# CRESCENT MIDSTREAM, LLC — Corrective Action Order

- **operation:** document
- **citation:** CPF 42024016CAO
- **title:** CRESCENT MIDSTREAM, LLC — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-08-02
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024016cao.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024016cao.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024016cao
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024016CAO
**body:**

Corrective Action Order involving CRESCENT MIDSTREAM, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2024-08-02 and is reported as closed as of 2025-05-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024016CAO_Closure Letter_05122025_(24-315924).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_Closure%20Letter_05122025_(24-315924).pdf

42024016CAO_Closure Letter_05122025_(24-315924)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_Closure%20Letter_05122025_(24-315924)_text.pdf

42024016CAO_Corrective Action Order_0802024_(24-315924).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_Corrective%20Action%20Order_0802024_(24-315924).pdf

42024016CAO_Corrective Action Order_0802024_(24-315924)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_Corrective%20Action%20Order_0802024_(24-315924)_text.pdf

42024016CAO_Operator Request for Hearing and Request for Case File and Statement of Issues_08122024_(24-315924).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_Operator%20Request%20for%20Hearing%20and%20Request%20for%20Case%20File%20and%20Statement%20of%20Issues_08122024_(24-315924).pdf

42024016CAO_Operator Withdrawal of Hearing Request_10082024_(24-315924).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_Operator%20Withdrawal%20of%20Hearing%20Request_10082024_(24-315924).pdf

42024016CAO_PHC Hearing Scheduled_09052024_(24-315924).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_PHC%20Hearing%20Scheduled_09052024_(24-315924).pdf

42024016CAO_PHC Hearing Scheduled_09052024_(24-315924)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024016CAO/42024016CAO_PHC%20Hearing%20Scheduled_09052024_(24-315924)_text.pdf

42024016CAO_Corrective Action Order_0802024_(24-315924)_text.pdf

August 2, 2024
VIA ELECTRONIC MAIL TO: jashcroft@crescentmid.com
Mr. Jeremiah Ashcroft III
Chief Executive Officer
Crescent Midstream, LLC
263 Trinity Lane
Gray, Louisiana 70359
CPF No. 4-2024-016-CAO
Dear Mr. Ashcroft:
Enclosed please find the Corrective Action Order (CAO or Order) issued by the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the
above-referenced case. It requires Crescent Midstream, LLC to take certain corrective actions
with respect to the July 27, 2024, release of crude oil from its pipeline facilities in Raceland,
Louisiana.
Service of the CAO by electronic transmission is deemed complete upon transmission
and acknowledgment of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms
and conditions of this Order are effective upon completion of service.
Sincerely,
for Alan Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: CAO
cc: Mr. Bryan Lethcoe, Director, Southwest Region, OPS
Mr. Eric Lyons, Vice President of Engineering and Operations, Crescent
Midstream, LLC, elyons@crescentmid.com
Mr. Daniel Pelas, Safety and Compliance Supervisor, Crescent Midstream, LLC
dpelas@crescentmid.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 )
)
Crescent Midstream, LLC, ) CPF No. 4-2024-016-CAO
)
)
Respondent. )
)
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority of 49
U.S.C. § 60112 and 49 C.F.R. § 190.233, to require Crescent Midstream, LLC (Crescent
Midstream or Respondent) to take necessary corrective actions to protect the public, property, and
the environment from potential hazards associated with a July 27, 2024, accident resulting in the
release of crude oil from Crescent Midstream’s hazardous liquid pipeline facilities located in
Raceland, Louisiana (Accident).
Crescent Midstream operates an interstate hazardous liquid pipeline system in Louisiana and the
Gulf of Mexico. Respondent operates over 900 miles of hazardous liquid pipelines, and its system
includes crude oil breakout tanks subject to the requirements of 49 C.F.R. Part 195 (Part 195).
At 10:49 a.m. Eastern Daylight Time (EDT)1 on Saturday, July 27, 2024, the National
Response Center (NRC) was notified1 that an unknown amount of crude oil was released at
approximately 8:00 a.m. in Lafourche Parish, Louisiana. Two additional NRC notifications2
were made by Crescent Midstream on Monday, July 29, 2024, indicating that an estimated 175
barrels (bbl.), and subsequently 852 total bbl., of crude oil had been released from Crescent
Midstream’s pipeline facilities in Raceland (the Accident). No fires, injuries, fatalities, or
evacuations occurred as a result of the crude oil release. However, it appears water sources,
wildlife, and vegetation have been affected.
Pursuant to 49 U.S.C. § 60117, PHMSA’s OPS initiated an investigation of the Accident. The
preliminary findings of OPS’ ongoing investigation are as follows:
1 NRC Report No. 1406083.
2 NRC Report No.’s 1406243 and 1406258, respectively.



Preliminary Findings
• Crescent Midstream’s hazardous liquid pipeline facilities in the Raceland area are part
of its “Bonefish” system which is composed of 12-, 16-, and 20-inch hazardous liquid
pipelines (constructed in the 1950s and 1960s), as well as an aboveground crude oil
breakout tank (Tank No. 2051). Respondent’s pipeline facilities near Raceland are
located within a high consequence area (HCA)3 as defined by Part 195.
• Tank No. 2051 was obtained by Crescent Midstream in 2016, and was removed from
service beginning on approximately June 6, 2024, for an inspection. It is unclear to
PHMSA if Respondent has construction and inspection history records for Tank No.
2051 as required under Part 195 and American Petroleum Institute (API) standards 650
and 653, to establish the out of service inspection interval.
• After removing Tank No. 2051 from service for inspection, Crescent Midstream has
been utilizing two temporary frac tanks4 (250 bbl. and 500 bbl. capacities, respectively)
and a temporary pump unit. The frac tanks were apparently being used for surge relief
purposes, in part, do not meet applicable requirements of Part 195, and were not
equipped with any liquid level monitoring devices.
• As part of Crescent Midstream’s frac tank setup at Raceland Station, a 16-inch PHMSA
regulated pipeline was temporarily connected to the two frac tanks through a Flex-Flo
valve set at 160 pounds per square inch gauge (psig). The temporary pump was used to
re-inject crude oil into the 16-inch pipeline. Respondent also reportedly performed a
tightline operation on one of its 16-inch pipelines (Raceland Station to St. James)
without any surge relief at Raceland Station. Another separate operation was performed
using the lower pressure measurement piping at the Raceland Station to deliver crude
oil to Port Allen via the Sentinel Pipeline and using the temporary frac tanks to provide
surge relief.
• The temporary pump required manual operation and needed to be in operation to pump
crude oil from the frac tanks back into the 16-inch pipeline to reduce the liquid level in
the frac tanks. According to Crescent Midstream personnel, the pump was disconnected
prior to the Accident.
• Respondent indicates it was manually checking the crude oil levels on the frac tanks since
their recent installation. However, PHMSA is not aware of the existence of any written
procedures addressing this monitoring operation at Raceland Station, nor has Respondent
presented records to confirm such monitoring was occurring. Additionally, Crescent
Midstream has been unable to provide any specifications related to the pressure rating of
the hoses connecting the frac tanks, pipeline, and the temporary pump.
• According to an EverLine5 control center log entry for June 25, 2024, the Respondent’s
3 See 49 C.F.R. § 195.450.
4 Frac tank are generally large, moveable, metal storage containers used for temporary storage of liquids or other bulk
materials.
5 Respondent utilizes EverLine, a third-party control center operator based out of Houston, Texas, as its control room



third-party control room was verbally informed that the operating pressure on
Respondent’s 16-inch pipeline at Raceland Station should not exceed 120 psig. However,
beginning on July 26, 2024, at about 5:20 p.m. Central Daylight Time (CDT), there were
multiple occasions where logs indicate the pressure on that pipeline exceeded 120 psig.
PHMSA is unaware of any documentation, procedures, or specifications addressing the
appropriate pressures relative to the temporary arrangement involving the frac tanks and
pump. Respondent was unable to provide any written operating procedures or
management of change procedures for communications with their third-party control
center (EverLine).
• On July 27, 2024 (the date of the Accident) Tank No. 2051 was still out of service and
the temporary frac tanks were being used as surge relief without liquid level
monitoring. The pressure excursions resulted in crude oil from the pipeline flowing into
the frac tanks which overflowed with crude oil.
• The discharge valve in the impoundment area in which the frac tanks were located was
open, and crude oil overflowing the frac tanks left the impoundment area and flowed into
an adjacent ditch and eventually into nearby Bayou Lafourche.6 Bayou Lafourche is a
water supply for three Louisiana parishes and a city.7
• According to Respondent, at approximately 9:00 a.m. CDT on July 27, 2024, the discharge
valve in the impoundment area was closed upon discovery of the crude oil release. The
control room was also instructed to shut down the Raceland Station and the pipelines
entering and leaving the facility. Respondent has not provided information indicating what
steps the control room took to shut down the pipeline.
• As a result of the crude oil release, Bayou Lafourche, nearby residents, wildlife, and
vegetation have been affected.
• Respondent’s pipeline facilities at Raceland Station remain shut down. PHMSA’s
investigation is ongoing and the circumstances leading to the release of crude oil has not
yet been determined.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 authorizes PHMSA to determine that a pipeline facility is or would be hazardous
to life, property, or the environment and if there is a likelihood of serious harm, to expeditiously
order to the operator of the facility to take necessary corrective action, including suspended or
restricted use of the facility, physical inspection, testing, repair, replacement, or other appropriate
action. An order issued expeditiously must provide an opportunity for a hearing as soon as
practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
contractor.
6 Bayou Lafourche is an over 100-mile waterway that flows into the Gulf of Mexico.
7 Assumption Parish, Terrebonne Parish, Lafourche Parish, and Thibodeaux (a city located in Lafourche Parish).



deteriorative qualities of the material, the sequence in which the material are transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the pipeline facility is located to environmentally sensitive areas;
(5) the population density and population and growth patterns of the area in which the pipeline
facility is located; (6) any recommendation of the National Transportation Safety Board made
under another law; and (7) other factors PHMSA may consider as appropriate.
After evaluating the foregoing preliminary findings of fact and having considered the lack of
procedures governing the Respondent’s current operations with respect to the temporary frac
tanks and related equipment at the Raceland facility; Crescent Midstream’s current pipeline
facility and tank arrangement at Raceland Station that appears to be outside of that allowed under
relevant PHMSA hazardous liquid pipeline facility regulations; the unknown status of the
required records applicable to Tank No. 2051 illustrating its safety; the hazardous nature of the
product transported; the proximity of the pipeline facilities to HCAs, drinking water sources, and
human populations; the uncertainty as to the cause of the crude oil release; the uncertainty of
potential impacts of the Accident to other of Respondent’s pipelines and facilities as presently
arranged at Raceland Station; and because the same condition(s),tank, and pipeline facility
equipment arrangement that may have caused the crude oil release remain present at
Respondent’s Raceland facilities, I find that continued operation of the pipeline without
corrective measures is or would be hazardous to life, property, or the environment, and that
failure to issue this Order without notice would result in the likelihood of serious harm.
Accordingly, under 49 C.F.R. § 190.233(b), this Order mandating immediate corrective action is
issued expeditiously without prior notice and opportunity for a hearing. The terms and conditions
of this Order are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, OPS Southwest Region, PHMSA (Director). If a hearing is requested, it will be
held in accordance with 49 C.F.R. § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, PHMSA will consider amending this Order. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions
Definitions:
Affected Segment – The “Affected Segment” means the 12-, 16-, and 20-inch pipelines
from Manila Junction to the Crescent Midstream Raceland Station; all piping, pump units,
measurement facilities, tanks, and appurtenant facilities at Raceland Station; the Crescent
Midstream-operated facilities used to deliver commodity to the Sentinel Pipeline; and the
Crescent Midstream-operated pipeline between Raceland Station and the St. James
Terminal.



Isolated Facility – The "Isolated Facility" means all piping, pump units, measurement
facilities, tanks, valves, actuators, control devices, pressure relief devices, SCADA
equipment, sensors, fabricated assemblies, and appurtenant facilities at the Crescent
Midstream Raceland Station.
Director – The "Director" means the Director, Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), Southwest Region. The
Director’s address is 8701 S. Gessner, Suite 630, Houston, Texas 77074.
Pursuant to 49 U.S.C. § 60112, I hereby order Crescent Midstream to immediately
take the following corrective actions:
1. Operating and Pressure Restrictions.
a. b. c. All pipelines within the Crescent Midstream Raceland Station (Isolated Facility) will
remain shut-in and out of operation until approval to restart is given by the Director
pursuant to Corrective Action Item 3.
Upon approval to restart partial operations, such operations will be restricted to those
specifically illustrated in the attached diagram, titled “Raceland Station Valve Chart”
(attached as Appendix A), with the proposed flow path specified as the Empire to St.
James “tight line” operation and highlighted on the diagram. Only the identified piping
and pump units reflected on the diagram at the Isolated Facility will be operated. No
low-pressure measurement piping is included in the operation. The initial approval will
limit the discharge pressure at the Isolated Facility to 350 psig. This permitted
operation is only to deliver crude oil from Manila Junction to the breakout tanks located
at the Crescent Midstream St. James terminal. Any changes to this operation must be
approved in writing by the Director before they occur during the effective period of this
Order.
Prior to requesting approval to restart operations of the Isolated Facility, Respondent
must contract with a properly qualified independent third-party vendor to identify the
cause and circumstances that resulted in the Accident and communicate the cause and
circumstances in writing to the Director. Prior to initiating the investigation, the
Respondent must submit the proposed third-party vendor and its qualifications to the
Director in writing for approval. Respondent must also review its reporting and
emergency response procedures, and accurately determine and report the release volume
that occurred during the Accident as required by 49 C.F.R. § 195.52. Respondent must
also identify any issues or actions with regard to the operation of the Isolated Facility
that were taking place at the time of the Accident that prevented the immediate
identification of the crude oil release and the timely required reporting of such release
by Crescent Midstream operations personnel. This information must be submitted in
writing to the Director prior to the initial request to restart operations, or in any event no
later than 60 days from issuance of this Order.
2. Actions Prior to Restart



Prior to submitting the Restart Plan under Corrective Action Item 3 below, Respondent
must:
a. Perform a thorough review of its operations for the entire Affected Segment to ensure
compliance with applicable Part 195 requirements, and provide the Director with a
signed affidavit from the Chief Executive Officer of Crescent Midstream attesting to
Respondent’s compliance with applicable PHMSA regulations;
b. Conduct a review of the Affected Segment to identify any abnormal operating
conditions, deficient operating practices, or lessons learned requiring corrections, and
address any such conditions that require remedial action implementation prior to
submitting the Restart Plan. Respondent must identify in writing to the Director all
operations reviewed in the Affected Segment and any corrective actions/changes made,
or that Respondent plans to make, to such operations, and receive approval for such
changes in writing from the Director;
c. Review its emergency response procedures and oil spill response plan (49 C.F.R. Part
194) with all personnel involved in operating the Affected Segment, identify any
deficiencies with the procedures or following the procedures, and ensure all operating
personnel are prepared to respond appropriately as required by their emergency
response procedures and Part 194;
d. Submit its complete Management of Change and Lockout/Tagout procedures to the
Director for review and approval;
e. Provide its written procedures for determining a leak or release has occurred on the
Affected Segment to the Director for review and approval.
3. Restart Plan.
a. b. Respondent must submit a detailed written Restart Plan to the Director and receive
approval from the Director prior to operating any pipeline facilities in the Isolated
Facility.
All pressure relief and overpressure protection devices within the Isolated Facility must
be set no higher than maximum operating pressure identified by Crescent Midstream’s
Restart Plan. All relief and overpressure protection devices must be reset to the
pressure restrictions in the Crescent Midstream Restart Plan and confirmed by written
documentation according to Respondent’s written procedures. A copy of the
documentation must be submitted to, and approved by, the Director in writing prior to
the restart.
c. The Restart Plan must specify how the Isolated Facility will be protected from surge
events as required by §195.406(b). All alarm setpoints must be adjusted and confirmed
using Respondent’s written Management of Change procedures, submitted to the
EverLine control center, and confirmed by written documentation. The EverLine
controllers and Respondent’s operations personnel must also be trained on any revisions
prior to the restart. Confirmation of the training and the additional documentation
described above in this Corrective Action Item 3.c. must be submitted in writing, and
approved by, the Director prior to the restart.



d. e. f. g. h. i. j. k. l. Any Isolated Facility piping not included in Respondent’s proposed restart plan must
remain isolated by written Lock Out/Tag Out procedures. These Lock Out/Tag Out
procedures must be submitted to the Director and approved in writing prior to restart.
Pressure relief and overpressure protection may not be accomplished via use of
administrative controls only.
The Restart Plan must provide for continuous in-person monitoring of the Isolated
Facility by Respondent’s personnel during the restart process, and continuing for a
minimum of 24 hours thereafter. If any abnormal operating conditions or other safety
concerns occur during the restart, operations must immediately be shut down and the
cause of any abnormal operating conditions or safety issues determined and reported to
the Director in writing, along with any proposed corrective actions identified.
Respondent must not restart operations again until receiving written approval to do so
from the Director.
The Restart Plan must be initiated only during daylight hours and must describe its plan
to ensure sufficient in-person monitoring to ensure no abnormal operating conditions
occur.
The Restart Plan must include provisions for communications with local emergency
response officials prior to restart of the Isolated Facility, and such communications
must be made by Respondent prior to restart.
The Restart Plan must include procedures requiring more frequent (at a minimum, at
least once every seven (7) days during the effective period of this Order) leak detection
patrolling than normally required by Part 195 regulations for the Affected Segment
during the effective period of this Order, and must identify the methods and frequencies
of such patrolling.
The Restart Plan must specify reduced leak detection thresholds for the Affected
Segment during the effective period of this Order. The Restart Plan must specify how
Respondent will perform leak detection activities to account for such reduced thresholds
and address the adjusted leak detection alarming to the new limits. Respondent’s
amended procedures governing leak detection at reduced thresholds must be submitted
to the Director and approved in writing prior to restart.
The Restart Plan must identify the EverLine control center points of contact and must
also be included in the EverLine control room shift change information. A copy of the
shift change information must be provided daily for the first 72 hours, and then weekly
thereafter, to the Director in writing during the effective period of this Order.
The Restart Plan must identify and specify the position of each valve in the Isolated
Facility, and those positions must be confirmed with the EverLine control center. The
valve positions and evidence of the control center confirmation of such information
must be provided to the Director in writing prior to restart.
The Restart Plan must include a description of the communications process with the
EverLine control center. The Restart Plan must also include applicable Management of
Change procedures (including documentation) that will be used for any changes made to
the portions of the Crescent Midstream system affected by this Order, including all
specified operational and pressure restrictions. The communications plan must also
identify how any operation issues will be communicated between the EverLine control
center and Crescent Midstream, including identification of specific personnel making
such notifications.



m. The Director may approve the Restart Plan incrementally without approving the entire
plan, but the Isolated Facility cannot resume any operations until the Restart Plan is
approved in its entirety.
n. Once approved by the Director in its entirety, the Restart Plan will be incorporated by
reference into this Order.
o. After any portion of the Isolated Facility identified in the approved Restart Plan has
operated without any abnormal conditions for a minimum of 72 hours, Respondent may
request from the Director approval for a full return to service (without the 350 psig
pressure restriction specified in Corrective Action Item 1.b. above) of such portion of
the Isolated Facility.
Other Requirements
4. 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.
5. Reporting. Respondent must submit quarterly reports to the Director that: (1) include all
available data and the results of any testing and evaluations, and of any other reviews (to
include of Respondent’s procedures and regulatory compliance evaluations) required by this
Order; (2) include and describe the progress of the repairs or any other remedial actions
being undertaken by Respondent on the Affected Segment and Isolated Facility and at the
Raceland Station under this Order. The first quarterly report is due on September 30, 2024.
The Director may amend the interval for the submission of these reports.
6. 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.
7. Documentation of the Costs. It is requested that Respondent maintain documentation of the
costs associated with implementation of this Corrective Action Order. Include in each
quarterly 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.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. 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 No. 4-2024-016-CAO” and for each
document you submit, please provide a copy in electronic format whenever possible. The actions
required by this Order are in addition to and do not waive any requirements that apply to
Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order
issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of
federal or state law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.
§ 190.5.
for Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

42024016CAO_Closure Letter_05122025_(24-315924)_text.pdf

VIA ELECTRONIC MAIL TO: jashcroft@crescentmid.com
May 12, 2025
Jeremiah Ashcroft III
Chief Executive Officer
Crescent Midstream, LLC
263 Trinity Lane
Gray, Louisiana 70359
RE: CPF 4-2024-016-CAO
Dear Mr. Ashcroft:
On August 2, 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Crescent Midstream, LLC, a Corrective Action Order in the above-referenced case. This Order
included a requirement to take corrective actions on your pipeline. Based on our review of the
documentation you provided, it has been determined that you have complied with the terms of this
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,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Eric Lyons, Vice President of Engineering and Operations, Crescent Midstream, LLC,
elyons@crescentmid.com
Kayley Gautreaux, Compliance Coordinator, Crescent Midstream, LLC
kgautreaux@crescentmid.com

42024016CAO_PHC Hearing Scheduled_09052024_(24-315924)_text.pdf

September 5, 2024
VIA ELECTRONIC MAIL TO: emallen@akingump.com and bryan.lethcoe@dot.gov
Ms. Emily P. Mallen
Counsel to Crescent Midstream, LLC
Akin Gump Strauss Hauer & Feld, LLP
Robert S. Strauss Tower
2001 K Street, NW
Washington, DC 20006
Mr. Bryan Lethcoe
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
8701 South Gessner Road, Suite 630
Houston, Texas 77074
Re: Notice of Hearing, Crescent Midstream, LLC
CPF No. 4-2024-016-CAO
Dear Ms. Mallen and Mr. Lethcoe:
In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the
Corrective Action Order issued by the Pipeline and Hazardous Materials Safety Administration
in the above-referenced case. The hearing will take place on November 13th, 2024, beginning at
8:30 a.m. Central Time.
The hearing will take place at the PHMSA Southwest Region office, 8701 South Gessner Road,
Suite 630, Houston, TX 77074. Upon arrival at the building, attendees will be required to
present photo identification to security personnel. A contact phone number for the day of the
hearing is (713) 272-2859.
At least 10 calendar days prior to the hearing (or by November 4th, 2024), both parties must
submit and exchange any additional written materials they intend to present at the hearing and
the name and email address of each attendee. This information should be provided
electronically. Materials not submitted by this date may be excluded.



If you have any questions, please do not hesitate to contact me.
Sincerely,
Larry White
Presiding Official
cc: Mr. Jeremiah Ashcroft III, Chief Executive Officer, Crescent Midstream, LLC,
jashcroft@crescentmid.com
Mr. Ian Curry, Esq., Counsel, Southwest Region, Office of Pipeline Safety, PHMSA,
ian.curry@dot.gov
Ms. Kelsey Gagnon, Counsel, Southwest Region, Office of Pipeline Safety, PHMSA,
kelsey.gagnon@dot.gov
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