CPF 520151011W
CPF 520151011W
520151011W_Warning Letter_12162015_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED December 16, 2015 Mr. Craig Meis Vice President, EHS & Compliance Tallgrass Energy Partners 370 Van Gordon Street Lakewood, CO 80228 CPF 5-2015-1011W Dear Mr. Meis: On August 10 – 14, 2015, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Rockies Express Pipeline System in Casper, Wyoming. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation is: 1. §192.245 Repair or Removal of Defects. … (c) Repair of a crack, or of any defect in a previously repaired area must be in accordance with written weld repair procedures that have been qualified under §192.225. Repair procedures must provide that the minimum mechanical properties specified for the welding procedure used to make the original weld are met upon completion of the final weld repair.#
520151011W_Warning Letter_12162015_text.pdf, page 2Records available at the time of the inspection, and additional records provided at a later date, did not provide sufficient documentation to verify that a repair of a previously repaired area on weld number 047 on the 42” pig receiver barrel fabricated for use at Arlington Compressor Station was performed in accordance with the operator’s written procedures. Records included the Daily Weld Inspection Report dated May 1, 2013 for 047-R, the Radiographic Daily Report dated May 5, 2013 for XRA-047, the Radiographic Daily Report dated May 6, 2013 for XRA-047R, the Daily Weld Inspection Report dated May 14, 2013 for 047 Repair, and the Radiographic Daily Report dated May 14, 2013 for XRB-047R1. NOTE: Discrepancies in dates of the various reports are recognized but are not involved in this issue. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in [Company name] being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF-5-2015-1011W and for each document you submit, please provide a copy in electronic format to PHP-WRADMIN@dot.gov whenever possible. 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). Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Stahoviak (#149631)#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.