# MONARCH OIL PIPELINE, LLC — Warning Letter

**Citation:** CPF 420155026W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-11-04

CLOSED warning letter citing 195.64(a), 195.64(c)(1).

## Document text

Warning Letter involving MONARCH OIL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.64(a),  195.64(c)(1). The case was opened on 2015-11-04 and is reported as closed as of 2015-11-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420155026W_Warning Letter_11042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155026W/420155026W_Warning%20Letter_11042015.pdf

420155026W_Warning Letter_11042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155026W/420155026W_Warning%20Letter_11042015_text.pdf

420155026W_Warning Letter_11042015_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 4, 2015
Mr. Lee Conley
Vice President Engineering & Operations
Monarch Oil Pipeline, LLC
5613 DTC Pkwy., Ste. 310
Greenwood Village, CO 80111
CPF 4-2015-5026W
Dear Mr. Conley:
On September 14-17, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
Reydon Pipeline construction project in Canadian, Texas.
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 violation(s) are:



1. §195.64 National Registry of Pipeline and LNG Operators.
(a) OPID Request. Effective January 1, 2012, each operator of a hazardous liquid
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.
At the time of the inspection, Monarch Oil Pipeline had neither obtained an Operator
Identification Number (OPID) nor completed an OPID Assignment Request DOT Form PHMSA
F 1000.1 through the National Registry of Pipeline and LNG in accordance with 195.58.
However, after this issue was identified to Monarch by PHMSA, the operator requested an
OPID.
2. §195.64 National Registry of Pipeline and LNG Operators.
(c) Changes. Each operator must notify PHMSA electronically through the
National Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov,
of certain events.
(1) An operator must notify PHMSA of any of the following events not later
than 60 days before the event occurs:
(i) Construction or any planned rehabilitation, replacement,
modification, upgrade, uprate, or update of a facility, other than a
section of line pipe that costs $10 million or more. If 60 day notice is
not feasible because of an emergency, an operator must notify
PHMSA as soon as practicable;
(ii) Construction of 10 or more miles of a new hazardous liquid
pipeline; or
(iii) Construction of a new pipeline facility.
Monarch did not notify PHMSA of its intent to construct 10 or more miles of a new hazardous
liquid pipeline and associated pipeline facilities beginning July 8, 2015. This notification was
required not later than 60 days before the event was to occur; which, in this case not later than
May 9, 2015. PHMSA became aware of Monarch’s construction activities of approximately 37
miles of crude oil pipeline and a 5,000 bbl. break-out tank from information provided by the
Oklahoma Corporation Commission (OCC).
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We have reviewed the circumstances and supporting documents
2



involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item(s) identified in this letter.
Failure to do so will result in Monarch Oil Pipeline LLC being subject to additional enforcement
action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2015-5026W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420155026W>
- Source ID: `phmsa-enforcement`
- SHA-256: `4546aa1400dbcc81bf64d835c56afb433ed6a4979f1fc4009dff5c9a9ccdd5f0`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T02:50:18.248Z
- Document slug: `phmsa-enforcement-420155026w`

### Source metadata

```json
{
  "cpf": "420155026W",
  "operator": "MONARCH OIL PIPELINE, LLC",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.64(a)",
    "195.64(c)(1)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "420155026W_Warning Letter_11042015.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420155026W/420155026W_Warning%20Letter_11042015.pdf",
      "bytes": 588519,
      "category": "agency_document"
    },
    {
      "name": "420155026W_Warning Letter_11042015_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420155026W/420155026W_Warning%20Letter_11042015_text.pdf",
      "bytes": 10035,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "MONARCH OIL PIPELINE, LLC"
}
```
