# ROVER PIPELINE, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120181018
- **title:** ROVER PIPELINE, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2018-09-10
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.243(b), 192.303, 192.319(a).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120181018
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120181018
**body:**

Notice of Probable Violation involving ROVER PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.243(b),  192.303,  192.319(a). The case was opened on 2018-09-10 and is reported as closed as of 2020-08-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120181018_Closure Letter_08042020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_Closure%20Letter_08042020.pdf

120181018_Closure Letter_08042020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_Closure%20Letter_08042020_text.pdf

120181018_Final Order_10162019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_Final%20Order_10162019.pdf

120181018_Final Order_10162019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_Final%20Order_10162019_text.pdf

120181018_NOPV PCO_09102018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_NOPV%20PCO_09102018.pdf

120181018_NOPV PCO_09102018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_NOPV%20PCO_09102018_text.pdf

120181018_Operator Response to Notice_10092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120181018/120181018_Operator%20Response%20to%20Notice_10092018.pdf

120181018_Closure Letter_08042020_text.pdf

OVERNIGHT EXPRESS DELIVERY
August 4, 2020
Mr. Kelcy Warren
Chief Executive Officer and Chairman of the Board of Directors
Energy Transfer Partners, LP
8111 Westchester Drive
Dallas, Texas 75225
CPF 1-2018-1018
Dear Mr. Warren:
On October 16, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Rover Pipeline, LLC, a Final Order in the above-referenced case. This Order included a
Compliance Order. Based on our review of the documentation you provided, it has been
determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120181018_Final Order_10162019_text.pdf

October 16, 2019
Mr. Kelcy Warren
Chief Executive Officer and Chairman of the Board of Directors
Energy Transfer Partners, LP
8111 Westchester Drive
Dallas, Texas 75225
Re: CPF No. 1-2018-1018
Dear Mr. Warren:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and specifies actions that need to be taken by your subsidiary, Rover Pipeline, LLC, to
comply with the pipeline safety regulations. When the terms of the compliance order have been
completed, as determined by the Director, Eastern Region, this enforcement action will be
closed. Service of the Final Order by certified mail is effective upon the date of mailing, as
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA
Mr. Eric Amundsen, Senior Vice President, Operations, Rover Pipeline, LLC, 1300 Main
Street, Houston, Texas 77002
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________________
)
In the Matter of )
)
Rover Pipeline, LLC, ) CPF No. 1-2018-1018
a subsidiary of Energy Transfer Partners, LP, )
)
Respondent. )
____________________________________________)
FINAL ORDER
On January 25, March 19-22, May 8-11, and June 18, 2019, pursuant to 49 U.S.C. § 60117, a
representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office
of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and
records of Rover Pipeline, LLC (Rover or Respondent), in Ohio. Rover is a subsidiary of Energy
Transfer Partners, LP.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated September 10, 2018, a Notice of Probable Violation and Proposed Compliance
Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Rover
had committed three violations of 49 C.F.R. Part 192, and proposed ordering Respondent to take
certain measures to correct the alleged violations.
Rover responded to the Notice by letter dated October 9, 2018 (Response). The company did not
contest the allegations of violation but provided information concerning the corrective actions it
had taken. Respondent did not request a hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
In its Response, Rover did not contest the allegations in the Notice that it violated 49 C.F.R. Part
192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.243(b), which states:
§ 192.243 Nondestructive testing.
(a) ….
(b) Nondestructive testing of welds must be performed:
1 https://energytransfer.com/natural-gas (last accessed September 24, 2019).



CPF No. 1-2018-1018
Page 2
(1) (2) In accordance with written procedures; and
By persons who have been trained and qualified in the established
procedures and with the equipment employed in testing.
The Notice alleged that Respondent violated 49 C.F.R. § 192.243(b) by failing to perform
nondestructive testing of welds in accordance with its written procedures. Specifically, Rover
failed to follow its procedure, Energy Transfer Welding Standards Document No. 060
(ETWS.060) effective February 1, 2017, which describes the nondestructive examination (NDE)
requirements for welds, including that NDE personnel must be qualified and certified for the
tasks they are performing.
During follow-up investigation of a December 17, 2017 girth weld failure that occurred during
post-construction hydrostatic testing on the Sherwood Lateral – South test segment SW-7, it was
noted that a project NDE film auditor was not certified or qualified in the applicable inspection
method, as required by ETWS.060. Further investigation and follow-up with Rover resulted in
the identification of an additional nine Rover Pipeline project NDE auditors not meeting the
requirements of ETWS.060.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.243(b) by failing to
nondestructively test welds in accordance with its written procedures.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 192.303, which states:
§ 192.303 Compliance with specifications or standards.
Each transmission line or main must be constructed in accordance with
comprehensive written specifications or standards that are consistent with
this part.
The Notice alleged that Respondent violated 49 C.F.R. § 192.303 by failing to construct each
transmission line in accordance with comprehensive written specifications or standards that are
consistent with 49 C.F.R. Part 192 during construction of the Rover Pipeline Project (Project).
Specifically, the Notice alleged that Rover failed to incorporate the code requirements for the
disposition of dents meeting criteria prescribed under § 192.309(b)(2) within its construction
standards for the Project. The construction standards failed to include a requirement for the
removal or repair of any dent that affects the longitudinal weld or a circumferential weld.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.303 by failing to construct each
transmission line in accordance with comprehensive written specifications or standards that are
consistent with 49 C.F.R. Part 192 during construction of the Project.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.319(a), which states:
§ 192.319 Installation of pipe in a ditch.
(a) When installed in a ditch, each transmission line that is to be
operated at a pressure producing a hoop stress of 20 percent or more of



CPF No. 1-2018-1018
Page 3
SMYS must be installed so that the pipe fits the ditch so as to minimize
stresses and protect the pipe coating from damage.
The Notice alleged that Respondent violated 49 C.F.R. § 192.319(a) by failing to install portions
of the Project in such a manner so as to minimize stresses and protect the pipe coating from
damage. Specifically, the Notice alleged the pipe was installed under excessive axial, tensile, or
bending stresses. The Notice alleged that the pipeline experienced three girth weld failures
during hydrostatic testing of the Project, two of which were attributable to large axial and/or
residual stresses. Independent third-party analysis concluded that improper installation practices
were contributing factors to these failures. In addition, the Project also experienced three
additional girth weld failures (cracks) during remediation efforts stemming from PHMSA
findings associated with non-conformance with API Std 1104 (incorporated by reference, see
§ 192.7).
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.319(a) by failing to install pipe
in such a manner so as to minimize stresses and protect the pipe coating from damage.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1, 2, and 3 in the Notice for
violations of 49 C.F.R. §§ 192.243(b), 192.303, and 192.319(a), respectively. Under 49 U.S.C.
§ 60118(a), each person who engages in the transportation of gas or who owns or operates a
pipeline facility is required to comply with the applicable safety standards established under
chapter 601.
With regard to the violation of § 192.243(b) (Item 1), Respondent provided documentation
concerning its completion of the proposed actions. The Director conducted a review of
documentation provided by Rover and confirms that the proposed compliance terms for Item 1
have been completed. Therefore, it is not necessary to include those terms in the Compliance
Order.
With regard to the violation of § 192.303 (Item 2), Respondent provided documentation
concerning its completion of the proposed actions. The Director conducted a review of the
documentation provided by Rover and confirms that the proposed compliance terms for Item 2
have been completed. Therefore, it is not necessary to include those terms in the Compliance
Order.2
With regard to the violation of § 192.319(a) (Item 3), Respondent requested that the terms be
modified. Specifically, Rover requested that it be permitted to use a combined high resolution
2 In a recommendation dated May 17, 2019, submitted pursuant to § 190.209(b)(7), the Director proposed to modify
Item 2(a) of the PCO. By letter dated July 12, 2019, Respondent objected and requested the modifications be
withdrawn. On July 31, 2019, the Director submitted an amended recommendation that did not contain the
modifications to Item 2(a). Accordingly, the proposed modifications are not included in this Order.



CPF No. 1-2018-1018
Page 4
longitudinal magnetic flux leakage (MFL), high resolution caliper/geometry and inertial mapping
unit (IMU) ILI tool to comply with the Proposed Compliance Order (PCO) Item 3(a). In support
of its request, Rover noted that this tool would prove more suitable in identifying pipe strain and
undue stress, especially with IMU capability to assess stresses and strain caused by degree of
settlement and post construction ground movement when compared to original survey caliper
tool date. The Director conducted a review of the proposed modification and confirms that such
modification should be made to the Compliance Order. Respondent stated that the completion of
the deployment of the ILI strain assessment tool for the entire Rover Pipeline Project will be
completed by November 1, 2019. The Director found this deadline to be acceptable.
Accordingly, this is reflected in the Compliance Order.
With regard to the PCO Item 4, Rover has completed the terms of this proposed requirement and
it is therefore not necessary to include the compliance terms in this Order.
With regard to the PCO Item 5, Rover has completed the terms of this proposed requirement and
it is therefore not necessary to include the compliance terms in this Order.
For the above reasons, the Compliance Order is modified as set forth below.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is
ordered to take the following actions to ensure compliance with the pipeline safety regulations
applicable to its operations:
1.With respect to the violation of § 192.319(a) (Item 3), Respondent must:
a. Assess locations where newly constructed pipe on the Rover Pipeline Project may
have been installed with undue stress or strain using a combined high resolution
longitudinal magnetic flux leakage (MFL), high resolution caliper/geometry and
inertial mapping unit (IMU) ILI tool. Investigation shall include field evaluations and
remediation as necessary. Emphasis should be placed on areas highlighted by tool
vendor, tie-ins welds, bends, offsets and areas where pipe is suspected of improperly
fitting the ditch.
b. Rover must complete the requirements of Item 1(a) of this Compliance Order by
November 1, 2019. Any identified locations shall be remediated as necessary, and a
detailed work plan and schedule shall be submitted to Director, Eastern Region within
30 days of discovery.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
It is requested (not mandated) that Respondent maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total to the
Director. It is requested that these costs be reported in two categories: (1) total cost associated
with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated
with replacements, additions and other changes to pipeline infrastructure.



CPF No. 1-2018-1018
Page 5
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for
each day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this
Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and
meet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective
action, remain in effect unless the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
October 16, 2019
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
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