# OSAGE PIPE LINE COMPANY, LLC — Safety Order

- **operation:** document
- **citation:** CPF 42022055NOPSO
- **title:** OSAGE PIPE LINE COMPANY, LLC — Safety Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2022-08-12
- **effective on:** Not available
- **summary:** CLOSED safety order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42022055nopso.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42022055nopso.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42022055nopso
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42022055NOPSO
**body:**

Safety Order involving OSAGE PIPE LINE COMPANY, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2022-08-12 and is reported as closed as of 2026-05-11. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42022055NOPSO_Closure Letter_05112026_(22-248385).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022055NOPSO/42022055NOPSO_Closure%20Letter_05112026_(22-248385).pdf

42022055NOPSO_Closure Letter_05112026_(22-248385)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022055NOPSO/42022055NOPSO_Closure%20Letter_05112026_(22-248385)_text.pdf

42022055NOPSO_Consent Agreement and Order_10192022_(22-248385).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022055NOPSO/42022055NOPSO_Consent%20Agreement%20and%20Order_10192022_(22-248385).pdf

42022055NOPSO_Consent Agreement and Order_10192022_(22-248385)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022055NOPSO/42022055NOPSO_Consent%20Agreement%20and%20Order_10192022_(22-248385)_text.pdf

42022055NOPSO_Notice of Proposed Safety Order_08122022_(22-248385).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022055NOPSO/42022055NOPSO_Notice%20of%20Proposed%20Safety%20Order_08122022_(22-248385).pdf

42022055NOPSO_Notice of Proposed Safety Order_08122022_(22-248385)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42022055NOPSO/42022055NOPSO_Notice%20of%20Proposed%20Safety%20Order_08122022_(22-248385)_text.pdf

42022055NOPSO_Notice of Proposed Safety Order_08122022_(22-248385)_text.pdf

VIA E-MAIL TO: richard.voliva@hollyenergy.com
August 12, 2022
Richard Voliva
President
Holly Energy Partners, L.P.
2828 North Harwood Street, Suite 1300
Dallas, Texas 75201
CPF 4-2022-055-NOPSO
Dear Mr. Voliva:
Enclosed is a Notice of Proposed Safety Order (Notice) issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA) in the above-referenced case. The Notice proposes
that Osage Pipe Line Company, LLC take certain measures with respect to its 20-inch crude oil
Osage pipeline. The options for responding are set forth in the Notice. Service of this Notice by
electronic mail is deemed effective upon the date of transmission, or as otherwise provided under
49 C.F.R. § 190.5.
We look forward to a successful resolution to ensure pipeline safety. Please direct any questions
on this matter to me at 713-272-2847.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Notice of Proposed Safety Order
Copy of 49 C.F.R. § 190.239
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, PHMSA
Ms. Lori Coupland, Vice President, Compliance and EHS, Holly Energy Partners, LP,
lori.coupland@hollyenergy.com



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
SOUTHWEST REGION
HOUSTON, TX 77074
_________________________________________ )
In the Matter of )
Osage Pipe Line Company, LLC, ) CPF No. 4-2022-055-NOPSO
a subsidiary of Holly Energy Partners, LP )
)
)
Respondent. )
_________________________________________ )
NOTICE OF PROPOSED SAFETY ORDER
Background and Purpose:
Pursuant to Chapter 601 of Title 49, United States Code, the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the
safety of Osage Pipe Line Company, LLC’s (Osage) 136-mile, 20-inch crude oil pipeline (Osage
Pipeline) that originates in Cushing, Oklahoma, and terminates in El Dorado, Kansas following an
accident that occurred on July 8, 2022.
At approximately 12:29 a.m. CDT on July 8, 2022, Osage’s control room reported a loss of suction
on the 20-inch crude oil Osage pipeline. At 12:30 a.m., the control room received a leak alarm,
however both the shift foreman and controller were on a break and did not notice the alarm. At
12:40 a.m., the controller attempted to restart the pipeline, and the control center received a third
leak alarm. At 12:43 am, the line was shut down and block valves were closed. Control room
personnel blocked in the pig trap at the Cushing pump station and closed the South Cimarron valve,
contacted the manager of pipeline operations, then blocked in all river crossings on the Osage
pipeline.
Osage dispatched a technician to the Cushing pump station who reported no sign of a release at
2:26 a.m. An hour later, the technician reported signs of hydrocarbon on the ground and in and
around Skull Creek, a tributary of the Cimarron River, and the operator confirmed discovery of
the accident. Osage originally estimated a release of 1,001-barrels (bbls) of crude oil. As of
August 3, 2022, Osage has recovered approximately 5,700 bbls of crude oil and 12,020 bbls of
water and oil. The crude oil released onto land and reached Skull Creek. The release migrated
about 0.75 miles northeast of the accident location.
As a result of the preliminary investigation, it appears that conditions exist on the Osage Pipeline
that pose an integrity risk to public safety, property, or the environment. Accordingly, pursuant to
49 U.S.C. § 60117, PHMSA OPS issues this Notice of Proposed Safety Order (Notice), notifying



you of the preliminary findings of the investigation, and proposing that you take certain measures
to ensure that the public, property, and the environment are protected from this integrity risk.
Preliminary Findings:
The preliminary findings of PHMSA’s ongoing investigation are as follows:
• Osage operates a 136-mile, 20-inch crude oil pipeline (Osage Pipeline) that originates at a
pump station in Cushing, Oklahoma, and terminates in El Dorado, Kansas. There are three
intermediate pump stations along the pipeline (Ralston, Hardy, and Wilmont). At the
termination point, the pipeline connects with a tank farm owned by Holly Energy Partners
- Operating, L.P. This 11-tank farm has a total capacity of 1.1 million barrels.
• On July 8, 2022, at 12:29 a.m. CDT, Osage’s control room reported a loss of suction on
the Osage Pipeline. Osage confirmed discovery of the leak at 3:26 am after observing
hydrocarbons on the ground in and around Skull Creek. As of August 8, 2022, Osage
estimated a release of 5,700 bbls of crude oil and 12,020 bbls of water and oil. There were
no injuries or fatalities.
• The Osage Pipeline released crude oil onto land and into a creek in a remote area of
Cushing, Oklahoma on the tribal land of the Sac and Fox Nation. Additionally, the oil
reached Skull Creek, a tributary of Cimmaron River. The release migrated about 0.75
miles northeast of the accident location.
• After the accident, Osage voluntarily provided a restart and repair plan to the Southwest
Region, OPS. After review and approval by the SWR, the pipeline resumed operation under
a 20% pressure reduction restriction (660 psi) on July 17, 2022.
• Although the root cause of the failure has yet to be confirmed, preliminary evidence
suggests that longitudinal seam failure is the probable cause of the failure. During the
repair process, Osage had to dig back and expose more pipe to find an area acceptable to
perform the cut to install a pipe replacement segment due to crack-like features in the weld.
At this time, Osage is performing additional testing and analysis to identify the potential
threats to the safe operations of its pipeline.
• The 20-inch crude oil steel pipeline was installed in 1975. Its maximum operating pressure
(MOP) is 1,080 psi. At the time of the accident, the operating pressure was 825 psi. The
Osage Pipeline is coated with coal tar enamel and has an impressed current cathodic
protection system.
• The pipeline has experienced four previous releases on this unit since 2002. Two were
caused by internal corrosion and two were caused by material failures.
• In 2014, Magellan Midstream Partners, L.P. (Magellan), the previous operator, conducted
an In-Line Inspection (ILI) using a T.D. Williamson (TDW) Magnetic Flux Leakage



Circumferential (MFL-C) tool. The ILI reported 85 seam variation anomalies. TDW
classified the 85 seam variations as “Other anomalies” in the final report and described
them as “[n]on-detrimental irregularit[ies] due to the manufacturing of the seam weld.” In
2016, Osage purchased the pipeline from Magellan. In 2018, Osage performed an ILI of
the pipeline using an Enduro tool. Osage determined during the post-accident examination
that one of the reported seam variation anomalies was in the area of the failure location.
• Osage contacted the previous ILI vendor, TDW, to request a reassessment of the 2014 data
to find defects similar to those of the accident site. TDW claims, that with the benefit of
an improved analysis process, they have reclassified 54 of the original 85 anomalies as
“Axial Planar” features with depths ranging from 10-36% wall thickness.
• On July 15, 2022, Osage received the reassessment from TDW. Based upon proximity to
upstream pump stations (ten miles or less), and percent of anomaly depth (greater than
twenty percent wall thickness), Osage chose to do validation digs at six locations for nine
axial planar anomalies. On July 25, 2022, Osage began the validation digs.
• On August 5, 2022, Osage completed an ILI run using a Xylem smart ball ILI tool along
the Osage Pipeline route to assist Osage in obtaining pressure and temperature data for the
entire line to confirm the absence of small leaks and improve their hydraulic modeling.
• Osage plans to perform two additional inspections with Baker Hughes (BH) ILI tools
starting mid to late August 2022 with an Ultra Sonic crack tool, followed by High
Resolution MFL/Caliper/Inertial Measuring Unit combination tool.
• Osage sent the failed joint of pipe and a contiguous joint to a Quest Integrity metallurgical
laboratory for further analysis.
Proposed Issuance of Safety Order:
Section 60117(m) of Title 49, United States Code, provides for the issuance of a Safety Order
(Order), after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include physical inspection, testing, repair, replacement, or other action, as appropriate.
The basis for making the determination that a pipeline facility has a condition or conditions that
pose a pipeline integrity risk to public safety, property, or the environment is set forth both in the
above-referenced statute and 49 C.F.R. § 190.239, a copy of which is enclosed.
After evaluating the foregoing preliminary findings of fact and considering the hazardous nature
of the product, the unknown cause of the failure, the identification of additional anomalies that
may be similar to the failed anomaly, the characteristics of the geographical area of the pipeline,
including its proximity to Tribal lands, and the likelihood that the additional weld issues exist
throughout the 136-mile pipeline, it appears that continued operation of the Osage Pipeline without



corrective measures may pose an integrity risk to public safety, property, or the environment.
Accordingly, PHMSA issues this Notice to notify Osage of the proposed issuance of an Order and
to propose that Osage take measures specified herein to address the potential risks identified in the
Preliminary Findings and other risks that may be determined as a result of the proposed corrective
measures.
Proposed Corrective Actions:
Pursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue to Osage
Pipe Line Company, LLC a Safety Order incorporating the following remedial requirements with
respect to its Osage Pipeline that originates in Cushing, Oklahoma and terminates in El Dorado,
Kansas:
Note: For the purposes of this Notice, “Director” means the Director, Southwest Region,
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety,
8701 S. Gessner, Suite 630, Houston, Texas, 77074.
Definitions:
Affected Pipeline – The “Affected Pipeline” means Osage’s entire 136 mile 20-inch pipeline
that originates in Lincoln County, Oklahoma and terminates in El Dorado, Kansas, where it
connects with Holly Energy Partners – Operating, L.P.
1. Operating Pressure Restriction. Osage must maintain a twenty percent (20%) pressure
reduction in the actual operating pressure along the entire length of the Affected
Pipeline such that the Affected Pipeline will not exceed eighty percent (80%) of the
actual operating pressure in effect at the failure location immediately prior to the failure
on July 8, 2022.
a. This pressure restriction will remain in effect until written approval to increase the
pressure or return the pipeline to its pre-failure operating pressure is obtained from
the Director.
b. Within 15 days of receipt of this Order, Osage must provide the Director the actual
operating pressures of the Cushing, Ralston, Hardy, and Wilmont pump stations at
the time of failure and the reduced pressure restriction set-points at these same
locations.
c. This pressure restriction requires any relevant remote or local alarm limits, software
programming set-points or control points, and mechanical over-pressure devices to
be adjusted accordingly.
d. When determining the pressure restriction set-points, Osage must consider any in-
line inspection (ILI) features or anomalies present in the Affected Pipeline to
provide for continued safe operation while further corrective actions are completed.



e. Osage must review the pressure restriction monthly by analyzing the operating
pressure data, taking into account any ILI features or anomalies present in the
Affected Pipeline. Osage must immediately reduce the operating pressure further
to maintain the safe operations of the Affected Pipeline, if warranted by the monthly
review.
f. The Director may allow the temporary removal or modification of the pressure
restriction upon a written request from Osage demonstrating that temporary
mitigative and preventive measures are implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director’s
determination will be based on available information, including the failure cause
and evidence that preventative and mitigative actions taken by the operator provide
for the safe operation of the Affected Pipeline during the temporary removal or
modification of the pressure restriction. Appeals to determinations of the Director
in this regard will be decided by the Associate Administrator for Pipeline Safety.
2. Review of Prior In-line Inspection (ILI) Results. Within 30 days of receipt of this
Order, Osage must conduct a review of any previous ILI results of the Affected
Pipeline. In its review, Osage must re-evaluate all ILI results from the past 10 calendar
years, including a review of the ILI vendors’ raw data and analysis. Osage must
determine whether prior ILI runs indicated any anomalies at the failure location. Also,
Osage must determine if any features with similar characteristics are present elsewhere
on the Affected Pipeline. Osage must submit documentation of this ILI review to the
Director within 45 days of receipt of this Order as follows:
a. List all ILI tool runs, tool types, and the calendar years of the tool runs.
b. List, describe (type, size, wall loss, etc.), and identify the specific location of all
ILI features present in the failed joint and other pipe removed.
c. List, describe (type, size, wall loss, etc.), and identify the specific location of all
ILI features with similar characteristics present elsewhere on the Affected Pipeline.
d. Explain the process used to review the ILI results and the results of the reevaluation.
3. Mechanical and Metallurgical Testing. Within 45 days of receipt of this Order, Osage
must complete mechanical and metallurgical testing and failure analysis of the failed
pipe, including an analysis of soil samples and any foreign materials. Mechanical and
metallurgical testing must be conducted by the previously approved independent third-
party. Osage must complete the testing and analysis and ensure the testing laboratory
distributes all reports whether draft or final in their entirety to the Director at the same
time they are made available to Osage.
4. Root Cause Failure Analysis. Within 90 days following receipt of this Order, Osage
must complete a root cause failure analysis (RCFA) and submit a final report of this
RCFA to the Director. The RCFA must be supplemented or facilitated by an
independent third-party approved by the Director. The RCFA must document the
decision-making process and all factors contributing to the failure. The final report
must include findings and any lessons learned and whether the findings and lessons
learned are applicable to other locations within Osage’s pipeline system.



5. Remedial Work Plan (RWP).
a. Within 90 days following receipt of this Order, Osage must submit a remedial work
plan (RWP) to the Director for approval.
b. The Director may approve the RWP incrementally without approving the entire
RWP.
c. Once approved by the Director, the RWP will be incorporated by reference into
this Order.
d. The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures Osage will use to verify the integrity of the Affected Pipeline.
It must address all known or suspected factors and causes of the July 8, 2022,
failure. Osage must consider the risks and consequences of another failure to
develop a prioritized schedule for RWP- related work along the Affected Pipeline.
e. The RWP must include a procedure or process to:
i. Identify pipe in the Affected Pipeline with characteristics similar to the
contributing factors identified for the July 8, 2022, failure.
ii. Gather all data necessary to review the failure history (in service and
pressure test failures) of the Affected Pipeline and to prepare a written report
containing all the available information such as the locations, dates, and
causes of leaks and failures.
iii. Integrate the results of the metallurgical testing, root cause failure analysis,
and other corrective actions required by this Order with all relevant pre-
existing operational and assessment data for the Affected Pipeline. Pre-
existing operational data includes, but is not limited to, design, construction,
operations, maintenance, testing, repairs, prior metallurgical analyses, and
any third-party consultation information. Pre-existing assessment data
includes, but is not limited to, ILI tool runs, hydrostatic pressure testing,
direct assessments, close interval surveys, and DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to the failure on July
8, 2022, are likely to exist elsewhere on the Affected Pipeline.
v. Conduct additional field tests, inspections, assessments, and evaluations to
determine whether, and to what extent, the conditions associated with the
failure on July 8, 2022, and other failures from the failure history (see (e)(ii)
above) or any other integrity threats are present elsewhere on the Affected
Pipeline. At a minimum, this process must consider all failure causes and
specify the use of one or more of the following:
1) ILI tools that are technically appropriate for assessing the pipeline
system based on the cause of failure on July 8, 2022, and that can
reliably detect and identify anomalies;
2) Hydrostatic pressure testing;
3) Close-interval surveys;
4) Cathodic protection surveys, to include interference surveys in



coordination with other utilities (e.g. underground utilities, overhead
power lines, etc.) in the area;
5) Coating surveys;
6) Stress corrosion cracking surveys;
7) Selective seam corrosion surveys; and
8) Other tests, inspections, assessments, and evaluations
appropriate for the failure causes.
Note: Osage may use the results of previous tests, inspections,
assessments, and evaluations if approved by the Director, provided the
results of the tests, inspections, assessments, and evaluations are
analyzed with regard to the factors known or suspected to have caused
the July 8, 2022, failure.
vi. Describe the inspection and repair criteria Osage will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other identified
integrity threats. Include a description of how any defects will be graded
and a schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Pipeline, describe
the methods Osage will use to repair, replace, or take other corrective
measures to remediate the conditions associated with the pipeline failure on
July 8, 2022, and to address other known integrity threats along the Affected
Pipeline. The repair, replacement, or other corrective measures must meet
the criteria specified in (e)(vi) above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Pipeline
considering the results of the analyses, inspections, evaluations, and
corrective measures undertaken pursuant to the Order.
f. Include a proposed schedule for completion of the RWP.
g. Osage must revise the RWP as necessary to incorporate new information obtained
during the failure investigation and remedial activities, to incorporate the results of
actions undertaken pursuant to this Order, and to incorporate modifications required
by the Director.
h. Submit any plan revisions to the Director for prior approval, the Director may
approve plan revisions incrementally as needed.
i. Implement the RWP as it is approved by the Director, including any revisions to
the plan.
Other Requirements:
6. Approvals. With respect to each submission that under this Order requires the approval
of the Director, the Director may: (a) approve, in whole or part, the submission; (b)
approve the submission on specified conditions; (c) modify the submission to cure any



deficiencies; (d) disapprove in whole or in part, the submission, directing that
Respondent modify the submission, or (e) any combination of the above. In the event
of approval, approval upon conditions, or modification by the Director, Respondent
shall proceed to take all action required by the submission as approved or modified by
the Director. If the Director disapproves all or any portion of the submission,
Respondent must correct all deficiencies within the time specified by the Director and
resubmit it for approval.
7. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Order upon a written request timely submitted demonstrating
good cause for an extension.
8. Reporting. Submit quarterly reports to the Director that: (1) include all available data
and results of the testing and evaluations required by this Order; and (2) describe the
progress of the repairs or other remedial actions being undertaken. The first quarterly
report is due on September 30, 2022. The Director may change the interval for the
submission of these reports.
9. Documentation of the Costs. It is requested that Respondent maintain documentation
of the costs associated with implementation of this Notice of Proposed Safety Order.
Include in each monthly report submitted, the to-date total costs associated with: (1)
preparation and revision of procedures, studies and analyses; (2) physical changes to
pipeline infrastructure, including repairs, replacements and other modifications; and
(3) environmental remediation, if applicable.
The actions proposed by this Notice are in addition to, and do not waive, any requirements that
apply to Osage’s pipeline facilities under 49 C.F.R. Parts 190 through 199, under any other order
issued to Osage under the authority of 49 U.S.C. § 60101 et seq., or under any other provision of
federal or state law.
After receiving and analyzing additional data in the course of this proceeding, PHMSA may
identify other corrective measures that the Osage must perform. In that event, Osage will be
notified of any additional measures required and any amendments to the final Safety Order. To
the extent consistent with safety, Osage will be afforded notice and an opportunity for a hearing
prior to the imposition of any additional corrective measures.
Response to this Notice:
In accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written
response to the Director. If you do not respond within 30 days, this constitutes a waiver of your
rights to contest this Notice and authorizes the Associate Administrator for Pipeline Safety to find
facts as alleged in this Notice without further notice to you and to issue a final Safety Order. In
your response, you may indicate that you intend to comply with the terms of the Notice as
proposed, or you may request that an informal consultation be scheduled (you will also have the
opportunity to request an administrative hearing before a final Safety Order is issued). Informal
consultation provides you with an opportunity to explain the circumstances associated with the
risk conditions alleged in the Notice and, as appropriate, to present a proposal for a work plan or
other remedial measures without prejudice to your position in any subsequent hearing.



If you and PHMSA agree within 30 days of the informal consultation on a plan and schedule for
you to address each identified risk condition, the parties may enter into a written consent
agreement, in which case PHMSA would then issue an administrative Consent Order incorporating
the terms of the agreement. If a consent agreement is not reached, or if you have elected not to
request informal consultation, you may request an administrative hearing in writing within 30 days
following receipt of the Notice or within 10 days following the conclusion of an informal
consultation that did not result in a consent agreement, as applicable. Following a hearing, if the
Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to
the public, property, or the environment in accordance with § 190.239, the Associate Administrator
may issue a final Safety Order.
Be advised that all material submitted in response to this enforcement action is subject to public
availability. If you believe that any portion of your responsive material qualifies for confidential
treatment under 5 U.S.C. § 552(b), along with the complete original document, you must provide
a second copy of the document with the portions you believe qualify for confidential treatment
redacted and an explanation of why you believe the redacted information qualifies for confidential
treatment under 5 U.S.C. § 552(b).
In your correspondence on this matter, please refer to CPF 4-2022-055-NOPSO, and for each
document you submit, please provide a copy in electronic format whenever possible.
_________________________________ _____________________
Mary L. McDaniel, P.E. Date Issued
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration

42022055NOPSO_Consent Agreement and Order_10192022_(22-248385)_text.pdf

October 19, 2022
VIA ELECTRONIC MAIL TO: richard.voliva@hollyenergy.com
Richard Voliva
President
Holly Energy Partners, L.P.
2828 North Harwood Street, Suite 1300
Dallas, Texas 75201
Re: CPF 4-2022-055-NOPSO
Dear Mr. Voliva:
Enclosed please find a Consent Order incorporating the terms of the fully executed Consent
Agreement between the Pipeline and Hazardous Materials Safety Administration (PHMSA) and
Osage Pipe Line Company, LLC, which was executed on October 19, 2022. Service of the Consent
Order and Consent Agreement by e-mail is deemed effective upon the date of transmission, 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
Enclosures: Consent Order and Consent Agreement
cc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Rob Jamieson, VP of Operations, Holly Energy Partners, LP,
robert.jamieson@hollyenergy.com
Ms. Lori Coupland, Vice President, Compliance and EHS, Holly Energy Partners, LP,
lori.coupland@hollyenergy.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 )
Osage Pipe Line Company, LLC, ) CPF No. 4-2022-055-NOPSO
a subsidiary of Holly Energy Partners, LP, )
)
)
)
Respondent. )
__________________________________________)
CONSENT ORDER
By letter dated August 12, 2022, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety, issued a Notice of Proposed Safety Order (Notice) to Osage
Pipe Line Company, LLC, a subsidiary of Holly Energy Partners, LP.
In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist on the Osage
Pipeline that pose an integrity risk to public safety, property, or the environment. The Notice also
proposed that Respondent take certain corrective measures to remedy the alleged conditions and
ensure that the public, property, and the environment are protected from the potential risk.
In response to the Notice, Respondent requested an informal consultation, whereupon the parties
engaged in good-faith settlement discussions that have resulted in the Consent Agreement attached
to this Consent Order that settles all of the allegations in the Notice.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order. The Respondent is hereby ordered to comply with the terms of the Consent
Agreement, effective immediately.
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 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.
October 19, 2022
_____________________________ ________________________
Alan K. Mayberry Date
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 )
Osage Pipe Line Company, LLC, ) CPF No. 4-2022-055-NOPSO
a subsidiary of Holly Energy Partners, LP, )
)
)
)
Respondent. )
__________________________________________)
CONSENT AGREEMENT
On August 12, 2022, pursuant to 49 C.F.R. § 190.239, the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety, Southwest Region, issued a Notice of
Proposed Safety Order (Notice) to Osage Pipe Line Company, LLC, a subsidiary of Holly Energy
Partners, (Osage or Respondent). The Notice was issued after a reportable accident1 occurred on
July 8, 2022, on Osage’s 136-mile, 20-inch crude oil pipeline (Osage Pipeline) that originates in
Cushing, Oklahoma, and terminates in El Dorado, Kansas.
At approximately 12:29 a.m. CDT on July 8, 2022, Osage’s control room reported a loss of suction
at the Cushing pump station on the 20-inch crude oil Osage pipeline, and the Cushing pump station
automatically shut down. At 12:30 a.m., the control room received a leak alarm, however both the
shift foreman and controller were on a break and did not notice the alarm. The downstream Ralston
Pump Station shut down automatically at 12:30 a.m. and the Hardy Pump Station shut down
automatically at 12:32 a.m. Other controllers in the control room noticed the leak alarm and a
senior controller phoned the upstream shipper at 12:33 a.m. to request that it shut down the booster
pump feeding the Cushing mainline pump, which the shipper then did. The control room received
a second leak alarm at 12:35 a.m. The Osage controller and shift foreman then returned and
investigated the cause of the loss of suction. At 12:40 a.m., the controller and shift foreman
attempted to restart the Cushing mainline pump, and the control center received a third leak alarm.
At 12:43 a.m., the controller shut down the line and began the block in sequence. As part of this
process, control room personnel blocked in the pig trap at the Cushing pump station and closed
the South Cimarron valve, contacted the manager of pipeline operations, then blocked in all river
crossings on the Osage Pipeline.
Osage dispatched a technician to the Cushing pump station at 12:50 a.m. who reported no sign of
a release at 2:26 a.m. The technician began to move down the line, and an hour later, the technician
reported signs of hydrocarbon on the ground in and around Skull Creek, a tributary of the Cimarron
River, and the operator confirmed discovery of the accident. On July 8, 2022, Osage originally
estimated a release of 1,001-barrels (bbls) of crude oil. On August 5, 2022, Osage reported the
1 See 49 C.F.R. § 195.50.



estimated volume of commodity released on Form PHMSA F 7000-1 as 5,769 bbls and noted that
the total volume may range between 6,000 to 8,000 bbls. The crude oil released onto land and
reached Skull Creek. The release migrated about 0.75 miles northeast of the accident location.
As a result of a preliminary investigation, PHMSA issued the Notice, which alleged that conditions
exist on the Osage Pipeline that pose a pipeline integrity risk to public safety, property, or the
environment, and proposed that Respondent take certain corrective measures to remedy the alleged
conditions to ensure that the public, property, and the environment are protected from the potential
risk.
On August 26, 2022, Osage responded to the Notice requesting an informal consultation. An
informal consultation was held virtually on September 1 and continued on September 22, 2022.
As a result of the informal consultation, PHMSA and Respondent (the Parties) agreed that
settlement of this proceeding will avoid further administrative proceedings or litigation of the
Notice and that entry into this Consent Agreement (Agreement) is the most appropriate means of
resolving the issues raised in the Notice and is generally in the public interest. Therefore, pursuant
to 49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and
agreement of the Parties, PHMSA and Osage agree as follows:
I. General Provisions
1. Respondent acknowledges that as the operator of the Osage Pipeline, Respondent
and the Osage Pipeline 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 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. Respondent does not admit or deny any of the alleged integrity risks identified in
the Notice but agrees, for purposes of this Agreement, to address the alleged integrity risks
identified in the Notice by completing the actions specified in Section II of this agreement
(Corrective Measures) and to abide by the terms of this Agreement. This Agreement does not
constitute a finding of violation of any Federal law or regulation and may not be used in any civil
or administrative proceeding of any kind as evidence or proof of any fact, fault or liability, or as
evidence of the violation of any law, rule, regulation or requirement, except in a proceeding to
enforce the provisions of this Agreement.
3. After Respondent returns this signed Agreement, a representative of PHMSA 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.
4. 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 as set forth herein.
5. This Agreement will apply to and be binding upon PHMSA, and upon 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.
6. For all transfers of ownership or operating responsibility of Respondent’s Osage
Pipeline, Respondent will provide a copy of this Agreement to the prospective transferee at least
30 days prior to such transfer and provide written notice of the transfer within 30 days after the
transfer to the PHMSA Southwest Region Director (Director) who issued the Notice.
7. 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.
8. 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.
9. 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.
10. 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.
II. Corrective Measures
11. Upon issuance of the Consent Order, Respondent agrees to perform the Corrective
Measures set forth below.



Definitions:
Affected Pipeline – The “Affected Pipeline” means Osage’s entire 136 mile 20-inch pipeline
that originates in Lincoln County, Oklahoma and terminates in El Dorado, Kansas, where it
connects with Holly Energy Partners – Operating, L.P.
12. Operating Pressure Restriction. Osage must maintain a twenty percent (20%)
pressure reduction in the actual operating pressure along 
- **truncated:** true
- **body characters:** 57382