# ROCKIES EXPRESS PIPELINE LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320131002
- **title:** ROCKIES EXPRESS PIPELINE LLC — Notice of Probable Violation
- **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 notice of probable violation citing 190.203(f).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320131002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320131002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320131002
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320131002
**body:**

Notice of Probable Violation involving ROCKIES EXPRESS PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 190.203(f). The case was opened on 2013-01-11 and is reported as closed as of 2016-06-10. Proposed civil penalty: $67,400. Assessed civil penalty: $67,400. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320131002_Closure Letter_06102016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_Closure%20Letter_06102016.pdf

320131002_Closure Letter_06102016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_Closure%20Letter_06102016_text.pdf

320131002_Final Order_01172014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_Final%20Order_01172014.pdf

320131002_Final Order_01172014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_Final%20Order_01172014_text.pdf

320131002_NOPV PCP PCO_01112013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_NOPV%20PCP%20PCO_01112013.pdf

320131002_NOPV PCP PCO_01112013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_NOPV%20PCP%20PCO_01112013_text.pdf

320131002_Operator Response Notice_03062013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320131002/320131002_Operator%20Response%20Notice_03062013.pdf

320131002_NOPV PCP PCO_01112013_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
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 3-2013-1002
Dear Messrs. Burton and Rider:
On February 6, 2006, pursuant to 49 U.S.C. §60118(c) and 49 C.F.R. §190.341, Rockies
Express Pipeline, L.L.C. (Rockies Express) filed a special permit request with the Pipeline
& Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
for a waiver from certain provisions of 49 C.F.R. Part 192 for its Rockies Express Pipeline
running from Wyoming to Ohio (REX Pipeline). PHMSA issues special permits to
pipeline operators if the agency determines that a waiver of a particular regulation or
standard is not inconsistent with pipeline safety. On July 11, 2006, PHMSA issued an
order granting Rockies Express a special permit (SP) for the REX Pipeline with certain



conditions and limitations (SP Order). See Docket number: PHMSA-2006-23998 Notice 2.
On May 16, 2009, PHMSA was notified of a release of gas from the REX Pipeline
downstream of its Bertrand, Nebraska, compressor station which met the reporting criteria
of Condition 25 of the special permit. On July 14-16, 2009, a representative of the
PHMSA pursuant to Chapter 601 of 49 United States Code, investigated the report
involving a release and inspected the pipeline facilities and records of Rockies Express'
Bertrand, Nebraska, compressor station to determine the company’s compliance with the
SP Order.
On April 1-15, and July 11-15, 2011, representatives of PHMSA pursuant to Chapter 601
of 49 United States Code inspected the REX Pipeline from the Mexico, Missouri,
Compressor Station to the Indiana/Ohio border facilities to determine the company’s
compliance with the SP Order.
As a result of the inspections, it appears that Rockies Express has committed probable
violations of the SP Order. As stated in 49 C.F.R. §190.203(f), when information obtained
from an inspection indicates that further OPS action is warranted, OPS may initiate one or
more enforcement proceedings prescribed in §190.207 through §190.235.
The items inspected and the probable violation(s) are:
1. Condition 15.
Overpressure Protection Control: Mainline pipeline overpressure protection
must be limited to a maximum of 104 percent MAOP.
Bertrand Compressor Station: Rockies Express allowed its pipeline pressure to
exceed 104 percent MAOP by failing to limit its overpressure protection in
accordance with SP Condition 15 at the Bertrand Compressor Station. On May 16,
2009, Rockies Express exceeded 104 percent of MAOP in the mainline pipeline
segment between its Bertrand Compressor Station and downstream mainline valve
number 15. After the unintended closure of valve number 15 at approximately
3:42 a.m., the station compressor units were automatically shut down because of
high discharge pressure alarms with a peak pipeline pressure of 104.6 percent.
Rockies Express failed to implement the O&M Procedure 703 for operation under
the special permit which required the unit shutdowns to be set to 103 percent for all
compressors in the REX pipeline. The overpressure protection set points for those
units at Bertrand compressor station in place at the time were set at 105 percent
MAOP.
2. Condition 15.
Overpressure Protection Control: Mainline pipeline overpressure protection
must be limited to a maximum of 104 percent MAOP.
Blue Mound Compressor Station: Rockies Express did not set its overpressure
protection at the Blue Mound Compressor Station to limit the pressure to a
maximum of 104 percent MAOP in accordance with SP Condition 15. PHMSA
discovered during the 2011 inspection of Rockies Express' Blue Mound
Page 2 of 6



Compressor Station that unit shutdown controls were set above 104% of mainline
MAOP. The September 15, 2010, inspection records for Blue Mound listed the “as
found” and “as left” set points at 105 percent MAOP for all five compressor station
units. The Blue Mound unit shutdowns remained out of compliance until they were
reset to 103 percent of MAOP on April 20, 2011.
3. Condition 24.
SCADA Procedures: A detailed procedure for establishing and maintaining
accurate SCADA set points must be established to ensure the pipeline operates
within acceptable design limits at all times.
Rockies Express failed to establish a detailed procedure for establishing and
maintaining SCADA set points within acceptable design limits for all operating
modes. On May 16, 2009, Rockies Express was allowed to operate under local
control at the Bertrand Compressor station. Although SCADA controllers were
monitoring the pipeline system, the pipeline was operated above acceptable design
limits, ultimately exceeding MAOP and allowable overpressure protection of 104
percent. The procedures (O&M 703 section 3.3.2.1.d, O&M 1103 section 3,
Bertrand unit “Start Procedure”) did not accurately define SCADA set points for
operating within acceptable design limits when in local mode.
4. Condition 28.
Gas Quality Monitoring and Control: An acceptable gas quality monitoring
and mitigation program must be instituted to not exceed the following limits:
Special Permit Condition # 28a:
H2S (4 grains maximum);
Special Permit Condition # 28b:
CO2 (3 percent maximum);
Special Permit Condition # 28c:
H2O (less than or equal to 7 pounds per million standard cubic feet and
no free water); and
Special Permit Condition # 28d:
Other deleterious constituents that may impact the integrity of the
pipeline must be instituted. Filters/separators must be installed at
locations where gas is received into the pipeline to minimize the entry of
contaminants and to protect the integrity of downstream pipeline
segments. Gas quality monitoring equipment must be installed to
permit the operator to manage the introduction of contaminants and
free liquids into the pipeline.
Rockies Express did not institute its gas quality monitoring and control program in
a manner that mitigated the entry of contaminants and ensured that the
contaminants did not exceed the limits prescribed in SP Condition 28. The SCADA
system recorded a total of 870 alarms indicating the gas quality exceeded the
maximum limit, yet no mitigation measures were taken.
Page 3 of 6



5. Condition 24
SCADA Procedures: A detailed procedure for establishing and maintaining
accurate SCADA set points must be established to ensure the pipeline operates
within acceptable design limits at all times.
Rockies Express failed to establish a detailed procedure to ensure accurate SCADA
set points for its gas quality monitoring and control program were maintained. The
accuracy of SCADA set points was not verified during, after, or as a result of
calibrations on equipment required for monitoring the gas quality limits prescribed
in SP Condition 28.
Proposed Civil Penalty
Under 49 United States Code, §60122, you are subject to a civil penalty not to exceed
$200,000 for each violation for each day the violation persists up to a maximum of
$2,000,000 for any 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. The
Compliance Officer has reviewed the circumstances and supporting documentation
involved in the above probable violation(s) and has recommended that you be preliminarily
assessed a civil penalty of $67,400 as follows:
Item number PENALTY
1 $28,700
2 $38,700
Proposed Compliance Order
With respect to item numbers 3, 4 and 5 pursuant to 49 United States Code §60118(b), the
Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance
Order to Rockies Express Pipeline, LLC. Please refer to the Proposed Compliance Order,
which is enclosed and made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the response
options. 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). If you
do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your
right to contest the allegations in this Notice and authorizes the Associate Administrator for
Pipeline Safety to find facts as alleged in this Notice without further notice to you and to
issue a Final Order.
In your correspondence on this matter, please refer to CPF 3-2013-1002 and for each
document you submit, please provide a copy in electronic format whenever possible.
Page 4 of 6



Right to Modify, Suspend, or Revoke a Special Permit
Issuance of this enforcement action does not preclude PHMSA’s authority to seek
modification, suspension or revocation of the special permit issued under PHMSA-2006-
23998 Notice 2 at any time, as provided in 49 C.F.R. §190.341(h)(1).(v). If such action is
taken, PHMSA will provide Rockies Express Pipeline, LLC with the opportunity to show
cause why the proposed action should not be taken.
Sincerely,
David Barrett
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
Page 5 of 6



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Rockies Express Pipeline, LLC a
Compliance Order incorporating the following remedial requirements to ensure compliance
with the Special Permit Order issued on July 11, 2006.
1. 2. 3. 4. In regard to Item Number 3 of the Notice pertaining to procedures for SCADA
set points and operation within acceptable design limits at all times, Rockies
Express Pipeline, LLC must, within 30 days of receipt of the Final Order,
develop and implement enhanced procedures for pipeline control which ensure
that all methods or modes of operation of the pipeline (manual, local, remote,
automatic, emergency) have an equivalent level of safety with respect to
maintaining mainline pressure set points, or PHMSA may issue a show cause
letter modifying, revoking, or suspending the Order issued under PHMSA-
2006-23998 Notice 2.
In regard to Item Number 4 of the Notice pertaining to the requirement for
Rockies Express to institute an acceptable gas quality monitoring and mitigation
program to not exceed the established limits, Rockies Express must, within 90
days of receipt of the Final Order, institute a program to monitor and mitigate
gas quality problems which requires a documented investigation and mitigating
actions whenever the limits are exceeded, or PHMSA may issue a show cause
letter modifying, revoking, or suspending the Order issued under PHMSA-
2006-23998 Notice 2.
In regard to Item Number 5 of the Notice pertaining to the requirement for
Rockies Express to establish and maintain accurate SCADA set points for gas
quality, Rockies Express must, within 90 days of the receipt of the Final Order,
develop detailed procedures for ensuring that SCADA set points are calibrated
on a point-to-point basis with all field equipment used to monitor the pipeline or
PHMSA may issue a show cause letter modifying, revoking, or suspending the
Order issued under PHMSA-2006-23998 Notice 2.
Submit the results of the Proposed Compliance Order Items above to David
Barrett, Director, Central Region.
Page 6 of 6

320131002_Final Order_01172014_text.pdf

JANUARY 17, 2014
Mr. David G. Dehaemers, Jr.
Chief Executive Officer
Tallgrass Energy Partners, LP
Rockies Express Pipeline, LLC
6640 W. 143rd Street, Suite 200
Overland Park, Kansas, 66223
Re: CPF No. 3-2013-1002
Dear Mr. Dehaemers:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $67,400, and specifies actions that need to be taken on the
Rockies Express Pipeline to comply with the pipeline safety regulations. This is to acknowledge
receipt of payment of the full penalty amount, by wire transfer, dated March 12, 2013. When the
terms of the compliance order have been completed, as determined by the Director, Central
Region, this enforcement action will be closed. Service of the Final Order by certified mail is
deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Director, Central Region, OPS
Mr. Daniel W. Prascher, Manager, Compliance and Records,
Tallgrass Development, LP, 370 Van Gordon St., Lakewood, CO 80228
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Rockies Express Pipeline, LLC, ) CPF No. 3-2013-1002
)
Respondent. )
____________________________________)
FINAL ORDER
On July 14-16, 2009 and on April 1-15 and July 11-15, 2011, pursuant to 49 U.S.C. § 60117,
representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office
of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and
records of Rockies Express Pipeline, LLC (Rockies Express or Respondent)1 from the Mexico,
Missouri compressor station to the Indiana-Ohio border facilities, including the Bertrand,
Nebraska compressor station. The Rockies Express Pipeline runs approximately 1,679 miles
from Wyoming to eastern Ohio and has the capacity to transport 1.8 billion cubic feet of natural
gas per day.2
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated January 11, 2013, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice).3 In accordance with 49 C.F.R. § 190.207, the Notice
proposed finding that Rockies Express had committed five violations of Special Permit Order
PHMSA-2006-23998 (SP Order), issued by PHMSA on July 11, 2006, and proposed assessing a
civil penalty of $67,400 for two of the alleged violations. The Notice also proposed ordering
Respondent to take certain measures to correct the other three alleged violations.
Rockies Express responded to the Notice by letter dated March 6, 2013, as supplemented by
letter dated March 19, 2013 (collectively, Response). The company did not contest the
allegations of violation and paid the proposed civil penalty of $67,400, as provided in 49 C.F.R.
1 Rockies Express Pipeline, LLC, is a joint venture of: a subsidiary of Tallgrass Development, LP (50 percent
share); Sempra U.S. Gas & Power (25 percent share), a subsidiary of Sempra Energy; and a subsidiary of Phillips 66
(25 percent share). A wholly-owned subsidiary of Tallgrass Development, LP, operates the pipeline.
See http://www.tallgrassenergylp.com/pipelines/rex/ (last accessed December 17, 2013).
2 PHMSA Violation Report at 1.
3 The Notice was issued to Kinder Morgan Energy Partners, LP, and Tallgrass Energy Partners, LP, but Rockies
Express Pipeline, LLC, responded on their behalf.



2
§ 190.227. Payment of the penalty serves to authorize the Associate Administrator to make
findings of violation as to the items with penalties and to issue a final order under 49 C.F.R.
§ 190.213.
FINDINGS OF VIOLATION
In its Response, Rockies Express did not contest the allegations in the Notice that it violated the
SP Order as follows:
Item 1: The Notice alleged that Respondent violated Condition 15 of the SP Order, which states:
Condition 15.
Overpressure Protection Control: Mainline pipeline overpressure
protection must be limited to a maximum of 104 percent [maximum
allowable operating pressure] MAOP.
The Notice alleged that Respondent violated Condition 15 by allowing the pipeline pressure to
exceed 104 percent MAOP on May 16, 2009, on the segment between the Bertrand compressor
station and Main Live Valve 15. Specifically, the Notice alleged that the pressure was allowed
to reach 104.6 percent due to the overpressure protection set points being set to 105 percent at
the compressor station.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated Condition 15 of the SP Order by allowing the
pipeline pressure to exceed 104 percent MAOP on May 16, 2009, on the segment between the
Bertrand compressor station and Main Live Valve 15.
Item 2: The Notice alleged that Respondent violated Condition 15 of the SP Order, as quoted
above, by failing to set the overpressure protection set point at the Blue Mound compressor
station below 104 percent of MAOP. Specifically, the Notice alleged that Rockies Express set
the overpressure protection set point to 105 percent at this compressor station between
September 2010 and April 2011.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated Condition 15 of the SP Order by failing to set the
overpressure protection set point at the Blue Mound compressor station below 104 percent of
MAOP.
Item 3: The Notice alleged that Respondent violated Condition 24 of the SP Order, which states:
Condition 24.
SCADA Procedures: A detailed procedure for establishing and
maintaining accurate [supervisory control and data acquisition] SCADA
set points must be established to ensure the pipeline operates within
acceptable design limits at all times.



3
The Notice alleged that Respondent violated Condition 24 by failing to have a detailed procedure
for establishing and maintaining accurate SCADA set points to ensure the pipeline operated
within acceptable design limits in all operating modes. Specifically, the Notice alleged that the
“Start Procedure” established by Rockies Express did not accurately define SCADA set points
for local-mode operation at the Bertrand compressor station.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated Condition 24 of the SP Order by failing to have a
detailed procedure for establishing and maintaining accurate SCADA set points to operate the
pipeline within acceptable design limits in all operating modes.
Item 4: The Notice alleged that Respondent violated Condition 28 of the SP Order, which states:
Condition 28.
Gas Quality Monitoring and Control: An acceptable gas quality
monitoring and mitigation program must be instituted to not exceed the
following limits:
Special Permit Condition # 28a:
H2S (4 grains maximum);
Special Permit Condition # 28b:
CO2 (3 percent maximum);
Special Permit Condition # 28c:
H2O (less than or equal to 7 pounds per million standard cubic feet
and no free water); and
Special Permit Condition # 28d:
Other deleterious constituents that may impact the integrity of the
pipeline must be instituted. Filters/separators must be installed at locations
where gas is received into the pipeline to minimize the entry of
contaminants and to protect the integrity of downstream pipeline
segments. Gas quality monitoring equipment must be installed to permit
the operator to manage the introduction of contaminants and free liquids
into the pipeline.
The Notice alleged that Respondent violated Condition 28 by failing to institute a gas quality
monitoring and control program in a manner that mitigated the entry of contaminants and
ensured contaminants did not exceed prescribed limits. Specifically, the Notice alleged that
Rockies Express failed to mitigate contaminants, as evidenced by 870 alarms indicating that gas
quality exceeded the prescribed limits.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated Condition 28 of the SP Order by failing to
institute a gas quality monitoring and control program in a manner that mitigated the entry of
contaminants and that ensured contaminants did not exceed prescribed limits.
Item 5: The Notice alleged that Respondent violated Condition 24 of the SP Order, which states:



4
Condition 24.
SCADA Procedures: A detailed procedure for establishing and
maintaining accurate [supervisory control and data acquisition] SCADA
set points must be established to ensure the pipeline operates within
acceptable design limits at all times.
The Notice alleged that Respondent violated Condition 24 by failing to have a detailed procedure
for establishing and maintaining accurate SCADA set points to operate within acceptable design
limits in all operating modes. Specifically, the Notice alleged that Rockies Express failed to
verify the accuracy of the SCADA set points during, after, or as a result of calibrations on
equipment required for monitoring gas quality limits prescribed in Condition 28.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated Condition 24 of the SP Order by failing to have a
detailed procedure for establishing and maintaining accurate SCADA set points to operate within
acceptable design limits in all operating modes.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s
ability to pay the penalty and any effect that the penalty may have on its ability to continue doing
business; and the good faith of Respondent in attempting to comply with the pipeline safety
regulations. In addition, I may consider the economic benefit gained from the violation without
any reduction because of subsequent damages, and such other matters as justice may require.
The Notice proposed a total civil penalty of $67,400 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $28,700 for Respondent’s violation of SP Order
Condition 15, for allowing the pipeline pressure to exceed 104 percent MAOP on May 16, 2009,
on the segment between the Bertrand compressor station and Main Live Valve 15.
With respect to the nature, circumstances, and gravity of this violation, controlling pipeline
pressure within maximum limits is a key part of operating a pipeline safely. Respondent is
culpable for the violation because there was no justification for the pressure exceedance.
Respondent paid the proposed penalty for this Item, which authorizes PHMSA to make a finding
of violation pursuant to 49 C.F.R. § 190.213. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $28,700 for this
violation of SP Order Condition 15.



5
Item 2: The Notice proposed a civil penalty of $38,700 for Respondent’s violation of SP Order
Condition 15, for failing to set the overpressure protection set point at the Blue Mound
compressor station below 104 percent of MAOP. With respect to the nature, circumstances, and
gravity of this violation, overpressure protection is a fundamental aspect of pipeline safety.
Respondent is culpable for the violation because there was no justification for the improper set
point levels.
Respondent paid the proposed penalty for this Item, which authorizes PHMSA to make a finding
of violation pursuant to 49 C.F.R. § 190.213. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $38,700 for this
violation of SP Order Condition 15.
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $67,400, which amount has
already been paid by Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 3, 4, and 5 in the Notice for
violations of SP Order Conditions 24, 28, and 24, respectively. Under 49 U.S.C. § 60118(a),
each person who engages in the transportation of gas or who owns or operates a pipeline facility
is required to comply with the regulations established and orders issued under chapter 601.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is
ordered to take the following actions to ensure compliance with the SP Order conditions
applicable to its operations:
1. With respect to the violation of SP Order Condition 24 (Item 3), within 30 days
following receipt of this compliance order, Respondent must develop and implement
enhanced procedures for pipeline control which ensure that all methods or modes of
pipeline operation (manual, local, remote, automatic, emergency) have an equivalent
level of safety with respect to maintaining pressure set points.
2. With respect to the violation of SP Order Condition 28 (Item 4), within 90 days
following receipt of this compliance order, Respondent must institute a program to
monitor and mitigate gas quality problems that provides for a documented
investigation and mitigative actions whenever the established limits are exceeded.
3. With respect to the violation of SP Order Condition 24 (Item 5), within 90 days
following receipt of this compliance order, Respondent must develop detailed
procedures for ensuring that SCADA set points are calibrated on a point-to-point
basis with all field equipment used to monitor the pipeline.
4. Upon completion of Items 1-3 above, Respondent must submit documentation
demonstrating completion to the Director.



6
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order [CPF No. 3-2013-1002] may result in an action to modify,
suspend, or revoke SP Order PHMSA-2006-23998 and/or the administrative assessment of civil
penalties not to exceed $200,000 for each violation for each day the violation continues or in
referral to the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

320131002_Closure Letter_06102016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 10, 2016
Mr. David G. Dehaemers, Jr.
Chief Executive Officer
Tallgrass Energy Partners, LP
Rockies Express Pipeline, LLC
4200 W. 115th Street, Suite 350
Leawood, KS 66211-2609
CPF 3-2013-1002
Dear Mr. Dehaemers:
On January 17, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Tallgrass Energy Partners, LP and Rockies Express Pipeline, LLC a Final Order in the
above-referenced case. This Order included a Compliance Order and Civil Penalty assessment.
Based on our review of the documentation you provided and confirmation of payment of the
civil penalty, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
- **truncated:** false
- **body characters:** 30169