{"operation":"document","citation":"CPF 32024034NOA","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-04-12","effective_on":null,"summary":"CLOSED notice of amendment citing 192.506(a)(4), 192.607(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024034noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024034noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024034noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024034NOA","body":"Notice of Amendment involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.506(a)(4),  192.607(c). The case was opened on 2024-04-12 and is reported as closed as of 2024-12-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024034NOA_Closure Letter_12172024_(23-270170).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024034NOA/32024034NOA_Closure%20Letter_12172024_(23-270170).pdf\n\n32024034NOA_Closure Letter_12172024_(23-270170)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024034NOA/32024034NOA_Closure%20Letter_12172024_(23-270170)_text.pdf\n\n32024034NOA_Notice of Amendment_04122024_(23-270170).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024034NOA/32024034NOA_Notice%20of%20Amendment_04122024_(23-270170).pdf\n\n32024034NOA_Notice of Amendment_04122024_(23-270170)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024034NOA/32024034NOA_Notice%20of%20Amendment_04122024_(23-270170)_text.pdf\n\n32024034NOA_Operator Response to Notice_05092024_(23-270170).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024034NOA/32024034NOA_Operator%20Response%20to%20Notice_05092024_(23-270170).pdf\n\n32024034NOA_Notice of Amendment_04122024_(23-270170)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: matt@tallgrass.com;\ncrystal.heter@tallgrassenergylp.com; danielle.stephens@tallgrass.com\nApril 12, 2024\nMr. Matt Sheehy\nChief Executive Officer\nTallgrass Energy, L.P.\n4200 W. 115th St. Suite 350\nLeawood, KS 66211\nCPF 3-2024-034-NOA\nDear Mr. Sheehy:\nFrom May 22 to June 8, 2023, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nTallgrass Energy, L.P.’s (Tallgrass) procedures for the new gas integrity rule1 in Lakewood,\nColorado.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nTallgrass’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 192.506 Transmission lines: Spike hydrostatic pressure test.\n(a) Spike test requirements. Whenever a segment of steel transmission pipeline that\nis operated at a hoop stress level of 30 percent or more of SMYS is spike tested\nunder this part, the spike hydrostatic pressure test must be conducted in accordance\nwith this section.\n(1) ….\n(4) After the test pressure stabilizes at the baseline pressure and within the first 2\nhours of the 8-hour test interval, the hydrostatic pressure must be raised (spiked) to\na minimum of the lesser of 1.5 times MAOP or 100% SMYS. This spike hydrostatic\npressure test must be held for at least 15 minutes after the spike test pressure\nstabilizes.\n1 Docket No. PHMSA–2011–0023; Amdt. Nos. 191–26; 192–125 Pipeline Safety: Safety of Gas Transmission\nPipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments (86\nFed. Reg. 63266 (Nov. 15, 2021)).\n\n\n\nTallgrass’ procedure, entitled “OM1600_GL Strength and Leak Testing” (O&M Procedure),\nreferenced a form that did not indicate the correct time for holding the spike hydrotest nor did it\nreference the option to go to 1.5 times the maximum allowable operating pressure (MAOP).\nO&M Form OM1600_01 GL (O&M Form) which is referenced in O&M Procedure section 6.1.1\nis the form Tallgrass requires to be filled out to document the test. However, the O&M Form\nindicated that the spike test was typically from 10 to 30 minutes and did not reference the option\nto go to 1.5 times the MAOP. Although section 4.1.1 of the O&M Procedure indicated the\ncorrect time frame for the spike test hold and also included the 1.5 times the MAOP option, the\nO&M Form must be revised to match Tallgrass’s procedure and the requirements of §\n192.506(a)(4).\n2. § 192.607 Verification of Pipeline Material Properties and Attributes: Onshore steel\ntransmission pipelines.\n(a)….\n(c) Verification of material properties and attributes. If an operator does not have\ntraceable, verifiable, and complete records required by paragraph (b) of this\nsection, the operator must develop and implement procedures for conducting\nnondestructive or destructive tests, examinations, and assessments in order to verify\nthe material properties of aboveground line pipe and components, and of buried line\npipe and components when excavations occur at the following opportunities:\nAnomaly direct examinations, in situ evaluations, repairs, remediations,\nmaintenance, and excavations that are associated with replacements or relocations\nof pipeline segments that are removed from service.\nTallgrass’ procedure “SOP-AI9” section 2.1.5, which is referenced in Tallgrass’ procedure\n“OM_210G Material Verification,” did not contain enough guidance for verifying the material\nproperties of buried line pipe and components when excavations occur. Specifically, section\n2.1.5 did not contain a process detailing how Tallgrass would coordinate between the field\npersonnel and the integrity personnel to verify pipe data at planned excavations\nopportunistically. Additionally, during PHMSA’s inspection, Tallgrass personnel indicated that\nTallgrass defined opportunistic digs as “opportunities to gather information from the same\nexcavation.” Section 2.1.5 did not include this as part of Tallgrass’s description of opportunistic\ndigs and it should be expanded to better reflect that.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\n\n\n\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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 amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested that Tallgrass maintain documentation of the safety improvement costs associated\nwith fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit\nthe total to Gregory A. Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 3-2024-034-NOA\nand, for each document you submit, please provide a copy in electronic format whenever\npossible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Danielle Stephens , DOT Compliance Primary, Tallgrass Energy, L.P.,\nDanielle.Stephens@tallgrass.com;\nCrystal Heter, Chief Operating Officer, Tallgrass Energy, L.P.,\ncrystal.heter@tallgrassenergylp.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n32024034NOA_Closure Letter_12172024_(23-270170)_text.pdf\n\nVIA ELECTRONIC MAIL TO: matt.sheehy@tallgrass.com; crystal.heter@tallgrassenergylp.com;\ndanielle.stephens@tallgrass.com; kale.stanton@tallgrassenergylp.com\nDecember 17, 2024\nMr. Matt Sheehy\nChief Executive Officer\nTallgrass Energy, L.P.\n4200 W. 115th St. Suite 350\nLeawood, KS 66211\nRE: CPF 3-2024-043-NOA\nDear Mr. Sheehy:\nFrom May 22 to June 8, 2023, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\nconducted an on-site inspection of Tallgrass Energy L.P.’s (Tallgrass) procedures for the new\ngas integrity rule in Lakewood, Colorado. As a result of the inspection, Tallgrass was issued a\nNotice of Amendment on April 12, 2024, which proposed amendment of your procedures.\nTallgrass submitted its amended procedures on May 9, 2024. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed.\nThank you for your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Danielle Stephens , DOT Compliance Primary, Tallgrass Energy, L.P.,\nDanielle.Stephens@tallgrass.com;\nCrystal Heter, Chief Operating Officer, Tallgrass Energy, L.P.,\ncrystal.heter@tallgrassenergylp.com","truncated":false,"body_characters":9666}