# DEAD HORSE OIL COMPANY, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 520190024W
- **title:** DEAD HORSE OIL COMPANY, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-09-25
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 191.22(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190024w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190024w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520190024w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520190024W
**body:**

Warning Letter involving DEAD HORSE OIL COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 191.22(a). The case was opened on 2019-09-25 and is reported as closed as of 2019-09-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520190024W_Warning Letter (REVISED)_09252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190024W/520190024W_Warning%20Letter%20(REVISED)_09252019.pdf

520190024W_Warning Letter (REVISED)_09252019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190024W/520190024W_Warning%20Letter%20(REVISED)_09252019_text.pdf

520190024W_Warning Letter (REVISED)_09252019_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 25, 2019
Mr. Dean Christensen
President
Dead Horse Oil Company, LLC
4880 Three Fountains, Apt. 139
Murray, Utah 84107-5069
CPF 5-2019-0024W
Dear Mr. Christensen:
On May 9, 2019, Pacific Energy and Mining Company (PEMC) submitted the Operator Registry
Notification Form PHMSA F 1000.2 (Notification) to our office. The Notification reported the ceasing
of PEMC operatorship, effective on May 14, 2019, of approximately 21 miles of 16-inch diameter gas
transmission pipeline located in Grand County, Utah.
As a result of the review of the Notification, it is alleged that you have committed a probable violation
of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The probable violation is:
1. §191.22 National Registry of Pipeline and LNG Operators.
(a) OPID request. Effective January 1, 2012, each operator of a gas pipeline, gas pipeline
facility, underground natural gas storage facility, LNG plant or LNG facility must obtain
from PHMSA an Operator Identification Number (OPID). An OPID is assigned to an
operator for the pipeline or pipeline system for which the operator has primary
responsibility. To obtain an OPID, an operator must complete an OPID Assignment
Request DOT Form PHMSA F 1000.1 through the National Registry of Pipeline,
Underground Natural Gas Storage Facility, and LNG Operators in accordance with
§191.7.



As the new owner/operator of the approximately 21 miles of 16-inch diameter gas transmission
pipeline located in Grand County, Utah, Dead Horse Oil Company, LLC should have obtained from
PHMSA an Operator Identification Number (OPID).
In order to obtain an assigned OPID, the new operator must request an OPID and provide company
information at https://portal.phmsa.dot.gov/opidmgmt/faces/jsp/opidmgmt.jspx or have your DOT
Compliance Primary contact request access to the PHMSA Portal for OpID 40009 at
https://portal.phmsa.dot.gov/phmsapub/faces/EnrollmentV2.jspx
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related
series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019,
the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to
exceed $2,132,679. 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 within seven (7)
days after receipt of this letter. Failure to do so will result in Dead Horse Oil Company, LLC 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
5-2019-0024W. 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 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 B. Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 N. Cruz (#166775)
Mr. Al Zadeh, Pipeline Safety Engineer, Utah Public Service Commission
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