# KPC PIPELINE, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 320121010W
- **title:** KPC PIPELINE, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-11-27
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.945(a).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320121010w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320121010W
**body:**

Warning Letter involving KPC PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.945(a). The case was opened on 2012-11-27 and is reported as closed as of 2012-11-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320121010W_Warning Letter_11272012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320121010W/320121010W_Warning%20Letter_11272012.pdf

320121010W_Warning Letter_11272012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320121010W/320121010W_Warning%20Letter_11272012_text.pdf

320121010W_Warning Letter_11272012_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 27, 2012
Mr. Joe Fowler
Vice President, Operations
KPC Pipeline, LLC
19970 161st Street
Olathe, KS 66062
CPF 3-2012-1010W
Dear Mr. Fowler:
On December 8-10, 2010, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) and the Kansas Corporation Commission (KCC) pursuant to Chapter
601 of 49 United States Code inspected the PostRock KPC Pipeline, LLC (PostRock)gas
transmission integrity management program in Olathe, Kansas. On September 28, 2012, MV
Pipelines, LLC purchased the entire pipeline system and renamed the company KPC Pipeline,
LLC (KPC).
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. §192.945 What methods must an operator use to measure program effectiveness?
(a) General. An operator must include in its integrity management program
methods to measure whether the program is effective in assessing and evaluating the
integrity of each covered pipeline segment and in protecting the high consequence



areas. These measures must include the four overall performance measures
specified in ASME/ANSI B31.8S (incorporated by reference, see § 192.7 of this
part), section 9.4, and the specific measures for each identified threat specified in
ASME/ANSI B31.8S, Appendix A. An operator must submit these measures, by
electronic or other means, on a semi-annual frequency to OPS in accordance with
§192.51.
PostRock was not measuring the threat-specific metrics semi-annually as required. In addition,
the semi-annual report of the four overall performance measures to OPS for the period ending
December 31, 2009, contained erroneous information that required correction and the semi-
annual report of the four overall performance measures to OPS for the period ending June 30,
2010, was not submitted on a timely basis. KPC should ensure that in the future, the four overall
performance measures be accurately reported as a part of its annual report as now required.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. 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 correct the item(s) identified in this letter.
Failure to do so will result in KPC 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 3-2012-1010W. 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,
David Barrett
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
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