{"operation":"document","citation":"CPF 320191001M","title":"TRAILBLAZER PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-03-15","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.605(b)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320191001m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320191001m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320191001m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320191001M","body":"Notice of Amendment involving TRAILBLAZER PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.605(b)(2). The case was opened on 2019-03-15 and is reported as closed as of 2022-07-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320191001M_Closure Letter_07192022_(17-155390S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191001M/320191001M_Closure%20Letter_07192022_(17-155390S).pdf\n\n320191001M_Closure Letter_07192022_(17-155390S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191001M/320191001M_Closure%20Letter_07192022_(17-155390S)_text.pdf\n\n320191001M_Notice of Amendment_03152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191001M/320191001M_Notice%20of%20Amendment_03152019.pdf\n\n320191001M_Notice of Amendment_03152019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191001M/320191001M_Notice%20of%20Amendment_03152019_text.pdf\n\n320191001M_Operator Response to Notice_05022019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320191001M/320191001M_Operator%20Response%20to%20Notice_05022019.pdf\n\n320191001M_Notice of Amendment_03152019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 15, 2019\nDavid Dehaemers\nPresident\nTallgrass Energy, LLC\nTrailblazer Pipeline\n370 Van Gordon Street\nLakewood, CO 80228\nCPF 3-2019-1001M\nDear Mr. Dehaemers:\nFrom March 7, 2017, through August 31, 2017, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Tallgrass Trailblazer Pipeline procedures for operations, maintenance, and\nemergencies in Lakewood, CO.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTallgrass Energy, LLC’s (Tallgrass’) plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of the\nrequirements of this subpart and Subpart M of this part.\nTallgrass did not have adequate procedures for operations and maintenance activities as\nrequired by Subparts L & M, 49 CFR Part 192. The procedure to ensure the inspection of\ntransmission linebreak valves that might be required during any emergency in accordance to\n§192.745 was inadequate. PHMSA inspectors reviewed Tallgrass Procedure O&M 301_G\n\n\n\ntitled, \"Inspecting and Servicing Emergency Valves.\" The procedure stated, \"Inspect and\nservice valves in conformance with manufacturers’ recommendations.\" PHMSA reviewed the\ntwo manufacturer’s recommendations that were provided by Tallgrass for the linebreak valves-\n“Automatic Linebreak Control Adjustment and Set-up Procedure ALBC 1983-Present” and the\n“Shafer valve Company Adjustment and Setting Procedure for Shafer Automatic Line Break\nControl.” A review of valve maintenance records found documentation where the rate of drop\nwas not in accordance with the manufacturers’ recommendations.\nThe Shafer Valve Company Adjustment and Setting Procedure for Shafer Automatic Line\nBreak Control and the Automatic Linebreak Control Adjustment and Set-up Procedure ALBC\n1983-Present manufacturer’s recommendations require different ranges for rate of pressure\ndrop calibrations. The ALBC manufacturer’s recommendations require that the rate of drop for\nthe #72 orifice and 1640 cubic inch tank should never exceed 18 psi/min. Shafer manufacturer\nrecommendations were reported by Tallgrass for the #72 orifice and 1640 cubic inch tank to be\ncalibrated between 18-30 psi.\nTallgrass does not have a procedure to ensure that linebreak valves are properly maintained to\nensure pressure sensing systems will adapt to pressure and flow changes (rate of drop) in order\nto minimize or eliminate accidental valve closures.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\nAt the time of the inspection, Tallgrass's O&M 903_GL titled, “External Corrosion Control for\nBuried or Submerged Pipelines,\" procedures were inadequate because the procedures did not\ndescribe how voltage (IR) drops - other than those across the structure electrolyte boundary -\nwould be calculated for valid interpretation of annual pipe-to-soil readings. As such, the\nprocedures do not provide for a level of cathodic protection (CP) that complies with one or\nmore of the applicable criteria contained in 49 CFR Part 192, Appendix D.\n49 CFR §192.463 (a) requires that “[e]ach cathodic protection system required by this subpart\nmust provide a level of cathodic protection that complies with one or more of the applicable\ncriteria contained in Appendix D of this part. If none of these criteria is applicable, the cathodic\nprotection system must provide a level of cathodic protection at least equal to that provided by\ncompliance with one or more of these criteria.”\n49 CFR 192, Appendix D,II - Interpretation of voltage measurement requires that “[v]oltage\n(IR) drops other than those across the structure electrolyte boundary must be considered for\nvalid interpretation of the voltage measurement in paragraphs A(1) and (2) and paragraph B(1)\nof section I of the appendix.”\nTallgrass’s O&M 903_GL states in Attachment 3, “Existing industry standards provide several\nexample methods in which the IR drop may be considered including measuring or calculating\n2\n\n\n\nthe IR drop, reviewing the historical CP system performance, evaluating the physical and\nelectrical characteristics of the pipe and its environment, and determining whether there is\nphysical evidence of corrosion.” The procedure did not discuss how to calculate IR drop or\nhow to use the industry standards referenced in Attachment 3 to calculate IR Drop.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this\nsection must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\nAt the time of the inspection, Tallgrass's O&M 903_GL titled, “External Corrosion Control for\nBuried or Submerged Pipelines,\" procedure was inadequate because the procedure describes\ninterference tests as a desired action not a requirement, which does not minimize adverse\neffects on existing adjacent underground metallic structures. 49 CFR § 192.473(b) requires\nthat “[e]ach impressed current type cathodic protection system or galvanic anode system must\nbe designed and installed so as to minimize any adverse effects on existing adjacent\nunderground metallic structures.”\nTallgrass's O&M 903_GL, Section 3.4.8. “Interference Test Surveys” states, “Conduct\ninterference tests on metallic structures in the immediate area after energizing new CP units or\nafter installing metallic structures in the area of influence of a CP unit if either party desires.\"\nTallgrass procedure does not ensure that interference testing is conducted to minimize any\nadverse effects on existing adjacent underground metallic structures. The Tallgrass procedure\nrelies solely on the desires of either party after newly installed CP units or other metallic\nstructures.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\n3\n\n\n\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 45 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Tallgrass Energy, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2019-1001M and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n4\n\n320191001M_Closure Letter_07192022_(17-155390S)_text.pdf\n\nVIA ELECTRONIC MAIL TO: bill.moler@tallgrassenergylp.com;\njennifer.eckels@tallgrassenergylp.com; crystal.heter@tallgrassenergylp.com\nJuly 19, 2022\nWilliam Moler\nPresident/CEO\nTallgrass Energy, LP\nTrailblazer Pipeline Company\n4200 W. 115th Street, Suite 350\nLeawood, KS 66221\nRe: CPF 3-2019-1001M\nDear Mr. Moler:\nOn March 7, 2017, through August 31, 2017, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Tallgrass Trailblazer Pipeline’s procedures in\nLakewood, Colorado. As a result of the inspection, Tallgrass Energy, LP (Tallgrass) was issued\na Notice of Amendment on March 15, 2019, which proposed amendments to Tallgrass’\nprocedures.\nTallgrass submitted its amended procedures on July 6, 2022. My staff has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the Notice of Amendment have been\ncorrected.\nThis letter is to inform you that no further action is necessary and this case is now closed. Thank\nyou for your cooperation\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":11640}