{"operation":"document","citation":"CPF 52021035WL","title":"TAPROOT ROCKIES MIDSTREAM LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-07-08","effective_on":null,"summary":"CLOSED warning letter citing 195.573(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021035wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021035wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52021035wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52021035WL","body":"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.\n\nOfficial case documents:\n\n52021035WL_Warning Letter_07082021_(21-211736).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021035WL/52021035WL_Warning%20Letter_07082021_(21-211736).pdf\n\n52021035WL_Warning Letter_07082021_(21-211736)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52021035WL/52021035WL_Warning%20Letter_07082021_(21-211736)_text.pdf\n\n52021035WL_Warning Letter_07082021_(21-211736)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. KEVIN SULLIVAN\nJuly 8, 2021\nMr. Kevin Sullivan\nCEO\nTaproot Energy Partners\n555 17th Street, Suite 800\nDenver, CO 80202\nCPF 5-2021-035-WL\nDear Mr. Sullivan:\nOn April 12th, 2021, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nyour liquid gathering system in Weld County, Colorado.\nAs a result of this inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1\n\n\n\n1. §195.573 What must I do to monitor external corrosion control?\n(c) Rectifiers and other devices. You must electrically check for proper performance\neach device in the first column at the frequency stated in the second column.\nDevice Check frequency\nRectifier\nReverse current switch.\nDiode.\nInterference bond whose failure\nwould jeopardize structural\nprotection.\nAt least six times each calendar year, but\nwith intervals not exceeding 21∕2 months.\nOther interference bond At least once each calendar year, but with\nintervals not exceeding 15 months.\nTaproot Midstream failed to present documentation showing their rectifier was inspected every\n2½ months between July 2020 and January 2021.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a\nrelated series of violations. For violation occurring on or after January 11, 2021 and before May\n3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in\nTaproot Energy Partners being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2021-035-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\n2\n\n\n\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Ogirima, J. Luo, J. Williams (#21-211736)\nMr. Rod Donovan, COO & President, Taproot Energy Partners\n3","truncated":false,"body_characters":4428}