{"operation":"document","citation":"CPF 520190019W","title":"TALLGRASS MIDSTREAM LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-08-26","effective_on":null,"summary":"CLOSED warning letter citing 192.465(b), 192.705(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190019w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190019w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190019w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520190019W","body":"Warning Letter involving TALLGRASS MIDSTREAM LLC. PHMSA's enforcement data identifies the cited regulations as 192.465(b),  192.705(b). The case was opened on 2019-08-26 and is reported as closed as of 2019-08-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520190019W_Warning Letter_08262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190019W/520190019W_Warning%20Letter_08262019.pdf\n\n520190019W_Warning Letter_08262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190019W/520190019W_Warning%20Letter_08262019_text.pdf\n\n520190019W_Warning Letter_08262019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 26, 2019\nMr. David G. Dehaemers Jr.\nChief Executive Officer\nTallgrass Energy\n4200 W. 115th Street, Suite 350\nLeawood, KS 66211-2609\nCPF 5-2019-0019W\nDear Mr. Dehaemers:\nOn May 20 through May 21, 2019 a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected your gas gathering system in Douglas, Wyoming.\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 (CFR). The items\ninspected and the probable violations are:\n1. § 192.705 Transmission lines: Patrolling.\n(a) . . . .\n(b) The frequency of patrols is determined by the size of the line, the operating\npressures, the class location, terrain, weather, and other relevant factors, but\nintervals between patrols may not be longer than prescribed in the following\ntable:\nMaximum interval between patrols\nClass location\nof line At highway and railroad crossings At all other places\n\n\n\n1, 2 71∕2 months; but at least twice each\ncalendar year\n15 months; but at least once each\ncalendar year.\n3 41∕2 months; but at least four times\neach calendar year\n71∕2 months; but at least twice each\ncalendar year.\n4 41∕2 months; but at least four times\neach calendar year\n41∕2 months; but at least four times\neach calendar year.\nTallgrass Energy failed to patrol its pipeline in a Class 1 location every 7 ½ months, but at\nleast twice each calendar year in violation of §192.705(b). During the inspection, a Tallgrass\nEnergy representative provided patrolling records conducted on September 19, 2018 but failed\nto provide records to indicate that patrolling has been conducted in 2017.\n2. § 192.465 External corrosion control: Monitoring.\n(a) . . . .\n(b) Each cathodic protection rectifier or other impressed current power source\nmust be inspected six times each calendar year, but with intervals not exceeding\n21∕2 months, to insure that it is operating.\nTallgrass Energy failed to inspect its Tongue River cathodic protection rectifier six times each\ncalendar year, but with intervals not exceeding 2 ½ months to ensure that it is operating in\nviolation of §192.465(b). At the time of inspection, Tallgrass Energy was not able to provide\nrecords to demonstrate that its cathodic protection rectifier had been inspected between June\n2017 and January 2018.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679\nfor a related series of violations. For violation occurring on or after November 2, 2015 and\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per\nday, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to\nNovember 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with\na maximum penalty not to exceed $2,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in\nTallgrass Energy being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2019-0019W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\n2\n\n\n\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Ogirima (#165183)\nJennifer Eckels, Compliance Manager, 370 Van Gordon Street, Lakewood, CO 80228\n3","truncated":false,"body_characters":5004}