented any evidence or argument justifying a reduction in or
elimination of the proposed penalty. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Par Pacific a civil penalty of $21,300 for violation of 49 C.F.R.
§ 195.573(a)(1).
Item 11: The Notice proposed a civil penalty of $20,600 for Respondent’s violation of 49
C.F.R. § 195.573(c), for failing to conduct electrical checks on its rectifiers for proper
performance at the intervals required by the regulation. ET neither contested the allegation nor
presented any evidence or argument justifying a reduction in or elimination of the proposed
penalty. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Par Pacific a civil penalty of $20,600 for violation of 49 C.F.R. § 195.573(c).
Item 12: The Notice proposed a civil penalty of $19,100 for Respondent’s violation of 49
C.F.R. § 195.573(d), for failing to inspect its cathodic-protection system on its three above-
ground breakout tanks to ensure that its operation and maintenance was in accordance with API
651. ET neither contested the allegation nor presented any evidence or argument justifying a
reduction in or elimination of the proposed penalty. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Par Pacific a civil penalty of $19,100 for
violation of 49 C.F.R. § 195.573(d).
Item 13: The Notice proposed a civil penalty of $18,700 for Respondent’s violation of 49
C.F.R. § 195.583(a), for failing to inspect its pipeline that was exposed to the atmosphere for
evidence of atmospheric corrosion at least every three years, but with intervals not exceeding 39
months. ET neither contested the allegation nor presented any evidence or argument justifying a
reduction in or elimination of the proposed penalty. Accordingly, having reviewed the record



CPF No. 3-2018-6004
Page 11
and considered the assessment criteria, I assess Par Pacific a civil penalty of $18,700 for
violation of 49 C.F.R. § 195.583(a).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Par Pacific a total civil penalty of $293,600, which amount was paid
in full by wire transfer dated June 12, 2018.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 3, 7, and 12 in the Notice for
violations of 49 C.F.R. §§ 195.402(a), 195.452(b)(1), and 195.573(d), respectively. Under 49
U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R.
§ 190.217, Respondent is ordered to take the following actions to ensure compliance with the
pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.402(a) (Item 3), Respondent must prepare a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies, as required by 49
C.F.R. Part 195. A schedule for completion of this manual must be submitted to the
Director, Central Region, within 30 days of receipt of this Final Order. The manual
required by this paragraph must be completed no later than six months from the
issuance of this Final Order.
2. With respect to the violation of § 195.452(b)(1) (Item 7), Respondent must
develop a written IM program in accordance with 49 C.F.R. § 195.452. A schedule
for completion of this manual must be submitted to the Director, Central Region
within 30 days of receipt of this Final Order. The manual required by this paragraph
must be completed no later than six months from the issuance of this Final Order.
3. With respect to the violation of § 195.573(d) (Item 12), Respondent must monitor
external corrosion control at its breakout tanks and remediate any deficiencies.
Monitoring of its breakout tanks must begin within 30 days of receipt of this Final
Order. Records of the initial monitor readings and any remediation must be
submitted to the Director, Central Region, within 30 days of completion.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
It is requested that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. It is
requested that these costs be reported in two categories: (1) total cost associated with
preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with



CPF No. 3-2018-6004
Page 12
replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for
each day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
WARNING ITEM
With respect to Item 9, the Notice alleged probable violations of Part 195 but did not propose a
civil penalty or compliance order for this item. Therefore, this is considered to be a warning
item. The warning was for:
49 C.F.R. § 195.509(b) (Item 9) ─ Respondent’s alleged failure to complete the
qualification of individuals performing covered tasks by October 28, 2002.
Specifically, the Notice alleged that ET had operated its pipeline continuously
since October 28, 2002, but had not completed the qualification of individuals
performing covered tasks as of the November 9-10, 2015 PHMSA inspection.
If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject
to future enforcement action.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
October 30, 2018
___________________________________ _________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320186004>
- Source ID: `phmsa-enforcement`
- SHA-256: `7bc367a351284a7d5d6130eaad0b7eda9dcf1d372794cf2cf07683ead5a81f21`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T02:50:11.792Z
- Document slug: `phmsa-enforcement-320186004`

### Source metadata

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  "caseStatus": "CLOSED",
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```