{"operation":"document","citation":"CPF 420125001W","title":"ROSE ROCK MIDSTREAM OPERATING, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-02-24","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(5), 195.452(f)(8).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420125001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420125001W","body":"Warning Letter involving ROSE ROCK MIDSTREAM OPERATING, LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(5),  195.452(f)(8). The case was opened on 2012-02-24 and is reported as closed as of 2012-02-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420125001W_Warning Letter_02242012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125001W/420125001W_Warning%20Letter_02242012.pdf\n\n420125001W_Warning Letter_02242012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420125001W/420125001W_Warning%20Letter_02242012_text.pdf\n\n420125001W_Warning Letter_02242012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 24, 2012\nMr. Pete Schwiering\nPresident of SemCrude\nSemGroup\n6120 S. Yale Ave.\nSuite 650\nTulsa, OK 74136\nCPF 4-2012-5001W\nDear Mr. Schwiering:\nOn November 14-19, 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nSemGroup procedures for Integrity Management in Oklahoma City, OK.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n\n\n\n(8) A process for review of integrity assessment results and information analysis by\na person qualified to evaluate the results and information (see paragraph (h)(2) of\nthis section).\n(g) What is an information analysis? In periodically evaluating the integrity of each\npipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the consequences\nof a failure. This information includes:\n(1) Information critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities, and\ndevelopment or planned development along the pipeline segment;\n(2) Data gathered through the integrity assessment required under this section;\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and cathodic\nprotection surveys; and\n(4) Information about how a failure would affect the high consequence area, such as\nlocation of the water intake.\nSemGroup did not provide information at the time of the inspection to demonstrate\ndocumentation of data integration for the 2007 KS-OK pipeline inline inspection tool\nassessment. There was no documentation of conclusions drawn from results of this\nintegrity assessment. It was not determinable if the process for review of integrity\nassessment results and information analysis by a person qualified to evaluate the results\nand information had been completed in this case.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n2\n\n\n\n(5) A continual process of assessment and evaluation to maintain a pipeline's\nintegrity (see paragraph (j) of this section);\n(8) A process for review of integrity assessment results and information analysis by\na person qualified to evaluate the results and information (see paragraph (h)(2) of\nthis section).\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(5) Assessment methods. An operator must assess the integrity of the line pipe by\nany of the following methods. The methods an operator selects to assess low\nfrequency electric resistance welded pipe or lap welded pipe susceptible to\nlongitudinal seam failure must be capable of assessing seam integrity and of\ndetecting corrosion and deformation anomalies.\n(i) Internal inspection tool or tools capable of detecting corrosion and deformation\nanomalies including dents, gouges and grooves;\n(ii) Pressure test conducted in accordance with subpart E of this part;\n(iii) External corrosion direct assessment in accordance with § 195.588; or\n(iv) Other technology that the operator demonstrates can provide an equivalent\nunderstanding of the condition of the line pipe. An operator choosing this option\nmust notify OPS 90 days before conducting the assessment, by sending a notice to\nthe address or facsimile number specified in paragraph (m) of this section.\nSemGroup did not provide a documented engineering analysis for susceptibility to seam failure\nfor the KS-OK line. The KS-OK pipeline experienced two failures associated with the seam\nwhen the line was hydrostatically tested in 2002. Determining susceptibility to seam failure is\nnecessary to choose the appropriate assessment techniques and assessment intervals. The line\nwas re-assessed in 2007; however, the specimen failure analysis did not appear to have been\nconsidered in the planning of that assessment. SemGroup provided information that the failure\nspecimens were sent for metallurgical analysis to determine the root cause and contributing\nfactors of the test failures, but these metallurgical analyses’ were unsound because none of the\noriginal fracture surfaces remained due to corrosion after the specimens were exposed to the\nelements for four years prior to being submitted for metallurgical analysis. Since the KS-OK\nline operates above 30% SMYS an engineering analysis should be documented for its\nsusceptibility to seam failure.\n3\n\n\n\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in SemGroup 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 4-2012-5001W. 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,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials\nSafety Administration\n4","truncated":false,"body_characters":7795}