# TALLGRASS MIDSTREAM LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

520190019W_Warning Letter_08262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190019W/520190019W_Warning%20Letter_08262019.pdf

520190019W_Warning Letter_08262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190019W/520190019W_Warning%20Letter_08262019_text.pdf

520190019W_Warning Letter_08262019_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 26, 2019
Mr. David G. Dehaemers Jr.
Chief Executive Officer
Tallgrass Energy
4200 W. 115th Street, Suite 350
Leawood, KS 66211-2609
CPF 5-2019-0019W
Dear Mr. Dehaemers:
On May 20 through May 21, 2019 a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected your gas gathering system in Douglas, Wyoming.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:
1. § 192.705 Transmission lines: Patrolling.
(a) . . . .
(b) The frequency of patrols is determined by the size of the line, the operating
pressures, the class location, terrain, weather, and other relevant factors, but
intervals between patrols may not be longer than prescribed in the following
table:
Maximum interval between patrols
Class location
of line At highway and railroad crossings At all other places



1, 2 71∕2 months; but at least twice each
calendar year
15 months; but at least once each
calendar year.
3 41∕2 months; but at least four times
each calendar year
71∕2 months; but at least twice each
calendar year.
4 41∕2 months; but at least four times
each calendar year
41∕2 months; but at least four times
each calendar year.
Tallgrass Energy failed to patrol its pipeline in a Class 1 location every 7 ½ months, but at
least twice each calendar year in violation of §192.705(b). During the inspection, a Tallgrass
Energy representative provided patrolling records conducted on September 19, 2018 but failed
to provide records to indicate that patrolling has been conducted in 2017.
2. § 192.465 External corrosion control: Monitoring.
(a) . . . .
(b) Each cathodic protection rectifier or other impressed current power source
must be inspected six times each calendar year, but with intervals not exceeding
21∕2 months, to insure that it is operating.
Tallgrass Energy failed to inspect its Tongue River cathodic protection rectifier six times each
calendar year, but with intervals not exceeding 2 ½ months to ensure that it is operating in
violation of §192.465(b). At the time of inspection, Tallgrass Energy was not able to provide
records to demonstrate that its cathodic protection rectifier had been inspected between June
2017 and January 2018.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679
for a related series of violations. For violation occurring on or after November 2, 2015 and
before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per
day, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to
November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with
a maximum penalty not to exceed $2,000,000 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 items identified in this letter. Failure to do so will result in
Tallgrass Energy 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 5-2019-0019W. 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
2



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,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 G. Ogirima (#165183)
Jennifer Eckels, Compliance Manager, 370 Van Gordon Street, Lakewood, CO 80228
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