{"operation":"document","citation":"CPF 420155028W","title":"ROSE ROCK MIDSTREAM OPERATING, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-12-08","effective_on":null,"summary":"CLOSED warning letter citing 195.202, 195.228(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155028w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155028w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155028w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420155028W","body":"Warning Letter involving ROSE ROCK MIDSTREAM OPERATING, LLC. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.228(a). The case was opened on 2015-12-08 and is reported as closed as of 2015-12-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420155028W_Warning Letter_12082015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155028W/420155028W_Warning%20Letter_12082015.pdf\n\n420155028W_Warning Letter_12082015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155028W/420155028W_Warning%20Letter_12082015_text.pdf\n\n420155028W_Warning Letter_12082015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 8, 2015\nMr. Norm Szydlowski\nPresident\nRose Rock Midstream L.P.\n3030 NW Expressway, Suite 1100\nOklahoma City, Ok 73112\nCPF 4-2015-5028W\nDear Mr. Szydlowski:\nOn July 28-29, 2015, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your Isabel to Alva pipeline\nproject in Alva, Oklahoma.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolation(s) are:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nRose Rock Midstream failed to follow their written construction specification, Coating Specifications\nConstruction Addendum, April 25, 2014 as noted below:\nRose Rock’s Coating Specification, Section 7.6.2 states:\n“All coating must be mixed and applied in strict accordance with Manufacturer’s written\ninstruction. Such written instruction shall be available at the construction site and is included\nin the specification by this reference.”\n\n\n\nDuring PHMSA’s observation of the coating application, the manufacturer’s recommendation for\nmixing, thinning, handling and application of coating material was not available at the construction\nsite as required by Rose Rock’s coating specification. As a result, PHMSA had no means to\ndetermine if the contractor was following the recommended manufacturer’s procedure for field joint\ncoating application.\nRose Rock Midstream’s Coating Specification, Section 7.7.1 states:\n“The surface to be coated shall be free from moisture, dust, dirt, oil, grease, weld splatter,\nslag or other contaminants which might interfere with the coating or adhesion of the coating\nto the metal or adjacent coating.”\nAt the time of the inspection, the field joint surface preparation did not meet the requirements of the\noperator’s written specification. On July 28, 2015, visual inspection by PHMSA revealed slag\nresidue in crevices between the weld-cap and adjoining pipe at three locations after the joint surface\nhad been sand blasted in preparation for the coating application.\nRose Rock Midstream’s Coating Specification, Section 7.8.2.4 states:\n“The compressed air for blasting shall be free of water and oil. Adequate separators and\ntraps shall be provided and maintained during blasting operations. Blast equipment and\ncompressors shall be inspected and information recorded by COMPANY inspector at least\nthree (beginning, middle and end of shift) times per 8 hour shift to ensure the system is\nremaining free of water, oil and other contaminants.”\nAt the time of PHMSA’s inspection, the operator did not perform the equipment inspection as\nrequired by Rose Rock’s specification. In addition, no documents/records existed to substantiate that\nthe blasting equipment had been inspected before the coating was applied.\nRose Rock’s Midstream’s Coating Specification, Section 7.10.6.2 states:\n“Temperature of the environment is critical to proper application process. Coating\nmanufacturer’s recommendation for cure times and application must be followed to ensure\nproper application. The surface temperature of the pipe immediately prior to coating\napplication shall be monitored and controlled within the limits recommended by the coating\nsupplier. This process must be monitored and values recorded as per NACE RP 0105-2005\nor latest revision.”\nDuring the inspection, no documents/records existed to verify that the pipe’s surface temperature had\nbeen monitored before applying the coating material or that the temperature was within the\ncontrolled limits recommended by the coating supplier. In addition, the temperature recording\napparatus used for monitoring the ambient temperature during coating application was inoperable\nand out of calibration (last calibrated in 2013).\nAfter the above findings were identified to Rose Rock by PHMSA the operator made changes to their\nfield-joint coating inspection procedures and replaced the field-joint coating inspector. The changes\nwere confirmed during a follow-up field inspection on September 24, 2015.\n2\n\n\n\n2. §195.228 Welds and welding inspection: Standards of acceptability.\n(a) Each weld and welding must be inspected to insure compliance with the\nrequirements of this subpart. Visual inspection must be supplemented by\nnondestructive testing.\nRose Rock Midstream’s Certified Welding Inspector (CWI) failed to perform visual inspections of\nproduction welds as required by Subpart D of §195.228 during PHMSA’s site visit. The operator\nalso had no inspection records to show that the visual inspections had been performed.\nOn July 29, 2015, during PHMSA’s observation of field production welds at Pixley Crossing and\nPhillips Pipeline (Station 841+46 & 843+98), the CWI failed to inspect each weld-pass for defects\nand to ensure interpass cleaning was sufficient between passes to eliminate slag entrapment. In\naddition, there were no records to indicate that the inspector was performing visual inspections on\nprevious field welds to ensure adherence to the welding procedure and the acceptability of welds per\nSection 9, API Std. 1104.\nAfter the above findings were identified to Rose Rock by PHMSA, the operator made changes to\ntheir welding inspection procedures and replaced the CWI. The changes were confirmed during a\nfollow-up field inspection on September 24, 2015.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed\n$100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related\nseries of violations. We have reviewed the circumstances and supporting documents involved in this\ncase, and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do\nso will result in Rose Rock Midstream being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n4-2015-5028W. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original\ndocument you must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n3","truncated":false,"body_characters":7835}