CPF 320131001W
CPF 320131001W
320131001W_Warning Letter_01112013_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 11, 2013 Mr. Dwayne Burton Vice President, Operations and Engineering Kinder Morgan Energy Partners, L.P. One Allen Center 500 Dallas Street, Suite 1000 Houston, Texas 77002 Mr. George Rider Executive Vice President and General Counsel Tallgrass Energy Partners, LP 6640 W. 143rd Street, Suite 200 Overland Park, Kansas 66223 CPF 3-2013-1001W Dear Messrs. Burton and Rider: On April 5-8, April 1-15, and July 11-15, 2011, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your Rockies Express Pipeline, LLC (REX) from the Mexico, Missouri Compressor Station to the Indiana/Ohio border in Mexico, Missouri, Blue Mound, Illinois, and Bainbridge, Indiana. 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 violation(s) are: 1. §192.743 Pressure limiting and regulating stations: Capacity of relief devices. (a) Pressure relief devices at pressure limiting stations and pressure regulating stations must have sufficient capacity to protect the facilities to which they are connected. Except as provided in §192.739(b), the capacity must be consistent with the pressure limits of §192.201(a). This capacity must be determined at intervals not exceeding 15 months, but at least once each calendar year, by testing the devices in place or by review and calculations.#
320131001W_Warning Letter_01112013_text.pdf, page 2REX failed to meet the relief devices capacity calculation requirements for three pressure limiting devices at the Blue Mound, Illinois Compressor Station. • REX did not determine the capacity of relief devices at the Blue Mound Compressor Station at a pressure which was consistent with the pressure limits of §192.201(a). REX incorrectly determined the capacity in 2009 and 2010 of two relief valves on the Fuel Gas Filter Separator (relief valve PSV 4010 and PSV 4015). The MAOP of the filter separator within the Compressor Station was 250 psig. The capacity calculation was made using 302 psig, which was 121% of MAOP. Therefore, the capacity calculation for the relief valve was incorrect. During PHMSA’s inspection, REX recalculated the capacity using 275 psig (110% MAOP) and found the relief valves were adequately sized. • REX did not perform a capacity calculation for ANR MAK-1000 Filter Separator Relief Valve, PSV-2011 (also designated - PSV 1000) in 2009 and 2010. The first capacity calculation for this device was in the year 2011 and was provided for PHMSA’s review. 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 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 REX 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 3-2013-1001W. 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#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.