{"operation":"document","citation":"CPF 32021100WL","title":"CRESTWOOD MIDSTREAM PARTNERS LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-12-10","effective_on":null,"summary":"CLOSED warning letter citing 195.208.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021100wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021100wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021100wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021100WL","body":"Warning Letter involving CRESTWOOD MIDSTREAM PARTNERS LP. PHMSA's enforcement data identifies the cited regulation as 195.208. The case was opened on 2021-12-10 and is reported as closed as of 2021-12-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021100WL_Warning Letter_12102021_(21-208851).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021100WL/32021100WL_Warning%20Letter_12102021_(21-208851).pdf\n\n32021100WL_Warning Letter_12102021_(21-208851)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021100WL/32021100WL_Warning%20Letter_12102021_(21-208851)_text.pdf\n\n32021100WL_Warning Letter_12102021_(21-208851)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: Bob.Phillips@crestwoodlp.com,\nRobert.Pettus@crestwoodlp.com and Justin.Davidson@crestwoodllp.com\nDecember 10, 2021\nMr. Robert G. Phillips\nPresident and Chief Executive Officer\nCrestwood Equity Partners LP\n811 Main Street, Suite 3400\nHouston, Texas 77002\nCPF 3-2021-100-WL\nDear Mr. Phillips:\nFrom August 9 through 13, 2021, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nyour Crestwood Arrow Crude Oil System (Crestwood) procedures, records, and field assets in\nWilliston, North Dakota.\nAs a result of the inspection, it is alleged that Crestwood has committed a probable violation of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item\ninspected and the probable violation is:\n1. § 195.208 Welding of supports and braces.\nSupports or braces may not be welded directly to pipe that will be operated at a\npressure of more than 100 p.s.i. (689 kPa) gage.\nCrestwood failed to comply with § 195.208 as the welding of supports or braces may not be\nwelded directly to pipe that will be operated at a pressure of more than 100 p.s.i. (689 kPa) gage.\nPHMSA, during the field audit of the Crestwood’s pump station number 3 and Central Delivery\nPoint, observed and photographed pipe supports welded directly to piping – a total of three (3)\nwelded braces were found.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a\nrelated series of violations. For violation occurring on or after January 11, 2021 and before May\n3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nCrestwood Equity Partners LP being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2021-100-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Robert Pettus, Senior Manager, Construction & Pipeline Regulatory, Crestwood Equity\nPartners LP, Robert.Pettus@crestwoodlp.com\nJustin Davidson, Pipeline Compliance Adviser, Crestwood Arrow Crude Oil System,\nJustin.Davidson@crestwoodllp.com\n2","truncated":false,"body_characters":4633}