# COFFEYVILLE RESOURCES CRUDE TRANSPORTATION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 32023008NOPV
- **title:** COFFEYVILLE RESOURCES CRUDE TRANSPORTATION, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2023-06-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.412(a), 195.573(a)(1), 195.573(e), 195.581(a), 195.589(c).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023008nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023008nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32023008NOPV
**body:**

Notice of Probable Violation involving COFFEYVILLE RESOURCES CRUDE TRANSPORTATION, LLC. PHMSA's enforcement data identifies the cited regulations as 195.412(a),  195.573(a)(1),  195.573(e),  195.581(a),  195.589(c). The case was opened on 2023-06-02 and is reported as closed as of 2024-03-06. Proposed civil penalty: $146,900. Assessed civil penalty: $78,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32023008NOPV_Closure Letter_03062024_(21-207275).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_Closure%20Letter_03062024_(21-207275).pdf

32023008NOPV_Closure Letter_03062024_(21-207275)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_Closure%20Letter_03062024_(21-207275)_text.pdf

32023008NOPV_Consent Agreement and Order_01022024_(21-207275).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_Consent%20Agreement%20and%20Order_01022024_(21-207275).pdf

32023008NOPV_Consent Agreement and Order_01022024_(21-207275)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_Consent%20Agreement%20and%20Order_01022024_(21-207275)_text.pdf

32023008NOPV_Operator Response to Notice_07072023_(21-207275).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_Operator%20Response%20to%20Notice_07072023_(21-207275).pdf

32023008NOPV_PCP PCO_06022023_(21-207275).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_PCP%20PCO_06022023_(21-207275).pdf

32023008NOPV_PCP PCO_06022023_(21-207275)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023008NOPV/32023008NOPV_PCP%20PCO_06022023_(21-207275)_text.pdf

32023008NOPV_Consent Agreement and Order_01022024_(21-207275)_text.pdf

January 2, 2024
VIA ELECTRONIC MAIL TO: dllamp@cvrenergy.com
David Lamp
President and Chief Executive Officer
Coffeyville Resources Crude Transportation, LLC
P.O. Box 3516
411 N.E. Washington Boulevard
Bartlesville, Oklahoma 74006
CPF No. 3-2023-008-NOPV
Dear Mr. Lamp:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Coffeyville Resources
Crude Transportation, LLC (CRCT), which was executed on December 15, 2023. Service of the
Consent Order and Consent Agreement by electronic mail is deemed effective upon the date of
transmission and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: Mr. Gregory A. Ochs, Director, Central Region, Office of Pipeline Safety, PHMSA
Mr. Keith Kuehn, Vice President, Crude Transportation, CRCT, kakuehn@cvrenergy.com
Mr. Blake Record, DOT Compliance Primary, CRCT, brecord@cvrenergy.com
Mr. Hunter Jeffrey, Partner, Perkins Coie LLP, Counsel for CRCT, jhunter@pekinscoie.com
CONFIRMATION OF 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 )
COFFEYVILLE RESOURCES )
CRUDE TRANSPORTATION, LLC, ) CPF No. 3-2023-008-NOPV
)
)
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated June 2, 2023, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Probable Violation, Proposed Civil
Penalty and Proposed Compliance Order (Notice) to Coffeyville Resources Crude Transportation,
LLC (CRCT or Respondent).
In response to the Notice, Respondent contested the proposed civil penalties for several Items and
asked to meet informally with PHMSA to discuss the civil penalties and the terms of the proposed
compliance order. Respondent did not request a hearing on the matter. Respondent and PHMSA
(the Parties) subsequently met to discuss the issues raised in the Response. As a result of those
discussions, as explained in more detail below, the Parties have agreed to a Consent Agreement
by which PHMSA makes findings of violations for each of the Items alleged in the Notice, CRCT
will pay a reduced civil penalty in the amount of $78,000, and CRCT will complete certain
compliance actions.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order. CRCT is hereby ordered to comply with the terms of the Consent Agreement
pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et seq., failure to comply with this Consent
Order may result in the assessment of civil penalties as set forth in 49 U.S.C. § 60122 and 49
C.F.R. § 190.223, or in referral to the Attorney General for appropriate relief in a district court of
the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 C.F.R. § 190.5.
January 2, 2024
______________________ ______________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
COFFEYVILLE RESOURCES )
CRUDE TRANSPORTATION, LLC, ) CPF No. 3-2023-008-NOPV
)
)
)
Respondent. )
____________________________________)
CONSENT AGREEMENT
From August 23, 2021 to October 4, 2021, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of title
49, United States Code (U.S.C.), conducted an on-site pipeline safety inspection of the facilities
and records of Coffeyville Resources Crude Transportation, LLC’s (CRCT or Respondent)
Hazardous Liquids Crude Pipeline System in Oklahoma and Kansas.
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated June 2, 2023, a Notice of Probable Violation, Proposed Compliance Order and
Proposed Civil Penalty (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that CRCT committed five violations of 49 C.F.R. Part 195, proposed ordering Respondent
to take certain measures to correct the alleged violations, and proposed a civil penalty of $146,900.
CRCT responded to the Notice by letters dated July 7, 2023, and November 9, 2023 (collectively,
Response). Respondent did not contest the allegations of violation but contested the proposed civil
penalty and provided additional evidence of actions taken to address the terms of the proposed
compliance order. CRCT requested an informal meeting with PHMSA to discuss the civil penalty
proposed in the Notice and the proposed compliance order. CRCT did not request a hearing.
PHMSA and Respondent (the Parties) subsequently met to discuss the issues raised in the
Response. As a result of those discussions and as explained in more detail below, the Parties have
agreed to a Consent Agreement by which PHMSA makes findings of violations for each of the
Items alleged in the Notice, CRCT will pay a reduced civil penalty in the amount of $78,000, and
CRCT will complete certain compliance actions.
Having agreed that settlement of this proceeding will avoid further administrative proceedings or
litigation and will serve the public interest by promoting safety and protection of the environment,



pursuant to 49 U.S.C. § 60101, et seq. and 49 C.F.R. Part 190, and upon consent and agreement,
the Parties hereby agree as follows:
I. General Provisions
1. Respondent acknowledges that as the operator of the pipeline facilities subject to
the Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the
Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative
orders issued thereunder. For purposes of this Consent Agreement (Agreement), Respondent
acknowledges that it received proper notice of PHMSA’s action in this proceeding and that the
Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq., and
the regulations and orders issued thereunder.
2. After Respondent returns this signed Agreement to PHMSA, the Agency’s
representative will present it to the Associate Administrator for Pipeline Safety, recommending that
the Associate Administrator adopt the terms of this Agreement by issuing an administrative order
(Consent Order) incorporating the terms of this Agreement. The terms of this Agreement constitute
an offer of settlement until accepted by the Associate Administrator. Once accepted, the Associate
Administrator will issue a Consent Order incorporating the terms of this Agreement.
3. Respondent consents to the issuance of the Consent Order, and hereby waives any
further procedural requirements with respect to its issuance. Respondent waives all rights to
contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including
all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution
provisions set forth herein.
4. This Agreement shall apply to and be binding upon PHMSA and Respondent, its
officers, directors, and employees, and its successors, assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
5. This Agreement constitutes the final, complete, and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this Agreement. The
Parties acknowledge that there are no representations, agreements or understandings relating to
settlement other than those expressly contained in this Agreement, except that the terms of this
Agreement may be construed by reference to the Notice.
6. Nothing in this Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101, et
seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA's
right of access, entry, inspection, and information gathering or PHMSA's authority to bring
enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.



7. For all transfers of ownership or operating responsibility of Respondent’s pipeline
system referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice of the
transfer to the Director no later than 60 days after the transfer occurs.
8. This Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a permit,
or a modification of any permit, under any Federal, State, or local laws or regulations. Respondent
remains responsible for achieving and maintaining compliance with all applicable Federal, State,
and local laws, regulations and permits.
9. This Agreement does not create rights in, or grant any cause of action to, any third
party not party to this Agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this Agreement. Respondent
agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents,
and representatives from any and all causes of action arising from any acts or omissions of
Respondent or its contractors in carrying out any work required by this Agreement.
10. Except as set forth herein, this Agreement does not constitute a finding of violation
of any other federal law or regulation and may not be used in any civil proceeding of any kind as
evidence or proof of any fact, fault, or liability, or as evidence of a violation of any law, rule,
regulation, or requirement, except in a proceeding to enforce the provisions of this Agreement or
in future PHMSA enforcement actions.
11. Agreement.
Respondent neither admits nor denies any allegation or conclusion in the Notice or
this Agreement but agrees for purposes of this Agreement to comply with the terms of this
II. Findings of Violation:
12. Item 1- 49 C.F.R. § 195.412(a): The Notice alleged that CRCT failed to satisfy the
requirements of § 195.412(a) by not using an appropriate method for inspecting the pipeline right-
of-way. Specifically, the Notice alleged that during the field inspection at the Hooser-Broome 8”
pipeline segment west of Bee Creek Valve (Lat. 37.053019, Long. -95.966233), PHMSA observed
that CRCT failed to adequately clear the right-of-way of tree cover, thereby preventing effective
aerial patrolling. Respondent did not contest the allegation in Item 1 of the Notice but provided
additional information to PHMSA and requested mitigation or elimination of the proposed civil
penalty. As such, PHMSA finds a violation of 49 C.F.R. § 195.412(a).
13. Item 2- 49 C.F.R. § 195.573: The Notice alleged that CRCT failed to satisfy the
Requirements of § 195.573(a)(1) by not performing cathodic protection testing on the protected
Shidler pipeline segment within the required interval of at least once each calendar year, but not
exceeding 15 months. Specifically, the Notice alleged that the Shidler cathodic protection test
surveys were conducted on February 28, 2018 and June 17, 2019, which exceeded the allowable
15-month interval by 20 days. Respondent did not contest the allegation in Item 2 of the Notice
but provided additional information to PHMSA and requested elimination of the proposed civil



penalty. As such, PHMSA finds a violation of 49 C.F.R. § 195.573(a)(1).
14. Item 3- 49 C.F.R. § 195.573(e): The Notice alleged that CRCT failed to satisfy the
Requirements of § 195.573(e) by failing to correct identified deficiencies in its corrosion control.
Specifically, the Notice alleged that during the inspection of corrosion control records, PHMSA
found that CRCT’s inspections in calendar years 2020 and 2021 for four of its steel breakout tanks
showed that the minimum protection criteria of NACE SP 0169 was not met as required by §
195.571. Respondent did not contest the allegation in Item 3 of the Notice but provided additional
information to PHMSA and requested mitigation of the proposed civil penalty. As such, PHMSA
finds a violation of 49 C.F.R. § 195.573(e).
15. Item 4- 49 C.F.R. § 195.581(a): The Notice alleged that CRCT failed to satisfy the
Requirements of § 195.581(a) by failing to provide protection against atmospheric corrosion by
cleaning and coating each pipeline or portion of pipeline that is exposed to the atmosphere.
Specifically, the Notice alleged that during PHMSA’s field inspection PHMSA observed severely
degraded and dis-bonded coating and large sections of rusted/corroded bare steel on exposed
portions of CRCT’s pipelines at six locations. Respondent did not contest the allegation in Item 4
of the Notice but provided additional information to PHMSA and requested mitigation of the
proposed civil penalty. As such, PHMSA finds a violation of 49 C.F.R. § 195.581(a).
16. Item 5- 49 C.F.R. § 195.589(c): The Notice alleged that CRCT failed to satisfy the
requirements of § 195.589(c) by failing to maintain records of cathodic protection surveys for
calendar years 2018 and 2019 for East Tank Farm breakout tanks 22A1, 22A2, 22A3 and Hooser
Tanks 25 and 270 due to a data processing error discovered in 2020. Specifically, the Notice
alleged that the device used by CRCT field personnel to capture cathodic protection readings had
unknown internal memory limitations, which resulted in the data being overwritten when
performing surveys across the system. Respondent did not contest the allegation in Item 5 of the
Notice but provided additional information to PHMSA and requested elimination of the proposed
civil penalty. As such, PHMSA finds a violation of 49 C.F.R. § 195.589(c).
17. Items 1, 2, 3, 4, and 5 will be considered by PHMSA as prior offenses in any future
PHMSA enforcement action taken against Respondent for the five (5)-year period following the
Effective Date of this Agreement.
III. Civil Penalty:
18. Item 1: The Notice proposed assessing a civil penalty in the amount of $24,200 for
Item 1. Respondent requested a reduction or elimination of the proposed civil penalty, and, with
its responses, provided new information and evidence to support its request. Respondent provided
evidence that CRCT found the non-compliance and took documented action to address the non-
compliance and was in the process of correcting the non-compliance before PHMSA learned of
the violation. Consequently, after consideration of the new information and evidence provided by
Respondent, PHMSA agrees a reduction of the civil penalty based on reconsideration of the
culpability assessment factor is appropriate, which results in a civil penalty of $0. Therefore,
PHMSA agrees to withdraw the proposed civil penalty for the violation in Item 1.



19. Item 2: The Notice proposed assessing a civil penalty in the amount of $24,200 for
Item 2. Respondent requested elimination of the proposed civil penalty based on three arguments:
that the repeat offense finding was inappropriate, that its post-violation actions should be taken
into consideration, and that COVID-19 made it difficult to comply with the regulation. PHMSA
finds that the repeat offense is appropriate, post-violation action is not considered in calculating
civil penalties, and per the March 20, 2020, Covid Stay of Enforcement and Notice of Enforcement
Discretion, operators had to promptly notify and disclose to PHMSA any non-compliance resulting
from COVID-19, which CRCT did not do. Therefore, no reduction of the civil penalty is
appropriate. Respondent agrees to pay a civil penalty of $24,200 for the violation of Item 2.
20. Item 3: The Notice proposed assessing a civil penalty in the amount of $70,700 for
Item 3. Respondent requested a reduction of the proposed civil penalty, and, with its responses,
provided new information and evidence to support its request. Respondent provided evidence that
CRCT found the non-compliance and took documented action to address the non-compliance and
was in the process of correcting the non-compliance before PHMSA learned of the violation.
Respondent also provided evidence that it had a reasonable justification for its non-compliance,
i.e., that it was using depolarization measurements to the cathodic protection readings to
demonstrate that a number of readings were in compliance with the NACE standard. Consequently,
after consideration of the new information and evidence provided by Respondent, PHMSA agrees
a reduction of the civil penalty based on reconsideration of the culpability and good faith
assessment factors is appropriate, which results in a civil penalty of $26,000. Respondent agrees
to pay a reduced civil penalty in the amount of $26,000 for the violation in Item 3.
21. Item 4: The Notice proposed assessing a civil penalty in the amount of $26,000 for
Item 4. Respondent requested a reduction of the proposed civil penalty based on an argument that
between the 2019 and 2022 inspections, it repaired the observed atmospheric corrosion prior to
the receipt of the Notice, and thus the good faith factor should be adjusted. PHMSA finds that
these actions were taken after PHMSA had already identified the violation and therefore are not
considered in calculating the civil penalty. In addition, Respondent failed to provide a reasonable
justification for its non-compliance, which is required for an adjustment of the good faith factor.
Therefore, no reduction of the civil penalty is appropriate. Respondent agrees to pay a civil penalty
of $26,000 for the violation in Item 4.
22. Item 5: The Notice proposed assessing a civil penalty in the amount of $1,800 for
Item 5. Respondent requested that PHMSA withdraw Item 5 as Respondent had addressed the
issue of record retention. PHMSA finds that the actions were taken after PHMSA had already
identified the violation and therefore are not considered in calculating the civil penalty. Therefore,
no reduction of the civil penalty is appropriate. Respondent agrees to pay a civil penalty in the
amount of $1,800 for Item 5.
23. Respondent agrees to pay an adjusted total civil penalty in the amount of $78,000,
pursuant to the payment instructions at 49 C.F.R. § 190.227(a), to be paid in full no later than 20
days from the Effective Date of this Agreement.



IV. Compliance Order:
24. Item 1: The Notice proposed certain compliance order actions to address the non-
compliance alleged in the Notice. Respondent provided supporting documents in its Response
demonstrating that Respondent has completed the proposed compliance terms for this Item.
Therefore, PHMSA agrees it is not necessary to include the proposed compliance terms for this
Item.
25. Item 3: The Notice proposed certain compliance order actions to address the non-
compliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order.
One of the steel tanks (Tank 270) identified and alleged to have been in non-compliance during
the inspection has been permanently removed from service. As such, Respondent agrees to perform
the following corrective measures:
A. In regard to Item 3 of the Notice pertaining to CRCT failing to correct identified
deficiencies in its corrosion control as required by § 195.401(b), CRCT must
provide to the Director, Central Region, records demonstrating cathodic protection
for the remaining three steel breakout tanks meet the minimum protection criteria
of NACE SP 0169 as required by § 195.571 within 180 days of receipt of the Final
Order.1
B. PHMSA requests that CRCT maintain documentation of the safety improvement
costs associated with fulfilling this Compliance Order and submit the total to the
Director, Central Region, Pipeline and Hazardous Materials Safety
Administration. It is requested that these costs be reported in two categories: 1)
total cost associated with preparation/revision of plans, procedures, studies and
analyses, and 2) total cost associated with replacements, additions and other
changes to pipeline infrastructure.2
26. Item 4: The Notice proposed certain compliance order actions to address the non-
compliance alleged in the Notice. Respondent provided supporting documents in its Response
demonstrating that Respondent has completed the proposed compliance terms for this Item.
Therefore, PHMSA agrees it is not necessary to include the proposed compliance terms for this
Item.
V. Enforcement:
27. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190, including administrative civil penalties
under 49 U.S.C. § 60122, of up to $257,664 per violation for each day the violation continues and
referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that
Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil
1 This Proposed Compliance Order term was originally term B in the Notice.
2 This Proposed Compliance Order term was originally term D in the Notice.



penalty amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223. All work plans and
associated schedules set forth or referenced in Section IV are automatically incorporated into this
Agreement and are enforceable in the same manner.
VI. Review and Approval Process:
28. With respect to any submission under Section IV (Compliance Order) of this
Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or
in part, the submission; (b) approve the submission on specified, reasonable conditions; (c)
disapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the
Director approves, approves in part, or approves with conditions, Respondent will take all actions
as approved by the Director, subject to Respondent’s right to invoke the dispute resolution
procedures with respect to any conditions the Director identifies. If the Director disapproves all or
any portion of the submission, the Director will provide Respondent a written notice of the
deficiencies. Respondent will correct all deficiencies within the time specified by the Director and
resubmit it for approval.
VII. Dispute Resolution:
29. The Director and Respondent will informally attempt to resolve any disputes arising
under this Agreement, including any decision of the Director under the terms of Section IV,
Compliance Order. If Respondent and the Director are unable to informally resolve the dispute
within 15 calendar days after the dispute is first raised, in writing, to the Director, Respondent may
submit a written request for a determination resolving the dispute from the Associate Administrator
for Pipeline Safety, PHMSA. Such request must be made in writing and provided to the Director,
counsel for the Central Region, and to the Associate Administrator for Pipeline Safety, no later
than 10 calendar days from the 15-day deadline for informal resolution referenced in this
paragraph. Along with its request, Respondent must provide the Associate Administrator with all
information Respondent believes is relevant to the dispute. Decisions of the Associate
Administrator under this paragraph will constitute final agency action. The existence of a dispute
and PHMSA’s consideration of matters placed in dispute will not excuse, toll, or suspend any term
or timeframe for completion of any work to be performed under this Agreement during the
pendency of the dispute resolution process.
VIII. Effective Date:
30. The term “Effective Date,” as used herein, is the date on which the Consent Order
is issued by the Associate Administrator, PHMSA, incorporating the terms of this Agreement.
IX. Recordkeeping and Information Disclosure:
31. Unless otherwise required in this Agreement, Respondent agrees to maintain
records demonstrating compliance with all requirements of this Agreement for a period of at least
five (5) years following completion of all work to be performed. For any reports, plans, or other
deliverables required to be submitted to PHMSA pursuant to this Agreement, Respondent may
assert a claim of business confidentiality or other protections applicable to the release of
information by PHMSA, covering part or all of the information required to be submitted to



PHMSA pursuant to this Agreement in accordance with 49 C.F.R. Part 7. Respondent must mark
the claim of confidentiality in writing on each page and include a statement specifying the grounds
for each claim of confidentially. PHMSA determines release of any information submitted
pursuant to this Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act,
5 U.S.C. § 552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.
X. Modification:
32. The terms of this Agreement may be modified by mutual agreement of the Parties.
Such modifications must be in writing and signed by both parties.
XI. Termination:
33. This Agreement will remain in effect until the Compliance Order in Section IV and
the Civil Penalty in Section III are satisfied, as determined by the Director. The Agreement shall
not terminate until the Director confirms, in writing, that the Agreement is terminated in
accordance with this paragraph. Nothing in this Agreement prevents Respondent from completing
any of the obligations earlier than the deadlines provided for in this Agreement.
XII. Ratification:
34. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Agreement and to execute and legally bind such party
to this document.
35. The Parties hereby agree to all findings, conditions, and terms of this Agreement.
[Signature Lines on Following Page]



For Coffeyville Resources Crude Transportation, LLC:
___________________________________
Keith Kuehn, Vice President Pipelines, Coffeyville Resources Crude Transportation, LLC
________________________
Date
For PHMSA:
________________________________________
Director, Central Region, Office of Pipeline Safety
________________________
Date

32023008NOPV_Closure Letter_03062024_(21-207275)_text.pdf

VIA ELECTRONIC MAIL TO: dllamp@cvrenergy.com; kakuehn@cvrenergy.com;
brecord@cvrenergy.com; rfmcgill@cvrenergy.com
March 6, 2024
David Lamp. President-Crude Transportation
Coffeyville Resources Crude Transportation, LLC
P.O. Box 3516
411 N.E. Washington Boulevard
Bartlesville, Oklahoma 74006
RE: CPF 3-2023-008-NOPV
Dear Mr. Lamp:
On January 2, 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Consent Agreement and Order in the above-referenced case. This Order included a Compliance
Order requirement to take corrective actions on your pipeline and a Civil Penalty assessment.
Based on our review of the documentation provided by Coffeyville Resources Crude
Transportation, LLC (“CRCT”)and confirmation of payment of the civil penalty on January 11,
2024, it has been determined that CRCT has complied with the terms of the Consent Agreement
and 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,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Keith Kuehn, VP-Crude Transportation, kakuehn@cvrenergy.com
Blake Record,, DOT Compliance Primary, brecord@cvrenergy.com
Ron McGill, DOT Compliance Primary, rfmcgill@cvrenergy.com
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