{"operation":"document","citation":"CPF 520165008W","title":"TALLGRASS PONY EXPRESS PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-09-01","effective_on":null,"summary":"CLOSED warning letter citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520165008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520165008W","body":"Warning Letter involving TALLGRASS PONY EXPRESS PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2016-09-01 and is reported as closed as of 2016-09-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520165008W_Warning Letter_09012016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165008W/520165008W_Warning%20Letter_09012016.pdf\n\n520165008W_Warning Letter_09012016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520165008W/520165008W_Warning%20Letter_09012016_text.pdf\n\n520165008W_Warning Letter_09012016_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 1, 2016\nMr. David Dehaemer\nCEO\nTallgrass Pony Express Pipeline, LLC.\n4200 W. 115th Street, Suite 350\nLeawood, KS 66211\nRevised CPF 5-2016-5008W\nDear Mr. Rafter:\nOn February 22 - 25, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nPony Express Pipeline (PXP) in Goshen County, Wyoming.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the\nprobable violation is:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a)\nof this section must include procedures for the following to provide safety during\nmaintenance and normal operations.\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nDuring remediation of anomaly #G38780, two (2) carrier sleeves were used to install a Type B\nsleeve over an anomaly in an area containing a girth weld. The repair procedure (O&M\n402/C1062 Welding Procedure) Section 3.16 Multiple Repair Sleeve Installation references a\nsketch on page 15 of 19, showing the sleeves and doubler plate, with a maximum gap (the linear\n\n\n\nwidth of the annular space over the girth weld between the line pipe and the doubler plate)\nbetween the carrier-sleeves specified as 3 inches. The anomaly repair observed in the field\ncovered a total length of 2.29 feet. The gap far exceeded the maximum specified gap in the\nsketch mentioned above, probably by approximately 18”, meaning that the operator’s repair\nprocedure was not followed. From discussions with Tallgrass personnel concerning this issue, it\nbecame apparent that there may have been at least two (2) versions of this repair procedure\nextant, yet there has been no internal resolution of the discrepancy between these versions of the\nprocedure regarding the maximum specified gap.\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,\nthe maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty\nnot to exceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting 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 Tallgrass Pony Express Pipeline,\nLLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2016-5008W. 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 (#152511)\n2","truncated":false,"body_characters":4650}