# TAPROOT ROCKIES MIDSTREAM LLC — Warning Letter

**Citation:** CPF 52021035WL  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2021-07-08

CLOSED warning letter citing 195.573(c).

## Document text

Warning Letter involving TAPROOT ROCKIES MIDSTREAM LLC. PHMSA's enforcement data identifies the cited regulation as 195.573(c). The case was opened on 2021-07-08 and is reported as closed as of 2021-07-08. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

52021035WL_Warning Letter_07082021_(21-211736).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021035WL/52021035WL_Warning%20Letter_07082021_(21-211736).pdf

52021035WL_Warning Letter_07082021_(21-211736)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021035WL/52021035WL_Warning%20Letter_07082021_(21-211736)_text.pdf

52021035WL_Warning Letter_07082021_(21-211736)_text.pdf

WARNING LETTER
VIA E-MAIL TO MR. KEVIN SULLIVAN
July 8, 2021
Mr. Kevin Sullivan
CEO
Taproot Energy Partners
555 17th Street, Suite 800
Denver, CO 80202
CPF 5-2021-035-WL
Dear Mr. Sullivan:
On April 12th, 2021, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected
your liquid gathering system in Weld County, Colorado.
As a result of this inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected
and the probable violation is:
1



1. §195.573 What must I do to monitor external corrosion control?
(c) Rectifiers and other devices. You must electrically check for proper performance
each device in the first column at the frequency stated in the second column.
Device Check frequency
Rectifier
Reverse current switch.
Diode.
Interference bond whose failure
would jeopardize structural
protection.
At least six times each calendar year, but
with intervals not exceeding 21∕2 months.
Other interference bond At least once each calendar year, but with
intervals not exceeding 15 months.
Taproot Midstream failed to present documentation showing their rectifier was inspected every
2½ months between July 2020 and January 2021.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a
related series of violations. For violation occurring on or after January 11, 2021 and before May
3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation
persists, up to a maximum of $2,225,034 for a related series of violations. For violation
occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not
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.
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 item identified in this letter. Failure to do so will result in
Taproot Energy Partners 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 5-2021-035-WL. 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).
2



Sincerely,
Dustin Hubbard
Director, Western Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 G. Ogirima, J. Luo, J. Williams (#21-211736)
Mr. Rod Donovan, COO & President, Taproot Energy Partners
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/52021035WL>
- Source ID: `phmsa-enforcement`
- SHA-256: `a764085c13647c1a1f3fc16a12013f6e537313529a1202e4e5a9e09340f0d46c`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T09:49:49.524Z
- Document slug: `phmsa-enforcement-52021035wl`

### Source metadata

```json
{
  "cpf": "52021035WL",
  "operator": "TAPROOT ROCKIES MIDSTREAM LLC",
  "region": "Western",
  "pipelineType": "INTRASTATE LIQUID",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.573(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "52021035WL_Warning Letter_07082021_(21-211736).pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/52021035WL/52021035WL_Warning%20Letter_07082021_(21-211736).pdf",
      "bytes": 324242,
      "category": "agency_document"
    },
    {
      "name": "52021035WL_Warning Letter_07082021_(21-211736)_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/52021035WL/52021035WL_Warning%20Letter_07082021_(21-211736)_text.pdf",
      "bytes": 126608,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "TAPROOT ROCKIES MIDSTREAM LLC"
}
```
