{"operation":"document","citation":"CPF 520195001W","title":"TALLGRASS PONY EXPRESS PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-01-16","effective_on":null,"summary":"CLOSED warning letter citing 195.202, 195.246(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520195001W","body":"Warning Letter involving TALLGRASS PONY EXPRESS PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.246(a). The case was opened on 2019-01-16 and is reported as closed as of 2019-01-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520195001W_Warning Letter_01162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195001W/520195001W_Warning%20Letter_01162019.pdf\n\n520195001W_Warning Letter_01162019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195001W/520195001W_Warning%20Letter_01162019_text.pdf\n\n520195001W_Warning Letter_01162019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 16, 2019\nMr. David Dehaemers\nPresident\nTallgrass Pony Express Pipeline, LLC\n370 Van Gordon St.\nLakewood, CO 80228\nCPF 5-2019-5001W\nDear Mr. Dehaemers:\nFrom October 29 through November 2, 2018, two representatives of the Pipeline &\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code, completed a construction field inspection of the Wyoming, Tallgrass Pony\nExpress Pipeline’s Guernsey Terminal and its associated laterals. Inspection of the\nconstruction site included: (a) four 150,000 BBL Tanks, (b) two, twenty-inch diameter,\npipelines, (c) and an additional sixteen-inch diameter lateral at the new Guernsey Terminal.\nThe new pipeline facilities were being constructed from the existing Guernsey pump station\nand terminated at the new Guernsey Terminal. As part of the inspection, the representatives\nalso reviewed your construction, operation and maintenance procedures, and records\ndocumenting the implementation of those procedures.\nDuring our inspection, the following probable violations of the Pipeline Safety Regulations,\nTitle 49, Code of Federal Regulations (CFR) were noted. The potential regulatory\ndeficiencies observed and probable violation(s) are:\n\n\n\n1\n2\n§195.246 Installation of pipe in a ditch.\n(a) All pipe installed in a ditch must be installed in a manner that minimized the\nintroduction of secondary stresses and the possibility of damage to the pipe.\nThe pipe being installed in the ditch was not following Tallgrass construction\nstandards developed to minimize secondary stresses and possible damage.\nPer Tallgrass Construction Standards, Section: C1090, Title: Lowering-In Pipe,\nRevised 02/10/2014; 3. Lowering-In Pipeline,\n3.13. Pipe shall be lowered into trench gradually and uniformly so that each\njoint of suspension bears a proportional part of total pipe weight. The\nmaximum distance between points of suspension is designated based upon the\noutside diameter (OD) and wall thickness (wt). Calculation of the maximum\ndistance is performed by engineering and communicated to the project\nmanager. The project manager is responsible for communicating the maximum\ndistance associated with his/her projects.\nPipe being lowered into the trench appeared to exceed the distance allowed for\nunsupported pipe length. The roller sling’s distance from the end of pipe being\nlowered was too great and may have caused undue stress on the pipe and the recently\nwelded girth welds by not proportionally bearing a part of the total pipe weight. Two\nroller booms were used but a third boom, near the pipe end being lowered into the\ntrench, would have alleviated the stress.\n§195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of\nthis part.\nThe pipe was not being constructed in compliance with Tallgrass’s comprehensive\nwritten specifications. Observed non-compliances include:\na) Per Tallgrass Construction Standards, Section: C1090, Title: Lowering-In Pipe,\nRevised 02/10/2014; 2. General,\n2.4 Where trench runs through rock, trench sides and bottom shall be cleared of\nall loose or projecting rock. Contractor shall provide a continuous 4-inch\npadding of earth or sand in trench bottom. The pipe shall conform to bottom\ncontours of the trench grade so that it is uniformly and continuously\nsupported. The pipe shall not be closer than 6-inches to either side of the\ntrench.\n2\n\n\n\nb) c) Pipe which had been already lowered into trench lacked the adequate and\ncontinuous support (sandbags underneath) while sitting in the ditch to conform to\nthe bottom contours of the trench grade. In certain areas, pipe does not track but\nsags due to support(s) not being spaced near enough to one another.\nPer Tallgrass Construction Standards, Section: C1040, Title: Unloading, Hauling,\nand Stringing Materials, Revised 06/10/2013; 2. Unloading Material, 2.7:\nTo avoid damage to materials or equipment during stockpiling, hauling,\nstringing, or loading and unloading from trucks or railroad cars, Contractor\nshall provide material-handling equipment and tools to avoid damage of any\nkind. Equipment used in handling, transporting, storing, and laying pipe shall\nbe padded effectively to prevent damage to pipe or coating.\nRope or cushion was not placed between pipe and skids in multiple locations\nduring stringing/welding process. Pipe was directly touching wood skids. When\nlaying of the pipe during stringing, operator did not effectively pad the skids to\nprevent damage to the pipe or its coating.\nPer Tallgrass O&M Procedure, Section: OM407_GL, Title: Welding Procedures\nand Selection Guide, Effective: June 1, 2018;\n3.2. Multiple Filler Metal Options\na. Many of the Tallgrass welding procedures include a choice of welding\noptions to join a specific range of O.D., wall thickness and pipe grade using\ndifferent electrode classes and electrode diameters. The options are indicated\nwithin the procedure by subsections A, B, C, etc. The project manager must\ndirect the welder(s) to follow the specific procedure and subsection (if\napplicable) prior to the start of work. The welding inspector must indicate on\nany written document the specific procedure and subsection (if applicable)\nused during the welder testing and project. The welding inspector will verify\nthat the welder is following the appropriate welding parameters including\nvolts, amps, travel speed, rod type and size.\nWelder’s bucket on truck had welding rods which were not supported by\nTallgrass’s standard welding procedure for pipeline construction. In addition, these\nexisting rods were not the designated rod type(s) in Tallgrass’s repair procedure.\nThus, welding inspector failed to verify the welder had appropriate rod type in\ntheir bucket. These rods remained in the bucket for duration of the welding\nexamination for at least three pipe joints and posed the risked of being mistakenly\nused. The required rod type for the additional weld passes were not present in the\nwelding bucket as well.\n3\n\n\n\nd) Per Tallgrass O&M Procedure, Section: OM406_GL, Title: Weld Inspections and\nTesting, Effective: June 1, 2018; 3. Core information and Requirements\nA Tallgrass Certified Welding Inspector1 (TCWI) must inspect each weld to\nensure that the proper welding procedure was followed and that the finished weld\nmeets applicable standards and codes. For natural gas or hazardous liquids\npipelines and related facilities a Company welder is permitted to act as the welding\ninspector.\nExternal Undercut (UC) in a weld occurred at one repair location causing a UC defect.\nThis was not discovered during visual inspection by the WI but later discovered during\nNon-Destructive Testing (NDT) and film review. Weld was shallow to bevel height\nand did not appear to be capped over the bevel edges when visually examined during\ninspection of the weld. WI should have observed this visually upon completion of the\nweld during construction.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022\nfor a related series of violations. For violations occurring prior to November 2, 2015, the\nmaximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We\nadvise you to correct the item(s) identified in this letter during future construction activities.\nFailure to do so will result in Tallgrass Pony Express Pipeline, LLC being subject to\nadditional enforcement action. No reply to this letter is required. If you choose to reply, in\nyour correspondence please refer to CPF 5-2019-5001W. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\n4\n\n\n\nSincerely,\nChris Hoidal\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP 60 Compliance Registry\nPHP-500 H.M. Flaherty (#157168)\n5","truncated":false,"body_characters":9405}