{"operation":"document","citation":"CPF 320171006W","title":"ROVER PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-05-08","effective_on":null,"summary":"CLOSED warning letter citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320171006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320171006W","body":"Warning Letter involving ROVER PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2017-05-08 and is reported as closed as of 2017-05-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320171006W_Operator Response to Notice_06022017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171006W/320171006W_Operator%20Response%20to%20Notice_06022017.pdf\n\n320171006W_Warning Letter_05082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171006W/320171006W_Warning%20Letter_05082017.pdf\n\n320171006W_Warning Letter_05082017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320171006W/320171006W_Warning%20Letter_05082017_text.pdf\n\n320171006W_Warning Letter_05082017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 8, 2017\nMr. Ryan Coffey\nExecutive Vice President\nRover Pipeline, LLC\n800 E Sonterra Blvd.\nSuite 400\nSan Antonio, TX 78258\nCPF 3-2017-1006W\nDear Mr. Coffey:\nOn March 24 and April 4-11, 2017, a representative of the Michigan Public Service\nCommission (MIPSC), acting as an interstate agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code conducted\na construction inspection of Rover Pipeline LLC (Rover) in North Baltimore, Ohio and\nPinckney, Michigan.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\na) Rover personel did not follow standard API 1104 Section 6.3.1 for multiple\nqualification when qualifying their welders for the ET Rover Pipeline project.\nOn March 24, 2017, MIPSC staff observed the qualification of welders to API 1104\nmulitple qualification. When the MIPSC arrived, they noted that two branches were\n\n\n\nb) c) ready to be grinded for final fit. When the MIPSC asked who prepared the branches,\nthey were told by a welding inspector that they were cut by the welder assistants and\nnot by the welder qualifying. MIPSC was further told that the welder assistant could\ngrind to prepare the branch surface and observed the welding assistant lay out the\nbranch on the pipe.\nAPI 1104 Section 6.3.1 states \"For the second test, the welder shall lay out, cut, fit, and\nweld a full-sized branch-on-pipe connection.\" The Rover welder did not lay out or fit\nthe full size branch as required by API 1104.\nDuring the application of a two part epoxy coating to a girth weld on the mainline\nbetween station numbers 4740+00 and 4755+00, the Rover contractor did not follow\nprocedures for curing the applied coating.\nOn April 4, 2017, the MIPSC observed the contractor make several coating repairs to a\nsection of pipe that was damaged during lowering-in. After preparing the surface and\napplying the two part repair to the damage, the repair crew used a heat gun to speed\ndrying time. According to a Request for Information (RFI) regarding the clarification\nof Procedure Corrosion Control-6.0306-Coating of Field Joints, the response indicated\nthat \"At no time can heat be applied to accelerate cure time\". The RFI was approved\non March 27, 2017 and shows that it was distributed to the client, field engineer,\nconstruction manager, QC/QA, and the project manager.\nDuring the welding of a girth weld on the mainline between station numbers 4740+00\nand 4755+00, the Rover welder did not weld within the welding parameters on the root\nbead pass and the hot pass.\nOn April 11, 2017, the MIPSC observed the welding inspector take readings of\nvoltages on a girth weld. The root bead pass was measured at 55 volts. Then on the\nhot pass, the volts were again found at 55 volts. Welding procedure ETC-A112A-\nRover specifies the range for volts on the root bead pass and the hot pass as 18-38\nvolts. The welder was asked on both passes to readjust when the high voltages were\nnoted. The parameters were all within specification from that point on.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violation occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at\nthis time. We advise you to correct the item(s) identified in this letter. Failure to do so will\nresult in Rover Pipeline, LLC being subject to additional enforcement action.\n2\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 3-2017-1006W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":6028}