{"operation":"document","citation":"CPF 520165006W","title":"TABULA RASA ENERGY LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-08-18","effective_on":null,"summary":"CLOSED warning letter citing 195.266(a), 195.404(c)(3), 195.420(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520165006W","body":"Warning Letter involving TABULA RASA ENERGY LLC. PHMSA's enforcement data identifies the cited regulations as 195.266(a),  195.404(c)(3),  195.420(b). The case was opened on 2016-08-18 and is reported as closed as of 2016-08-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520165006W_Warning Letter_08182016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165006W/520165006W_Warning%20Letter_08182016.pdf\n\n520165006W_Warning Letter_08182016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165006W/520165006W_Warning%20Letter_08182016_text.pdf\n\n520165006W_Warning Letter_08182016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 18, 2016\nMr. Brady McConaty\nPresident\nTabula Rasa Energy\n12012 Wickchester Lane\nS-660\nHouston, TX 77079\nCPF 5-2016-5006W\nDear Mr. McConaty:\nOn September 14-17, 2015, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your Blue\nLake CO2 Pipeline (aka Huerfano County CO2 Line) near La Veta in Huerfano County,\nColorado.\nAs a result of the inspection, it is alleged 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. §195.266 Construction Records.\nA complete record that shows the following must be maintained by the operator\ninvolved for the life of each pipeline facility:\n(a) The total number of girth welds and the number nondestructively tested,\nincluding the number rejected and the disposition of each rejected weld.\nDuring original construction of the Blue Lake CO2 Pipeline in 2007, several defective welds were\nidentified by non-destructive testing. Of these welds, no x-ray film or weld inspection records\n\n\n\ncould be located which indicate that welds A-113, A-1060, and A-1140 were repaired, or cut-out\nand replaced, during construction, despite an exhaustive search of all available records.\n2. §195.404 Maps and records.\n…(c) Each operator shall maintain the following records for the periods specified:\n…(3) A record of each inspection and test required by this subpart shall be\nmaintained for at least 2 years or until the next inspection or test is performed,\nwhichever is longer.\nRecords available at the time of the inspection indicated that the maximum 7 ½-month interval\nbetween mainline valve inspections allowed under §195.420(b) was exceeded between July 15,\n2014, and April 16, 2015.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violation occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Tabula Rasa Energy being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2016-5006W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Stahoviak (#149561)\n2","truncated":false,"body_characters":4376}