# ROCKIES EXPRESS PIPELINE LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

320131001W_Warning Letter_01112013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131001W/320131001W_Warning%20Letter_01112013.pdf

320131001W_Warning Letter_01112013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131001W/320131001W_Warning%20Letter_01112013_text.pdf

320131001W_Warning Letter_01112013_text.pdf

WARNING 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.



REX 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
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