# TRAILBLAZER PIPELINE CO — Notice of Probable Violation **Citation:** CPF 320211003 **Type / status:** enforcement / historical **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2021-02-26 CLOSED notice of probable violation citing 192.481(b), 192.605(a). ## Document text Notice of Probable Violation involving TRAILBLAZER PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.481(b), 192.605(a). The case was opened on 2021-02-26 and is reported as closed as of 2022-11-16. Proposed civil penalty: $36,600. Assessed civil penalty: $36,600. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 320211003_AMENDED NOPV PCP PCO_0727021_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_AMENDED%20NOPV%20PCP%20PCO_0727021_(17-155390S).pdf 320211003_AMENDED NOPV PCP PCO_0727021_(17-155390S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_AMENDED%20NOPV%20PCP%20PCO_0727021_(17-155390S)_text.pdf 320211003_Closure Letter_11162022_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Closure%20Letter_11162022_(17-155390S).pdf 320211003_Closure Letter_11162022_(17-155390S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Closure%20Letter_11162022_(17-155390S)_text.pdf 320211003_Final Order_03162022_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Final%20Order_03162022_(17-155390S).pdf 320211003_Final Order_03162022_(17-155390S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Final%20Order_03162022_(17-155390S)_text.pdf 320211003_NOPV PCP PCO_02262021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_NOPV%20PCP%20PCO_02262021.pdf 320211003_NOPV PCP PCO_02262021_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_NOPV%20PCP%20PCO_02262021_text.pdf 320211003_Op Resp Req for Mtg Req for Hrng Prelim Stmnt of Issues_03262021_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Op%20Resp%20Req%20for%20Mtg%20Req%20for%20Hrng%20Prelim%20Stmnt%20of%20Issues_03262021_(17-155390S).pdf 320211003_Operator Response to Notice and Withdrawal of Request for Hearing_07302021_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Operator%20Response%20to%20Notice%20and%20Withdrawal%20of%20Request%20for%20Hearing_07302021_(17-155390S).pdf 320211003_PHC Hearing Scheduled_05202021_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_PHC%20Hearing%20Scheduled_05202021_(17-155390S).pdf 320211003_PHC Hearing Scheduled_05202021_(17-155390S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_PHC%20Hearing%20Scheduled_05202021_(17-155390S)_text.pdf 320211003_Final Order_03162022_(17-155390S)_text.pdf March 16, 2022 VIA ELECTRONIC MAIL TO: bill.moler@tallgrassenergylp.com Mr. William Moler Director and Chief Executive Officer Tallgrass Energy, LP Trailblazer Pipeline Company 4200 W. 115th Street, Suite 350 Leawood, Kansas 66211 Re: CPF No. 3-2021-1003 Dear Mr. Moler: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $36,600, and specifies actions that need to be taken by your subsidiary, Trailblazer Pipeline Company, to comply with the pipeline safety regulations. The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date of transmission and acknowledgment of receipt 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. Gregory A. Ochs, Director, Central Region, Office of Pipeline Safety, PHMSA Ms. Jennifer Eckels, Manager- Compliance, Tallgrass Energy, LP, jennifer.eckels@tallgrassenergylp.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 ) Trailblazer Pipeline Company, ) CPF No. 3-2021-1003 a subsidiary of Tallgrass Energy, LP, ) ) ) ) Respondent. ) ____________________________________) FINAL ORDER From March 7, 2017 through August 31, 2017, 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 Trailblazer Pipeline Company’s natural gas pipeline system from Cheyenne, Wyoming to Beatrice, Nebraska (Trailblazer). Trailblazer, a subsidiary of Tallgrass Energy, LP, (Tallgrass, or collectively, Respondent) has an approximately 450-mile-long pipeline that interconnects with large interstate natural gas pipelines that transport gas to major consumer markets in the upper Midwest and Northeast.1 Tallgrass Energy, LP, owns and operates more than 8,300 miles of natural gas pipeline and more than 850 miles of crude pipeline, as well as natural gas midstream and natural gas liquids facilities, across Wyoming, Colorado, Nebraska, Kansas, Oklahoma, Missouri, Illinois, Indiana, and Ohio.2 As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent, by letter dated February 26, 2021, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Trailblazer had violated 49 C.F.R. §§ 192.481(b) and 192.605(a) and proposed assessing a civil penalty of $36,600 for one of the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct one of the alleged violations. Tallgrass responded to the Notice by letter dated March 26, 2021 (Response). Tallgrass contested one of the allegations of violation and requested a reduction in the proposed civil 1 Violation Report, page 1, on file with PHMSA. 2 Tallgrass Energy website, About Tallgrass Energy, www.tallgrassenergy.com/About.aspx,; Tallgrass Energy System Map, https://www.tallgrassenergy.com/Documents/Tallgrass System Map 11x17 v620q.pdf (Last accessed January 24, 2022). CPF 3-2021-1003 Page 2 penalty. Tallgrass requested a hearing as well as an opportunity for informal technical discussions prior to a hearing to clarify factual issues alleged in the Notice. On various dates between March 26, 2021 and July 27, 2021, OPS and Tallgrass engaged in informal technical discussions regarding the issues raised in the Response. As a result of those discussions, the Director issued an Amended Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Amended Notice) by letter dated July 27, 2021. The Amended Notice contained the same allegations of violation, proposed civil penalty, and proposed compliance order as the original Notice, but did not contain certain factual statements that were clarified during the informal technical discussions. By letter dated July 30, 2021, Tallgrass withdrew its request for a hearing, stated that it was no longer contesting either of the two allegations of violation, but reiterated its request for a reduction in the proposed civil penalty (Amended Response). The Amended Response thereby authorized the entry of this Final Order without further notice. FINDINGS OF VIOLATION In its Amended Response, Tallgrass did not contest the allegations in the Amended Notice that it violated 49 C.F.R. Part 192, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.481(b), which states: § 192.481 Atmospheric corrosion control: Monitoring. (a)…. (b) During inspections the operator must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. The Notice alleged that Respondent violated 49 C.F.R. § 192.481(b) by failing to give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. Specifically, the Notice alleged that Tallgrass failed to inspect for atmospheric corrosion (AC) at pipe supports at the 601 Compressor Station, Cheyenne Station/TB1 pig launchers, NNG Gage interconnect, and NGPL Gage interconnect. The Notice further alleged that Tallgrass also failed to inspect for AC under thermal insulation at the 601 Compressor Station. 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. § 192.481(b) by failing to give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a), which states in relevant part: CPF 3-2021-1003 Page 3 § 192.605 Procedural manual of operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response…. The Notice alleged that Respondent violated 49 C.F.R. § 192.605(a) by failing to follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. Specifically, the Notice alleged that Tallgrass failed to follow its Operations and Maintenance (O&M) manual procedure O&M 301. The Notice alleged further that O&M 301 referenced form OM300-01 Automatic Valve Service Report but that Respondent’s records indicated that three different forms were used for valve service reporting in 2015 and 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. § 192.605(a) by failing to follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. 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; any effect that the penalty may have on its ability to continue doing business; the good faith of Respondent in attempting to comply with the pipeline safety regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA. 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 $36,600 for the violation of Item 1, cited above. Item 1: The Notice proposed a civil penalty of $36,600 for Respondent’s violation of 49 C.F.R. § 192.481(b), for failing to give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. 3 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223. CPF 3-2021-1003 Page 4 In its Response and Amended Response, Tallgrass requested a reduction in the civil penalty based on a modification of the gravity factor. Tallgrass argued that the gravity factor should be reduced from a factor of seven to a factor of one because pipeline safety was minimally affected.4 In support of this argument, Tallgrass referenced photos in Exhibit A-1 of the Amended Notice and argued that the locations cited in the Amended Notice only had signs of “rust and discoloration” not signs of wall loss, peeling, or pitting.5 Tallgrass also pointed to PHMSA guidance which provides that rust is not indicative of active corrosion where there are no signs of coating deterioration, metal loss, or pitting.6 In addition, Tallgrass discussed the actions it had taken since the 2017 inspection.7 Specifically, Tallgrass noted that it had installed Fiberglass Reinforced Plastic at the locations identified in the Amended Notice, with the exception of the NNG meter run which it plans to replace with an ultrasonic meter, and observed no signs of active corrosion, metal loss, or pitting during the installation process.8 Tallgrass stated that it also installed inspection ports in the thermal insulation at the 601 Compressor Station so that the pipe under thermal insulation may be inspected for corrosion.9 Lastly, Tallgrass averred that if any of the locations in the Amended Notice developed active corrosion, it would have been promptly identified and remediated.10 In light of the aforementioned factors, Tallgrass request that the gravity factor, and thereby the penalty, be reduced. I will address Respondent’s arguments in reverse order. I acknowledge the various actions Respondent has taken; however, I do not find that post-inspection corrective actions warrant the reduction of the civil penalty.11 4 Gravity considers the severity of the violation. A gravity factor of seven is for violations that did not occur within a high consequence area (HCA) or “could affect” HCA, and were not within an area required to be covered by a gas distribution system’s integrity management program. A gravity factor of one is for violations in which pipeline safety was minimally affected. 5 Response, at 2 citing PHMSA Exhibit A-1, at pgs. 1-6, 21, on file with PHMSA. 6 Response, at 2 citing definition of atmospheric corrosion in PHMSA Part 192 Corrosion Enforcement Guidance at pg. 121 of 161 (Dec. 7, 2015), (“Atmospheric Corrosion is an area of metal loss due to general corrosion, localized corrosion pitting, or peeling scale on the steel surface that has damaged the pipe. Surface oxide is corrosion and if allowed to continue may affect the safe operation of the pipeline at some point in the future. Oxidation (or “light surface oxide”) can be defined as the slow rusting of pipe which is not yet considered to be atmospheric corrosion because there is no evidence of metal loss at this time.”), available at https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/Corrosion_Enforcement_Guidance_Part192_12_7_2015. pdf. 7 Response, at 2. 8 Id. 9 Id. 10 Id. 11 See, In the Matter of Phillips 66 Pipeline, LLC, CPF No. 3-2019-5006, available at https://primis.phmsa.dot.gov/comm/reports/enforce/documents/320195006/320195006 Final%20Order 05112020.p df (Last accessed March 1, 2022). CPF 3-2021-1003 Page 5 Concerning Respondent’s argument that the gravity factor should be reduced because active corrosion was not present, I am unconvinced that a penalty reduction is warranted. The Violation Report alleged that pipeline safety had been compromised in an area other than a high consequence area and this allegation is supported by color photographs clearly showing staining from atmospheric corrosion. Further, it is undisputed that Tallgrass failed to give particular attention to specific locations, many of which are not viewable to the naked eye without removing support or thermal insulation, for purposes of determining the presence of AC. The regulation is preventative, designed to ensure that atmospheric corrosion does not develop. Moreover, as I have previously stated “atmospheric corrosion inspections are a fundamental part of basic pipeline maintenance and that ensuring that any surface corrosion is detected and addressed before becoming a potential integrity threat is a key part of safely operating a pipeline.” (Emphasis added). 12 For these reasons, I find that there is no justification to reduce the gravity factor and therefore no justification to reduce the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $36,600 for violation of 49 C.F.R. §192.481(b) Payment of the civil penalty must be made within 20 days of receipt of the Final Order. Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845. Failure to pay the $36,600 civil penalty will result in accrual of interest at the current annual rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the matter to the Attorney General for appropriate action in a district court of the United States. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 2 in the Notice for violations of 49 C.F.R. §192.605(a). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas 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: 12 See, In the Matter of Express Holdings, LLC, Decision on Reconsideration, CPF No. 3-2020-5005, available at https://primis.phmsa.dot.gov/comm/reports/enforce/documents/320205005/320205005 Decision%20on%20Petition %20for%20Reconsideration 07262021 (16-153538S) text.pdf, (Last accessed March 1, 2022). CPF 3-2021-1003 Page 6 1. With respect to the violation of § 192.605(a) (Item 2), Respondent must re-inspect all line break or automatic shutoff valves, verify the correct pressure drop and maintenance activities per a PHMSA approved procedure utilizing PHMSA approved standardized forms. This work must be completed within six months of receipt of the Final Order. All records and outcomes of this required activity must be provided to PHMSA within one month after all have been completed. 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. PHMSA requests 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 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 (see 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. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of this Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays the payment of any civil penalty assessed. The other terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. March 16, 2022 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety 320211003_PHC Hearing Scheduled_05202021_(17-155390S)_text.pdf May 20, 2021 VIA ELECTRONIC MAIL TO: jennifer.eckels@tallgrassenergylp.com and gregory.ochs@dot.gov Ms. Jennifer Eckels Manager – Compliance Tallgrass Energy, LP 370 Van Gordon Street Lakewood, CO 80228 Mr. Gregory Ochs Director, Central Region Pipeline and Hazardous Materials Safety Administration 901 Locust Street, Suite 480 Kansas City, MO 64106-2641 Re: Notice of Hearing, Tallgrass Energy, LP CPF No. 3-2021-1003 Dear Ms. Eckels and Mr. Ochs: In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the Pipeline and Hazardous Materials Safety Administration in the above-referenced case. The hearing will take place on August 19, 2021, beginning at 8:30 a.m. Central Time. The hearing will be held via videoconference. I will provide the videoconference information prior to the hearing. At least 10 calendar days prior to the hearing (or by August 9, 2021), both parties must submit and exchange any additional written materials they intend to present at the hearing and the name and email address of each attendee. This information should be provided electronically. Materials not submitted by this date may be excluded. If you have any questions, please do not hesitate to contact me. Sincerely, Larry White Presiding Official cc: Mr. William Moler, President and Chief Executive Officer, Tallgrass Energy, LP, bill.moler@tallgrassenergylp.com Mr. Joseph Hainline, Counsel, Central Region, Office of Pipeline Safety, joseph.hainline@dot.gov 320211003_Closure Letter_11162022_(17-155390S)_text.pdf VIA ELECTRONIC MAIL TO: matt@tallgrass.com ; jennifer.eckels@tallgrassenergylp.com November 16, 2022 Mr. Matt Sheehy President and Chief Executive Officer Trailblazer Pipeline Company 370 Van Gordon Street Lakewood, CO 80228 Re: CPF 3-2021-1003 Dear Mr. Sheehy: On March 16, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Trailblazer Pipeline Company (Trailblazer), a Final Order in the above-referenced case. This Order included a Civil Penalty assessment and Compliance Order requirement to take corrective actions on Trailblazer’s pipeline. Based on our review of the documentation provided by Trailblazer and confirmation of payment of the civil penalty, it has been determined that Trailblazer has 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, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration cc: Ms. Jennifer Eckels, Manager- Compliance, Tallgrass Energy, LP, jennifer.eckels@tallgrassenergylp.com 320211003_NOPV PCP PCO_02262021_text.pdf NOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER VIA ELECTRONIC MAIL TO: Bill.moler@tallgrassenergylp.com and jennifer.eckels@tallgrassenergylp.com February 26, 2021 William Moler President/CEO Tallgrass Energy, LP Trailblazer Pipeline Company 4200 W. 115th Street, Suite 350 Leawood, KS 6611 CPF 3-2021-1003 Dear Mr. Moler: From March 7, 2017, through August 31, 2017, 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 (U.S.C.) inspected your Trailblazer natural gas pipeline system from Cheyenne, Wyoming to Beatrice, Nebraska. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are: 1. §192.481 Atmospheric corrosion control: Monitoring. (b) During inspections the operator must give particular attention to pipe at soil-to- air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. Tallgrass Energy, LP (Tallgrass) failed to give particular attention, during inspections, to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. Specifically, Tallgrass failed to inspect for atmospheric corrosion at pipe supports at 601 Compressor Station, Cheyenne Station/TB1 pig launchers, NNG Gage interconnect, and NGPL Gage interconnect. Tallgrass also failed to inspect for atmospheric corrosion under thermal insulation at 601 Compressor Station. During the PHMSA field evaluation of the 601 Compressor Station and the Cheyenne Hub/TB-1, signs of atmospheric corrosion were present at the pipe supports on the pig launchers. The pig launchers had pipe supports that did not appear to have been removed or lowered to inspect for atmospheric corrosion. Records from 2014-2017 were reviewed and confirmed that inspecting under pipeline supports had not been documented. During the PHMSA field evaluation of NNG Gage interconnect, and NGPL Gage interconnect, the pipeline displayed signs of atmospheric corrosion at the pipe supports. The supports did not appear to be removed or lowered to inspect for atmospheric corrosion on the pipeline. Records from 2014-2017 were reviewed and confirmed that inspecting under pipeline supports had not been documented for these locations. During the PHMSA field evaluation of the 601 Compressor Station, Tallgrass personnel failed to inspect for atmospheric corrosion under pipe under thermal insulation. The OM_300-03 – Valve Inspection Report used to record atmospheric corrosion inspections did not indicate that insulation was removed for examination. Furthermore, after addressing the thermal insulation on the pipeline at Compressor Station 601, the field personnel verbally confirmed that insulation is not removed for atmospheric corrosion inspections. Accordingly, there was no evidence to show Tallgrass gave particular attention, during inspections, to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. 2 2. §192.605 Procedural manual for operations, maintenance, and emergencies (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least one each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Tallgrass failed to follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. Specifically, Tallgrass failed to follow its Operations and Maintenance (O&M) manual procedure O&M 301. Tallgrass’s O&M 301 titled, “Inspecting and Servicing Emergency Valves”, Section 3.3 titled, “Service Procedure” states, “For valves with an automatic operator, refer to the manufacturer’s manual for instructions on inspecting and servicing the operator (e.g., Bettis, Keystone, Nordstrom, Shafer).” During the valve maintenance PHMSA record review, documentation was provided that showed Tallgrass did not comply with the manufacturers’ manual for instructions on inspecting and servicing. The rate of drop recorded values were not in accordance with the “Automatic Linebreak Control Adjustment and Set-up Procedure ALBC 1983- Present” (ALBC) manufacturer’s recommendations as provided by Tallgrass. The ALBC manufacturer’s recommendations displayed that a #72 orifice and 1640 cubic inch tank were used in conjunction with each other. This configuration was confirmed verbally by Tallgrass field personnel to be the correct sizes for the Trailblazer pipeline. The ALBC manufacturer’s recommendations require that the rate of drop for the #72 orifice and 1640 cubic inch tank should never exceed 18 psi/min. The rate of drop exceeded the 18psi/min on the following occasions:  The Automatic Valve Service Report dated 9/8/2016 documented a rate of drop of 25.3 psi/min for Motor Line Valve 17.  The Automatic Valve Service Report dated 8/16/2016 documented a rate of drop of 19.3 psi/min for TB 1.  The Automatic Valve Service Report dated 9/30/2015 documented a rate of drop of 21.6 psi/min for TB 1.  The Automatic Valve Service Report dated 9/15/2015 documented a rate of drop of 25.6 psi/min for TB 2.  The Automatic Valve Service Report dated 9/30/2015 documented a rate of drop of 28.6 psi/min for TB 3 3  The Automatic Valve Service Report dated 9/13/2016 documented a rate of drop of 20.3 psi/min for TB 4. On December 20, 2017, PHMSA received hand-written notes on a different document regarding manufacturer’s recommendations, “Shafer Valve Company Adjustment and Setting Procedure for Shafer Automatic Line Break Control” (Shafer). The hand-written notes on the Shafer manufacturer recommendations stated that the #72 orifice and 1640 cubic inch tank should be calibrated between 18-30 psi. However, The Automatic Valve Service Reports for TB 23, TB 21, and TB 18 for calendar years 2014, 2015, and 2016 were all calibrated below 18 psi. MLV 17 was also calibrated below 18 psi in 2014 and 2015. Furthermore, Tallgrass failed to follow O&M 301. O&M 301 references form OM300-01 Automatic Valve Service Report. However, records indicated that three different forms were used for 2015 and 2016. Form OM300-01 and the other two forms used do not contain the same information including orifice size. Tallgrass has experienced abnormal operations due to unintended valve closures. Unintentional valve closures can lead to loss of service to customers, including sensitive customers such as hospitals, schools, chemical plants and power plants. Accordingly, Tallgrass failed to follow its manual of written procedures for conducting operations and maintenance activities and for emergency response. Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. We have reviewed the circumstances and supporting documentation involved for the above probable violation(s) and recommend that you be preliminarily assessed a civil penalty of $36,600 as follows: Item number PENALTY 1 $36,600 4 Proposed Compliance Order With respect to item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Tallgrass Energy, LP. 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 Enforcement 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). Following the receipt of this Notice, you have 30 days to submit written comments, or request a hearing under 49 CFR § 190.211. 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. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. This period may be extended by written request for good cause. In your correspondence on this matter, please refer to CPF 3-2021-1003 and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings 5 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Tallgrass Energy, LP a Compliance Order incorporating the following remedial requirements to ensure the compliance of Tallgrass Energy, LP with the pipeline safety regulations: A. B. In regard to Item 2 of the Notice pertaining to Tallgrass Energy, LP failing to follow its Operations and Maintenance (O&M) manual procedure O&M 301, Tallgrass Energy, LP must re-inspect all line break or automatic shutoff valves, verify the correct pressure drop and maintenance activities per a PHMSA approved procedure utilizing PHMSA approved standardized forms. This work must be completed within 6 months of receipt of the Final Order. All records and outcomes of this required activity must be provided to PHMSA within 1 month after all have been completed. It is requested (not mandated) that Tallgrass Energy, LP maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Greg A. Ochs, 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. 6 320211003_AMENDED NOPV PCP PCO_0727021_(17-155390S)_text.pdf AMENDED NOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER VIA ELECTRONIC MAIL TO: Bill.moler@tallgrassenergylp.com and jennifer.eckels@tallgrassenergylp.com July 27, 2021 William Moler President/CEO Tallgrass Energy, LP Trailblazer Pipeline Company 4200 W. 115th Street, Suite 350 Leawood, KS 6611 CPF 3-2021-1003 Dear Mr. Moler: From March 7, 2017, through August 31, 2017, 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 (U.S.C.) inspected your Trailblazer natural gas pipeline system from Cheyenne, Wyoming to Beatrice, Nebraska. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are: 1. § 192.481 Atmospheric corrosion control: Monitoring. (a) . . . . (b) During inspections the operator must give particular attention to pipe at soil-to- air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. Tallgrass Energy, LP (Tallgrass) failed to give particular attention, during inspections, to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. Specifically, Tallgrass failed to inspect for atmospheric corrosion at pipe supports at 601 Compressor Station, Cheyenne Station/TB1 pig launchers, NNG Gage interconnect, and NGPL Gage interconnect. Tallgrass also failed to inspect for atmospheric corrosion under thermal insulation at 601 Compressor Station. During the PHMSA field evaluation of the 601 Compressor Station and the Cheyenne Hub/TB-1, signs of atmospheric corrosion were present at the pipe supports on the pig launchers. The pig launchers had pipe supports that did not appear to have been removed or lowered to inspect for atmospheric corrosion. Records from 2014-2017 were reviewed and confirmed that inspecting under pipeline supports had not been documented. During the PHMSA field evaluation of NNG Gage interconnect, and NGPL Gage interconnect, the pipeline displayed signs of atmospheric corrosion at the pipe supports. The supports did not appear to be removed or lowered to inspect for atmospheric corrosion on the pipeline. Records from 2014-2017 were reviewed and confirmed that inspecting under pipeline supports had not been documented for these locations. During the PHMSA field evaluation of the 601 Compressor Station, Tallgrass personnel failed to inspect for atmospheric corrosion under pipe under thermal insulation. The OM_300-03 – Valve Inspection Report used to record atmospheric corrosion inspections did not indicate that insulation was removed for examination. Furthermore, after addressing the thermal insulation on the pipeline at Compressor Station 601, the field personnel verbally confirmed that insulation is not removed for atmospheric corrosion inspections. Accordingly, there was no evidence to show Tallgrass gave particular attention, during inspections, to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. 2 2. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least one each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Tallgrass failed to follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. Specifically, Tallgrass failed to follow its Operations and Maintenance (O&M) manual procedure O&M 301. O&M 301 references form OM300-01 Automatic Valve Service Report. However, records reviewed indicated that three different forms were used for 2015 and 2016. Form OM300-01 and the other two forms used do not contain the same information including orifice size. Accordingly, Tallgrass failed to follow its manual of written procedures for conducting operations and maintenance activities and for emergency response. Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. We have reviewed the circumstances and supporting documentation involved for the above probable violation(s) and recommend that you be preliminarily assessed a civil penalty of $36,600 as follows: Item number PENALTY 1 $36,600 Proposed Compliance Order With respect to item 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Tallgrass Energy, LP. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. 3 Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement 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). Following the receipt of this Notice, you have 30 days to submit written comments, or request a hearing under 49 CFR § 190.211. 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. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. This period may be extended by written request for good cause. In your correspondence on this matter, please refer to CPF 3-2021-1003 and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings 4 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Tallgrass Energy, LP a Compliance Order incorporating the following remedial requirements to ensure the compliance of Tallgrass Energy, LP with the pipeline safety regulations: A. B. In regard to Item 2 of the Notice pertaining to Tallgrass Energy, LP failing to follow its Operations and Maintenance (O&M) manual procedure O&M 301, Tallgrass Energy, LP must re-inspect all line break or automatic shutoff valves, verify the correct pressure drop and maintenance activities per a PHMSA approved procedure utilizing PHMSA approved standardized forms. This work must be completed within 6 months of receipt of the Final Order. All records and outcomes of this required activity must be provided to PHMSA within 1 month after all have been completed. It is requested (not mandated) that Tallgrass Energy, LP maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Greg A. Ochs, 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. 5 ## Provenance - Official: Yes - Source: - Source ID: `phmsa-enforcement` - SHA-256: `172d1dd7b2b22cca1961c0b649667a2a3fdb8023e4eb28a03c6da7de912140b1` - Retrieved: 2026-08-20T04:44:44.458Z - Exported: 2026-08-22T22:02:29.622Z - Document slug: `phmsa-enforcement-320211003` ### Source metadata ```json { "cpf": "320211003", "operator": "TRAILBLAZER PIPELINE CO", "region": "Central", "pipelineType": "GAS INTERSTATE ONSHORE", "caseStatus": "CLOSED", "citedSections": [ "192.481(b)", "192.605(a)" ], "dataAsOf": "08/04/2026 12PM", "caseDataAsOf": "2026-08-04", "attachmentCount": 12, "attachments": [ { "name": "320211003_AMENDED NOPV PCP PCO_0727021_(17-155390S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_AMENDED%20NOPV%20PCP%20PCO_0727021_(17-155390S).pdf", "bytes": 323174, "category": "agency_document" }, { "name": "320211003_AMENDED NOPV PCP PCO_0727021_(17-155390S)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_AMENDED%20NOPV%20PCP%20PCO_0727021_(17-155390S)_text.pdf", "bytes": 147508, "category": "agency_document" }, { "name": "320211003_Closure Letter_11162022_(17-155390S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Closure%20Letter_11162022_(17-155390S).pdf", "bytes": 254666, "category": "agency_document" }, { "name": "320211003_Closure Letter_11162022_(17-155390S)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Closure%20Letter_11162022_(17-155390S)_text.pdf", "bytes": 81046, "category": "agency_document" }, { "name": "320211003_Final Order_03162022_(17-155390S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Final%20Order_03162022_(17-155390S).pdf", "bytes": 238336, "category": "agency_document" }, { "name": "320211003_Final Order_03162022_(17-155390S)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Final%20Order_03162022_(17-155390S)_text.pdf", "bytes": 144762, "category": "agency_document" }, { "name": "320211003_NOPV PCP PCO_02262021.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_NOPV%20PCP%20PCO_02262021.pdf", "bytes": 314670, "category": "agency_document" }, { "name": "320211003_NOPV PCP PCO_02262021_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_NOPV%20PCP%20PCO_02262021_text.pdf", "bytes": 157187, "category": "agency_document" }, { "name": "320211003_Op Resp Req for Mtg Req for Hrng Prelim Stmnt of Issues_03262021_(17-155390S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Op%20Resp%20Req%20for%20Mtg%20Req%20for%20Hrng%20Prelim%20Stmnt%20of%20Issues_03262021_(17-155390S).pdf", "bytes": 202985, "category": "case_document" }, { "name": "320211003_Operator Response to Notice and Withdrawal of Request for Hearing_07302021_(17-155390S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_Operator%20Response%20to%20Notice%20and%20Withdrawal%20of%20Request%20for%20Hearing_07302021_(17-155390S).pdf", "bytes": 150005, "category": "party_submission" }, { "name": "320211003_PHC Hearing Scheduled_05202021_(17-155390S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_PHC%20Hearing%20Scheduled_05202021_(17-155390S).pdf", "bytes": 165364, "category": "agency_document" }, { "name": "320211003_PHC Hearing Scheduled_05202021_(17-155390S)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/320211003/320211003_PHC%20Hearing%20Scheduled_05202021_(17-155390S)_text.pdf", "bytes": 80975, "category": "agency_document" } ], "extractedAgencyDocumentCount": 5, "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.", "jurisdiction": "US", "operatorName": "TRAILBLAZER PIPELINE CO" } ```