{"operation":"document","citation":"CPF 320131001W","title":"ROCKIES EXPRESS PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-01-11","effective_on":null,"summary":"CLOSED warning letter citing 192.743(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320131001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320131001W","body":"Warning Letter involving ROCKIES EXPRESS PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 192.743(a). The case was opened on 2013-01-11 and is reported as closed as of 2013-01-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320131001W_Warning Letter_01112013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131001W/320131001W_Warning%20Letter_01112013.pdf\n\n320131001W_Warning Letter_01112013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131001W/320131001W_Warning%20Letter_01112013_text.pdf\n\n320131001W_Warning Letter_01112013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 11, 2013\nMr. Dwayne Burton\nVice President, Operations and Engineering\nKinder Morgan Energy Partners, L.P.\nOne Allen Center\n500 Dallas Street, Suite 1000\nHouston, Texas 77002\nMr. George Rider\nExecutive Vice President and General Counsel\nTallgrass Energy Partners, LP\n6640 W. 143rd Street, Suite 200\nOverland Park, Kansas 66223\nCPF 3-2013-1001W\nDear Messrs. Burton and Rider:\nOn April 5-8, April 1-15, and July 11-15, 2011, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49\nUnited States Code inspected your Rockies Express Pipeline, LLC (REX) from the\nMexico, Missouri Compressor Station to the Indiana/Ohio border in Mexico, Missouri,\nBlue Mound, Illinois, and Bainbridge, Indiana.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected\nand the probable violation(s) are:\n1. §192.743 Pressure limiting and regulating stations: Capacity of relief devices.\n(a) Pressure relief devices at pressure limiting stations and pressure regulating\nstations must have sufficient capacity to protect the facilities to which they are\nconnected. Except as provided in §192.739(b), the capacity must be consistent with\nthe pressure limits of §192.201(a). This capacity must be determined at intervals\nnot exceeding 15 months, but at least once each calendar year, by testing the\ndevices in place or by review and calculations.\n\n\n\nREX failed to meet the relief devices capacity calculation requirements for three\npressure limiting devices at the Blue Mound, Illinois Compressor Station.\n• REX did not determine the capacity of relief devices at the Blue Mound\nCompressor Station at a pressure which was consistent with the pressure limits\nof §192.201(a). REX incorrectly determined the capacity in 2009 and 2010 of\ntwo relief valves on the Fuel Gas Filter Separator (relief valve PSV 4010 and\nPSV 4015). The MAOP of the filter separator within the Compressor Station\nwas 250 psig. The capacity calculation was made using 302 psig, which was\n121% of MAOP. Therefore, the capacity calculation for the relief valve was\nincorrect. During PHMSA’s inspection, REX recalculated the capacity using\n275 psig (110% MAOP) and found the relief valves were adequately sized.\n• REX did not perform a capacity calculation for ANR MAK-1000 Filter\nSeparator Relief Valve, PSV-2011 (also designated - PSV 1000) in 2009 and\n2010. The first capacity calculation for this device was in the year 2011 and\nwas provided for PHMSA’s review.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum\npenalty not to exceed $1,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter. Failure to do so will result in REX\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 3-2013-1001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDavid Barrett\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":4820}