{"operation":"document","citation":"CPF 520165005M","title":"TALLGRASS PONY EXPRESS PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-07-27","effective_on":null,"summary":"CLOSED notice of amendment citing 195.214(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520165005M","body":"Notice of Amendment involving TALLGRASS PONY EXPRESS PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 195.214(a). The case was opened on 2016-07-27 and is reported as closed as of 2017-06-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520165005M_Closure Letter_06282017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165005M/520165005M_Closure%20Letter_06282017.pdf\n\n520165005M_Closure Letter_06282017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165005M/520165005M_Closure%20Letter_06282017_text.pdf\n\n520165005M_Notice of Amendment_07272016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165005M/520165005M_Notice%20of%20Amendment_07272016.pdf\n\n520165005M_Notice of Amendment_07272016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165005M/520165005M_Notice%20of%20Amendment_07272016_text.pdf\n\n520165005M_Operator Response to Notice_08152016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165005M/520165005M_Operator%20Response%20to%20Notice_08152016.pdf\n\n520165005M_Closure Letter_06282017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 28, 2017\nMr. Mick Rafter\nVice President, Operations and EHS\nTallgrass Pony Express Pipeline, LLC\n370 Van Gordon Street\nLakewood, CO 80228\nCPF 5-2016-5005M\nClosure Letter\nDear Mr. Rafter:\nOn March 23 through 26, 2015, representatives from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of the Tallgrass Pony Express Pipeline’s (Tallgrass) operations and\nmaintenance procedures in Lakewood, Colorado. As a result of the inspection, Tallgrass was\nissued a Notice of Amendment on July 27, 2016, that proposed amendment of your procedures.\nTallgrass submitted its amended procedures on April 26, 2017. 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 no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nHuy Nguyen\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#149812)\n\n520165005M_Notice of Amendment_07272016_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 27, 2016\nMr. Mick Rafter\nVice President, Operations and EHS\nTallgrass Pony Express Pipeline, LLC\n370 Van Gordon Street\nLakewood, CO 80228\nCPF 5-2016-5005M\nDear Mr. Rafter:\nOn March 23-26, 2015, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nTallgrass Pony Express Pipeline, LLC’s procedures for Operations and Maintenance in\nLakewood, Colorado.\nOn the basis of the inspection, PHMSA has identified an apparent inadequacy found within\nTallgrass’s plans or procedures for maintaining your crude oil pipeline systems, as described\nbelow:\n1. § 195.214 Welding procedures.\n(a) Welding must be performed by a qualified welder in accordance with welding\nprocedures qualified under Section 5 of API 1104 or Section IX of the ASME Boiler\nand Pressure Vessel Code (incorporated by reference, see § 195.3) . The quality of\nthe test welds used to qualify the welding procedure shall be determined by\ndestructive testing.\n\n\n\nTallgrass Pony Express Pipeline, LLC’s (Tallgrass) procedures for welding did not include a\nqualified procedure for back welding and Tallgrass did not have a qualified back welding\nprocedure. At the time of the inspection the operator was using a standard butt weld\nprocedure for back welding (on the Pony Express Conversion project) and did not have a\nseparate back welding procedure or an O&M Procedure requiring back welding to be\nperformed using a separate back welding procedure.\nAccording to API 1104, Section 5.4.1 (Essential Variables/General): A welding procedure\nmust be re-established as a new procedure specification and must be completely requalified\nwhen any of the essential variables listed in Section 5.4.2 are changed. Section 5.4.2.3\n(Changes Requiring Requalification/Joint Design) states: A major change in joint constitutes\nan essential variable design. Back welds are used as fillet welds when there is a different wall\nthickness. Also Section 5.3.2.5 (Filler Metal and Number of Beads) states: The sizes and\nclassification number of the filler metal and the minimum number and sequence of beads shall\nbe designated. The weld design for a back weld is that of a fillet weld and is different than a\nbutt weld. Typically a “V” or “U” groove is used for a butt weld. Furthermore, the weld\nprocedure qualifying tests should be recorded in detail per § 195.214(b).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within sixty (60) days of receipt of this\nNotice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\n2\n\n\n\nIt is requested (not mandated) that Tallgrass Pony Express Pipeline, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal,\nDirector, Western Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 5-2016-5005M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#149812)\n3","truncated":false,"body_characters":7239}