# SUNOCO PIPELINE L.P. — Notice of Probable Violation

**Citation:** CPF 320045030  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2004-09-22

CLOSED notice of probable violation citing 195.402(c)(3), 195.404, 195.410, 195.420(b), 195.440.

## Document text

Notice of Probable Violation involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulations as 195,  195.402(c)(3),  195.404,  195.410,  195.420(b),  195.440. The case was opened on 2004-09-22 and is reported as closed as of 2005-10-14. Proposed civil penalty: $6,200. Assessed civil penalty: $6,200. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320045030_Final Order_10142005.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320045030/320045030_Final%20Order_10142005.pdf

320045030_Final Order_10142005.pdf

U.S. Department
400 Seventh Street, S.W.
of Transportation
Washington, D.C. 20590
Pipeline and
Administration
Hazardous Materials Safety
OCT 14 2005
Mr. David Justin
Vice President
Sunoco Pipeline L.P.
525 Fritztown Road
Sinking Spring, PA 19608
Re: CPF No. 3-2004-5030
Dear Mr. Justin:
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in the
above-referenced case. It makes findings of violation and assesses a civil penalty of $6,200 for those
violations. I acknowledge your wire transfer of $6,200 dated October 27, 2004, as payment in full
of the civil penalty assessed in the Final Order. The Final Order also finds that you have completed
the actions specified in the Notice required to comply with the pipeline safety regulations, and that
you have addressed the inadequacies in your procedures that were cited in the Notice of Amendment.
Your receipt of the Final Order constitutes service of that document under 49 C.F.R. § 190.5. This
case is now closed.
Sincerely,
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
CC:
Ivan Huntoon
Director, Central Region, OPS
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON. DC 20590
In the Matter of
Sunoco Pipeline L.P.,
Respondent.
CPF No. 3-2004-5030
FINAL ORDER
On September 22, 2004, in accordance with 49 C.F.R. 5 I90.207, the Director, Central Region,
Office ofPipeline Safety (OPS) issued to Respondent aNotice ofProbable Violation, Proposed Civil
Penalty, Notice of Amendment and Proposed Compliance Order (Notice). The Notice proposed
finding that Respondent had committed violations of 49 C.F.R .Part I95,proposed assessing a civil
penalty of $6,200 for the alleged violations, and proposedthatRespondent take certainmeasures to
correct the alleged violations. The Notice also proposed, in accordance with 49 C.F.R. 5 190.237
,
that Respondent amend its procedures for operations, maintenance and emergencies.
Respondent responded to the Notice by letter dated October 25,2004 (Response). Respondent did
not contest the allegations or the amount of the proposed civil penalty and submitted a wire transfer
in the amount of the proposed civil penalty ($6,200), waiving further right to respond and
authorizing the entry of this Final Order.
FINDINGS OF VIOLATION
Pursuant to 49 C.F.R. $ 190.209(aX1) and 49 U.S.C. 60122,I find that Respondent violated the
following sections of 49 C.F.R .Part 195 as more fully described in the Notice:
49 C.F.R. $ 195.404 (Item 2) - fallingto maintain up-to-date maps of its pipeline systems
including all crossings of certain buried utilities and foreign pipelines;
49 C.F.R. g 195.410 (Item 3) - failing to maintain line markers displaying a telephone
number where the operator can be reached at all times on a background of sharply contrasting
color at the specified locations;
49 C.F.R. 5 195.420 (item 4) - failing to adequately inspect and verify proper operation of
ihe speciiie,i rriain line valvcs.
These findings of violation will be considered prior offenses in any subsequent enforcement action
taken against Respondent. Having reviewed the record and considered the assessment criteia,I
assess the civil penalty of $6,200 already paid by Respondent'



L
COMPLIANCE ORDER
The Notice proposed a Compliance Order with respect to Items 2 and 3 in the Notice. Under
49 U.S.C. $ 60118(a), each person who engages in the transportation of hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under Chapter 601. The Regional Director has indicated that Respondent submitted an
appropriate schedule for revising the company's maps to reflect all utility crossings and has
completed activities bringing all of its line markers into compliance. Accordingly, since compliance
has been achieved with respect to these violations, it is not necessary to include compliance terms
in this Order.
AMENDMENT OF PROCEDIIRES
The Notice alleged inadequacies in Respondent's procedures for operations, maintenance and
emergencies and proposed to require amendment of Respondent's procedures to comply with the
requirements of 49 C.F.R. Part 195. Specifically, the Notice alleged that Respondent's procedures
for public education were inadequate to enable the public in the vicinity of the pipeline to recognize
ahazardots liquid pipeline emergency and report it to the operator or to police, flre, or other
appropriate public offi cials.
In its response, Respondent submitted copies ofits amended procedures, which the Director, Central
Region, OPS reviewed. Based on the results of this review, I find that Respondent's original
procedures as described in the Notice were inadequate to ensure safe operation ofits pipeline system,
but that Respondent has corrected the identified inadequacies. Accordingly, it is not necessary to
issue an Order directing Respondent to amend its procedures.
WARNING ITEM
The Notice did not propose a civil penalty or corrective action for Item 5 in the Notice, failure to
adequatelyestablish a continuing educationproglam ensuringthat stakeholders who maybe involved
in or affected by excavation activities are notified about its damage prevention program in
accordance with $ 195.440. Therefore, this is considered to be a warning item. Respondent
presented information its response showing that it has initiated actions addressing the item, including
upgrading its mailing lists of stakeholders receiving public awareness materials to ensure their
accuracy and completeness. Respondent is again warned that if OPS finds a violation for any of
these items in a subsequent inspection, enforcement action will be taken.
The terms and conditions of this Final Order are effective on teceipt.
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Date Issued
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Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320045030>
- Source ID: `phmsa-enforcement`
- SHA-256: `559fca9e221c3c0af363dd7aa4fdb678927489af3c5e6b47799f4d9f8171e197`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T21:52:42.896Z
- Document slug: `phmsa-enforcement-320045030`

### Source metadata

```json
{
  "cpf": "320045030",
  "operator": "SUNOCO PIPELINE L.P.",
  "region": "Central",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.402(c)(3)",
    "195.404",
    "195.410",
    "195.420(b)",
    "195.440"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 1,
  "attachments": [
    {
      "name": "320045030_Final Order_10142005.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320045030/320045030_Final%20Order_10142005.pdf",
      "bytes": 174831,
      "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": "SUNOCO PIPELINE L.P."
}
```
