# WEST TEXAS GULF PIPELINE CO — Corrective Action Order

**Citation:** CPF 420155005H  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2015-03-12

CLOSED corrective action order.

## Document text

Corrective Action Order involving WEST TEXAS GULF PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2015-03-12 and is reported as closed as of 2020-02-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420155005H_Amended Corrective Action Order_09042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Amended%20Corrective%20Action%20Order_09042015.pdf

420155005H_Amended Corrective Action Order_09042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Amended%20Corrective%20Action%20Order_09042015_text.pdf

420155005H_Closure Letter_02122020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Closure%20Letter_02122020.pdf

420155005H_Closure Letter_02122020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Closure%20Letter_02122020_text.pdf

420155005H_Consent Agreement_10032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Agreement_10032016.pdf

420155005H_Consent Agreement_10032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Agreement_10032016_text.pdf

420155005H_Consent Order_03242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Order_03242017.pdf

420155005H_Consent Order_03242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Order_03242017_text.pdf

420155005H_Corrective Action Order_03122015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Corrective%20Action%20Order_03122015.pdf

420155005H_Corrective Action Order_03122015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Corrective%20Action%20Order_03122015_text.pdf

420155005H_Corrective Action Order_03122015_text.pdf

March 12, 2015
Mr. Michael J. Hennigan
President and Chief Executive Officer
Sunoco Logistics Partners L.P.
1818 Market Street, Suite 1500
Philadelphia, Pennsylvania 19103
Re: CPF No. 4-2015-5005H
Dear Mr. Hennigan:
Enclosed is a Corrective Action Order issued in the above-referenced case. It requires your
subsidiary, West Texas Gulf Pipe Line Company, to take certain corrective actions with respect
to the West Texas Gulf System #1, Unit 8514, Blum to Wortham Segment, which failed on
February 25, 2015, at mile post (MP) 257 in Navarro County near the Town of Dawson, Texas.
Service is being made by certified mail and facsimile. Service by electronic transmission is
deemed complete upon transmission and acknowledgement of receipt, or as otherwise provided
under 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion
of service.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. R. M. Seeley, Director, Southwest Region, OPS
Mr. David Chalson, Vice President, Operations, Sunoco Logistics Partners L.P.,
4041 Market Street, Aston, PA 19014
Mr. Todd Nardozzi, DOT Compliance Manager, Sunoco Logistics Partners L.P.



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
)
)
West Texas Gulf Pipe Line Company, a subsidiary of Sunoco Logistics )
Partners L.P., )
)
Respondent. )
___________________________________ )
) CPF No. 4-2015-5005H
CORRECTIVE ACTION ORDER
Purpose and Background:
This Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to
require West Texas Gulf Pipe Line Company (West Texas Gulf or Respondent), a subsidiary of
Sunoco Logistics Partners L.P., to take the necessary corrective actions to protect the public,
property, and the environment from potential hazards associated with the recent failure on
Respondent’s West Texas Gulf Pipeline.
On February 25, 2015, a reportable accident occurred on the West Texas Gulf Pipeline System
#1, Unit 8514, at mile post (MP) 257 on the Blum to Wortham Segment, resulting in the release
of approximately 50 barrels of crude oil (Failure). The West Texas Gulf Pipeline is
approximately 580 miles in length and transports crude oil from Colorado City, Texas, to
terminals in Longview and Nederland, Texas. The probable cause of the Failure is external
metal loss due to corrosion. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an
investigation of the accident. The preliminary findings of the ongoing investigation are as
follows.
Preliminary Findings:
• Respondent, a wholly-owned subsidiary of Sunoco Logistics Partners L.P., operates
approximately 580 miles of pipeline and delivers crude-oil from Colorado City, Texas, to
terminals in Longview and Nederland, Texas.
• Sunoco Logistics Partners L.P. (Sunoco Logistics) is a master limited partnership and
parent company of Respondent. Sunoco Logistics’ crude-oil Pipeline System consists of



CPF No. 4-2015-5005H
Page 2
approximately 5,300 miles of crude-oil trunk pipelines for high-volume, long-distance
transportation, and approximately 500 miles of crude-oil gathering lines that supply the
trunk lines. Sunoco Logistics’ general partner is owned by Energy Transfer Partners,
L.P.1
• The Affected Segment was originally constructed in 1952. It consists of Grade X-46 26-
inch diameter seamless pipe manufactured by National Tube and has a wall thickness of
0.312,” with a coal tar coating. It transports crude-oil from Blum, Texas, to Wortham,
Texas, a distance of approximately 63 miles (Affected Segment).
• The maximum operating pressure (MOP) of the pipeline is 750 psig. The MOP was
established using a risk-based alternative to hydrotesting. The operating pressure at the
time of the Failure was 625 psig.
• At approximately 12:00 a.m. Central Time (C.T.), on February 25, 2015, a Failure
occurred on the Affected Segment at MP 257 near the Town of Dawson, Texas (Failure
Site). The failed pipeline segment is a 26-inch diameter line. The release occurred
downstream of the company’s Blum Pump Station and upstream of the Wortham Pump
Station.
• As a result of the Failure, approximately 50 barrels of crude-oil flowed onto the ground
and approximately 1 barrel of crude oil flowed into a nearby pond. The Failure was
reported to the National Response Center (NRC Report # 1109008) on February 25,
2015, at approximately 3:33 a.m. Eastern Time (E.T.).
• Respondent was notified of the release at approximately 12:00 a.m. C.T. when local
emergency responders contacted the Sunoco Logistics Control Room to report crude oil
being released at Farm to Market (FM) Road 709 in Navarro, Texas. The report
indicated that crude-oil was being released from a casing vent onto the ground and in the
bar ditch adjacent to the pipeline crossing in that location.
• In response, Respondent shut down the pump units and immediately dispatched field
personnel to the Failure Site. Once on-site, Respondent’s field personnel deployed
booms and stationed vacuum trucks to collect oil from the roadway bar ditches, an
adjacent field, and a pond.
• The probable cause of the Failure is external metal loss due to corrosion.
• The accident did not cause any known fatalities, injuries, or evacuations.
• As a result of the Failure, the Farm to Market Road 709 was temporarily closed so that
Respondent’s field personnel could collect oil from the roadway. Additionally,
approximately 1 barrel of crude oil reached a nearby pond, and some oil traveled to an
adjacent field. The Failure Site is located in Navarro County, Texas, which has a
1 See http://www.sunocologistics.com/Investors/Company-Information/32/ (last accessed March 9, 2015).



CPF No. 4-2015-5005H
Page 3
population of approximately 48,000 people. Specifically, the release occurred near the
Town of Dawson, which has a population of approximately 800 people.
• PHMSA, Southwest Region (SW), Office of Pipeline Safety (OPS), made initial contact
with Respondent on February 25, 2015. Respondent advised PHMSA, SW, OPS, that it
would be notified prior to the pipeline being placed back in service.
• On February 25, 2015, Respondent exposed the pipeline and began repairs. At that time,
an 80% metal loss anomaly was discovered in close proximity to the Failure location on
the same pipeline joint.
• During repair of the failure location, Respondent installed a leak clamp on the newly-
discovered 80% metal loss anomaly.
• On February 26, 2015, Respondent returned the line to service at full operating pressure
without notice to PHMSA, SW, OPS.
• PHMSA, SW, OPS, requested repair records and In-line Inspection (ILI) data from the
Respondent and reviewed them between February 27, 2015, and March 6, 2015.
• According to Respondent’s ILI data, the Affected Segment was inspected in 2006 and
2011 using ILI tools to perform an assessment of the geometry and metal loss conditions
of the pipeline. The next assessment was scheduled for 2016.
• Further review revealed that there was 17% metal loss at the site of the Failure in 2006
and that by 2011 the metal loss had grown to 68%. The corrosion growth rate for this
feature predicted failure prior to Respondent’s next scheduled assessment in 2016.
• The newly-discovered 80% metal loss anomaly was not identified in the 2011
assessment.
• The cause and proliferation of the accelerated metal loss growth rates along the Affected
Segment is unknown at this time.
• Review of Respondent’s repair records revealed that the leak clamp used to repair the
newly-discovered 80% metal loss anomaly was not installed in accordance with the
manufacturer’s specifications and was not an appropriate application with respect to this
type of anomaly.
• Upon subsequent questioning by PHMSA, Respondent chose to take a voluntary 20%
operating pressure reduction and committed to removal of the 80% metal loss anomaly
repair on March 6, 2015.2
2 See Sunoco Logistics Partners L.P. email and attachments, (March 6, 2015).



CPF No. 4-2015-5005H
Page 4
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous, requiring corrective action, is set
forth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
pipeline without corrective measures is or would be hazardous to life, property, or the
environment. Additionally, having considered the nature of the failure; the unexplained
accelerated metal loss growth rates; the existence of at least one immediate repair anomaly not
previously identified; the location of the failure; the proximity to a public roadway and pond; the
age of the pipeline, and the threat of further failures and detrimental environmental impact due to
uncertainty in Respondent’s integrity management processes along this segment, I find that a
failure to issue this Order expeditiously to require immediate corrective action would result in
the likelihood of serious harm to life, property, or the environment.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The terms and conditions of this Order are
effective upon receipt.
Within 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited
review either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be
held as soon as practicable under the terms of such regulation, by notifying the Associate
Administrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,
PHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person
in Southwest Region Office or Washington, D.C.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, PHMSA will notify
Respondent of any additional measures that are required and an amended Order issued, if
necessary. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
Pursuant to 49 U.S.C. § 60112, I hereby order West Texas Gulf to immediately take the
following corrective actions for the Affected Segment:



CPF No. 4-2015-5005H
Page 5
Definitions:
“Affected Segment” – The “Affected Segment” means approximately 63 miles of West Texas
Gulf’s 26-inch pipeline designated as the Blum to Wortham segment located in rural East Texas.
“Director” – “Director” means the Director, Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety, Southwest Region, 8701 South Gessner,
Suite 1110, Houston, Texas 77074.
1. Operating Pressure Restriction. Respondent must maintain a twenty percent (20%)
pressure reduction in the actual operating pressure along the Affected Segment such
that the operating pressure on this segment will not exceed eighty percent (80%) of the
actual operating pressure in effect immediately prior to the failure on February 25,
2015.
a. This pressure restriction is to remain in effect until written approval to increase
the pressure or return the pipeline to its pre-failure operating pressure is
obtained from the Director.
b. This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-
pressure devices to be adjusted accordingly.
2. Removal of Pressure Restriction.
a. The Director may allow the removal or modification of the pressure restriction
upon a written request from Respondent demonstrating that restoring the
Affected Segment to its pre-failure operating pressure is justified, based on a
reliable engineering analysis showing that the pressure increase is safe,
considering all known defects, anomalies, and operating parameters of the
pipeline.
3. Mechanical and Metallurgical Testing. Within 30 days of receipt of this Order, West
Texas Gulf must complete mechanical and metallurgical testing and failure analysis of
the failed pipe, including an analysis of water samples and any foreign materials related
to the casing and pipeline failure environment. Complete the testing and analysis as
follows:
a. b. c. Within 10 days of receipt of this Order, develop and submit the testing protocol
and the proposed testing laboratory to the Director for prior approval.
Provide the Director with the scheduled date, time, and location of the testing to
allow for an OPS representative to witness the testing.
Ensure the testing laboratory distributes all reports whether draft or final in their
entirety to the Director at the same time they are made available to Respondent.
4. Root Cause Failure Analysis (RCFA). Within 45 days following receipt of the final
report from the metallurgical testing laboratory, Respondent must submit a Report
summarizing the results of the Root Cause Failure Analysis performed by the
Respondent or its Third Party. The Root Cause Failure Analysis shall include, at a



CPF No. 4-2015-5005H
Page 6
minimum, a structured method to evaluate the causal factors and perform an
investigation of the following management processes and the role they may have had in
the failure:
a. Respondent’s ILI specifications and instructions to its vendors and the timing
and detail of the information provided by the ILI vendor;
b. Respondent’s evaluation of corrosion growth rates, interaction criteria,
evaluation of ILI vendor data, determination of assessment schedules, processes
to confirm assumptions used in determining the assessment schedules (corrosion
growth rates, tool uncertainty, correlation, etc.); and
c. Respondent’s proposed corrective actions, including revisions to its Integrity
Management Plan and Pipeline Repair Procedures, as necessary, to prevent
recurrence of such a failure.
5. Remedial Work Plan.
a. Within 15 days following submittal of the Root Cause Failure Analysis Report,
Respondent must submit a Remedial Work Plan (RWP) to the Director for
approval.
b. The Director may approve the RWP incrementally without approving the entire
RWP.
c. Once approved by the Director, the RWP will be incorporated by reference into
this Order.
d. The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures Respondent will use to verify the integrity of the Affected
Segment. It must address all known or suspected factors and causes of the
February 25, 2015 failure.
e. The RWP must include a procedure or process to:
i. Perform an ILI inspection of the Affected Segment.
ii. Evaluate the results of the ILI inspection using appropriately
conservative interaction criteria and corrosion growth rates to determine
the features to be evaluated by direct examination, and the next
assessment schedule.
iii. Revise procedures, as identified in the RCFA Report, and complete
training of personnel on the revised procedures.
iv. Integrate the results of the metallurgical testing, root cause failure
analysis, and other corrective actions required by this Order with all
relevant pre-existing operational and assessment data for the Affected
Segment.
v. Determine if conditions similar to those contributing to the failure on
February 25, 2015 are likely to exist elsewhere on the West Texas Gulf
Pipeline.
f. Describe the inspection and repair criteria Respondent will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other identified
integrity threats along the Affected Segment. Include a description of how any
defects will be graded and a schedule for repairs or replacement.
g. Respondent shall include a proposed schedule for completion of the activities
included in the RWP.



CPF No. 4-2015-5005H
Page 7
h. Respondent must revise the RWP as necessary to incorporate new information
obtained during the failure investigation and remedial activities, to incorporate
the results of actions undertaken pursuant to this Order, and/or to incorporate
modifications required by the Director.
i. Submit any plan revisions to the Director for prior approval.
j. Respondent shall implement the RWP as it is approved by the Director,
including any revisions to the plan.
6. Monthly Reports to the Director. Respondent shall submit written reports to the
Director, detailing the status of the work associated with this Order, and providing a list
of upcoming work involving live-line welding, tie-ins or other activities that will
involve the submittal of Job Plans to the Director for approval. The first Report will be
due April 15, 2015, and monthly thereafter, on the 15th of each month until such time
that the schedule is adjusted and approved by the Director or this Order is closed.
Other Requirements:
1. Reporting. Submit monthly reports to the Director that: (1) include all available data and
results of the testing and evaluations required by this Order; and (2) describe the progress
of the repairs or other remedial actions being undertaken. The first monthly report is due
on April 15, 2015. The Director may change the interval for the submission of these
reports.
2. Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Order. Include in each
monthly report the to-date total costs associated with: (1) preparation and revision of
procedures, studies and analyses; (2) physical changes to pipeline infrastructure,
including repairs, replacements and other modifications; and (3) environmental
remediation, if applicable.
Approvals. With respect to each submission requiring the approval of the Director, the
Director may: (a) approve the submission in whole or in part; (b) approve the submission
on specified conditions; (c) modify the submission to cure any deficiencies; (d)
disapprove the submission in whole or in part and direct Respondent to modify the
submission; or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission, as approved or modified by the Director. If the Director
disapproves all or any portion of a submission, Respondent must correct all deficiencies
within the time specified by the Director and resubmit it for approval.
4. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Order upon a written request timely submitted and demonstrating
good cause for an extension.
The actions required by this Corrective Action Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Part [195, 193, 192],
3.



CPF No. 4-2015-5005H
Page 8
under any other order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or
under any other provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
Be advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted information
qualifies for confidential treatment under 5 U.S.C. 552(b).
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.
§ 60120.
In your correspondence on this matter, please refer to CPF No. 4-2015-5005H and for each
document you submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Corrective Action Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420155005H_Amended Corrective Action Order_09042015_text.pdf

September 4, 2015
Mr. Michael J. Hennigan
President and Chief Executive Officer
Sunoco Logistics Partners L.P.
c/o Mr. David Chalson
4041 Market Street
Aston, PA 19014
Re: CPF No. 4-2015-5005H
Dear Mr. Hennigan:
Enclosed is an Amendment to the Corrective Action Order issued in the above-referenced case
on March 12, 2015. Service by electronic transmission is deemed complete upon transmission
and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms
and conditions of this Order are effective upon completion of service.
Please direct any questions on this matter to Rod Seeley, Director, Southwest Region, Office of
Pipeline Safety, PHMSA at (713) 272-2852.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. R. M. Seeley, Director, Southwest Region, OPS
Mr. David Chalson, Vice President, Operations, Sunoco Logistics Partners, L. P., 4041
Market Street, Aston, PA 19014
Mr. Todd Nardozzi, Compliance Manager, Sunoco Logistics Partners, L. P., Sugar Land,
TX



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
)
)
West Texas Gulf Pipe Line Company, a subsidiary of Sunoco Logistics )
Partners L.P., )
)
Respondent. )
___________________________________ )
) CPF No. 4-2015-5005H
AMENDMENT
TO THE CORRECTIVE ACTION ORDER
Background and Purpose:
On March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a
Corrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas
Gulf or Respondent), a subsidiary of Sunoco Logistics Partners L.P., to take the necessary
corrective actions to protect the public, property, and the environment from potential hazards
associated with Respondent’s West Texas Gulf Pipeline.
1 PHMSA issued the Original CAO in
response to a failure that occurred on February 25, 2015, on the West Texas Gulf Pipeline
System #1, Unit 8514, at mile post (MP) 257 on the Blum to Wortham Segment, resulting in the
release of approximately 50 barrels of crude oil (Failure).
The West Texas Gulf Pipeline is approximately 580 miles in length and transports crude oil from
Colorado City, Texas, to terminals in Longview and Nederland, Texas.
Additional Preliminary Findings:
The preliminary findings in the Original CAO noted the failure and related information on
Respondent’s West Texas Gulf Pipe Line and details about the defect discovered as a result of
the February 25, 2015 failure. Since that time, the following events have occurred:
1 In the Matter of West Texas Gulf Pipe Line Company, Corrective Action Order (CPF No. 4-2015-5005H) dated
March 12, 2015.



CPF No. 4-2015-5005H
Page 2
• On April 8, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty and Compliance Order (NOPV1) to West Texas Gulf Pipe Line for failure to
report a serious accident that was alleged to have occurred on February 19, 2013.2
• On April 27, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty (NOPV2)3 to West Texas Gulf Pipe Line alleging improper pipeline repair
methods and failing to correct a metal loss condition that was known to exist prior to its
failure related to the accident for which the Original CAO was issued.
• On May 8, 2015, West Texas Gulf’s operator, Sunoco Pipeline, L.P. (SPLP), responded
to the NOPV, submitted an accident report for the reportable accident that occurred on
February 19, 2013, submitted a copy of the internal investigation report and stated that
the proposed civil penalties associated with the Probable Violations had been paid via
wire transfer on May 7, 2015.
• On June 7, 2015, a second leak of the same nature as the leak of February 25, 2015 was
reported to PHMSA by the Respondent at a location approximately seven (7) miles
downstream from the original leak for which the Original CAO was issued.
• On June 19, 2015, a major release of crude oil occurred at the Wortham Facility where
more than 3,000 barrels of crude oil leaked from a failed flanged connection on piping
that was installed in 2013 and associated with the project in which the serious accident
occurred.
• On May 28, 2015 and June 23, 2015, two reportable accidents4 occurred at the Sunoco
Pipeline, L. P. Corsicana facility as part of the Permian Express II construction project
which was managed by the same construction manager, and pipeline operator responsible
for projects upon which the West Texas Gulf February 19, 2013 accident and the June 19,
2015 accidents occurred.
The preliminary findings, additional failures and subsequent investigation into the events on the
West Texas Gulf Pipe Line system indicate that potential hazards associated with the operation
of this system remain. PHMSA has communicated its concerns about this pattern of failures
with Respondent since an accident similar to the 2013 accident subject of NOPV1 occurred on
the Respondent’s system in 2009.5
2 In the Matter of West Texas Gulf Pipe Line Company, Notice of Probable Violation and Proposed Civil Penalty
and Compliance Order (CPF No. 4-2015-5009) dated April 8, 2015.
3 In the Matter of West Texas Gulf Pipe Line Company, Notice of Probable Violation and Proposed Civil Penalty
and Compliance Order (CPF No. 4-2015-5012) dated April 27, 2015.
4 Reference OPID 19718, Sunoco Pipeline, L. P., Accident Reports filed on Form 7000-1, Report Numbers
20150230–20542, and 20150266–20613 for accidents occurring on May 28, 2015 and June 23, 2015, respectively.
5 In the Matter of West Texas Gulf Pipe Line Company, Final Order (CPF No. 4-2010-5010) dated August 1, 2012,
and Decision on Petition for Reconsideration (CPF No. 4-2010-5010) dated December 31, 2012.



CPF No. 4-2015-5005H
Page 3
Finding of Hazardous Condition
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, including amendments, after reasonable notice and the opportunity for a hearing,
requiring the operator of a pipeline determined to pose a hazard to take corrective actions to
protect people and the environment. These may include the suspended or restricted use of a
pipeline facility, physical inspection, testing, repair, replacement, or other action, as appropriate.
The basis for making a determination that a pipeline facility is or would be hazardous, requiring
corrective action, is set forth both in the above-referenced statute and 49 C.F.R. § 190.233, a
copy of which is enclosed.
After evaluating all available information regarding the safety of the West Texas Gulf Pipe Line
System, including the foregoing additional preliminary findings, and considering the nature,
circumstances, and gravity surrounding the pattern of accidents, the hazardous nature of the
product transported, the serious nature of the injury that went unreported, and the ongoing
investigation to determine the root cause of the multiple failures reported on Respondent’s
pipeline system, I find that the continued operation of the West Texas Gulf Pipe Line without
additional corrective measures would be hazardous to life, property, and the environment.
Accordingly, PHMSA hereby issues this Amendment to the CAO requiring the additional
actions specified herein be taken to protect life, property, and the environment. The additional
actions set forth in this Amendment to the CAO are in addition to the actions set forth in the
Original CAO and do not suspend or eliminate the requirements of the Original CAO, unless
otherwise specifically provided herein.
Amendments to Required Corrective Action
Pursuant to 49 U.S.C. § 60112 and 49 C.F.R. §190.233, West Texas Gulf Pipe Line, and its
operator Sunoco Pipeline, L. P. are ordered to comply with this Amendment to the CAO and take
the following additional corrective actions with respect to the West Texas Gulf Pipe Line. The
following item is added to the Corrective Action Order:
7. Before the Director, Southwest Region, OPS, approves the return to normal operating
pressure under Item 2 of the Original CAO, Respondent must complete the following:
A. Reinstate the 20% Operating Pressure Restriction ordered in the Original CAO, and
maintain that pressure restriction until the actions in Item 7B of this Amended CAO have
been completed.
B. For the entire West Texas Gulf Pipe Line System, its operation, and the Operating,
Maintenance and Construction policies and procedures under which it operates, including all
aspects for which the regulations in 49 C.F.R. §195 apply to the pipeline system and its
operator, SPLP must: (1) submit, for prior review and approval of the Director, a
comprehensive written plan, including timelines for specific actions to improve the safety
performance of Respondent’s West Texas Gulf Pipe Line System; and (2) hire an
independent third party pipeline expert in safety management systems to review and assess



CPF No. 4-2015-5005H
Page 4
the written plan, which third party expert must oversee the creation, execution and
implementation of the actions identified in the plan, and must provide bi-monthly monitoring
summaries to PHMSA and Respondent concurrently.
Respondent must address any deficiencies or risks identified in the third party’s
assessment, including completing repairs and implementing corrective actions related to
safety culture and safety management processes. The plan must be sufficiently detailed with
specific tasks, milestones and completion dates. At a minimum, the plan must address:
a. Organizational issues, including creation of a Safety Management System
promoting a safety culture that is equivalent to the elements considered essential
in the American Petroleum Institute (API) Recommended Practice (RP) 1173
including:
i. Management Commitment and Leadership
ii. Risk Management
iii. Operational Controls
iv. Incident Investigation, Evaluation and Lessons Learned
v. Safety Assurance and Continuous Improvement
vi. Competence, Training, Qualification and Development
vii. Emergency Preparedness and Response
viii. Documentation and Record Keeping
ix. Stakeholder Engagement
b. Contractor oversight and inspection of construction activities while performing
construction in existing or operating facilities, whether the facilities are owned or
operated by Respondent or other pipeline operators transporting hazardous
materials and subject to the requirements of 49 C.F.R. §195, and the commitment
to ensure adequate resources are provided to maintain safety during construction
activities. Specific attention shall be given to:
ii. iii. i. Adherence to Respondent’s Operations and Maintenance procedures
required by 49 C.F.R. 195 Subpart F,
Operator Qualification regulations in 49 C.F.R.§ 195 Subpart G, and
Drug and Alcohol Post Accident Testing regulations in 49 C.F.R.§199
c. Work Plans and the requirement for preparation of and adherence to a detailed
Work Plan when performing activities for which an existing Operations and
Maintenance procedure does not exist.
d. Any other risk, task, issue, or item that is necessary to promote and sustain the
safety of its pipeline system.
The actions required by this Amendment to the CAO are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under the Original CAO, and under 49
C.F.R. Parts 190, 194, 195 and 199, as applicable, or any other Order issued to Respondent under
authority of 49 U.S.C. § 60101, et seq., or under any other provision of Federal or State law.



CPF No. 4-2015-5005H
Page 5
After receiving and analyzing additional data in the course of this and the subject related
investigations, PHMSA may identify other corrective actions that need to be taken. In that event,
Respondent will be notified of any additional measures required and further amendment of the
CAO will be considered. To the extent consistent with safety, Respondent will be afforded
notice and an opportunity for a hearing prior to the imposition of any additional corrective
measures.
The terms and conditions of this Amended Corrective Action Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420155005H_Consent Agreement_10032016_text.pdf

U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of )
West Texas Gulf Pipe Line Company, Respondent. )
_
)
)
)
)
) CPF No. 4-2015-5005H
CONSENT AGREEMENT
On March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a
Corrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas
Gulf or Respondent), owned and operated by Sunoco Pipeline, LP (SPLP), to take the necessary
corrective actions to protect the public, property, and the environment from potential hazards
associated with Respondent’s West Texas Gulf Pipeline. PHMSA issued the Original CAO in
response to a failure that occurred on February 25, 2015, on the West Texas Gulf Pipeline System
#1, Unit 8514, at mile post (MP) 257 on the Blum-to-Wortham Segment, which resulted in the
release of approximately 30 barrels of crude oil (Failure).
Since that time, there have been additional accidents on the West Texas Gulf Pipeline that have
caused the expansion of PHMSA’s concerns regarding the safety of the West Texas Gulf System.
The following events have occurred:
• On April 8, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty and Compliance Order 4-2015-5009 (NOPV1) to Respondent for failure to report
a serious accident that occurred on February 19, 2013, at its Wortham, Texas Facility
(2013 Failure). Respondent has complied with the terms of the proposed Compliance
Order and paid the proposed penalty, so PHMSA issued a Final Order and closed the case
on November 3, 2015.
• On April 27, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty 4-2015-5012 (NOPV2) to Respondent for certain violations arising out of the
Failure, alleging improper pipeline repair methods and the failure to correct a metal-loss
condition that was known by Respondent to exist prior to the Failure. Respondent paid a
portion of the proposed penalty in that case and is awaiting the issuance of a Final Order.
• On June 7, 2015, West Texas Gulf experienced a second leak on the Affected Segment
involving external metal loss due to corrosion was reported to PHMSA by the Respondent
at a location approximately seven miles downstream from the original leak and nine and



one-half miles upstream of the Wortham, Texas Facility for which the Original CAO was
issued.
• On June 19, 2015, a major release of crude oil occurred at Respondent’s Wortham Facility,
where an estimated 3,300 barrels of crude oil leaked from a failed flanged connection on
piping that was installed in 2013 and associated with the construction/modification project
in which the February 19, 2013 accident occurred.
• On May 28, 2015 and June 23, 2015, two reportable accidents occurred at the SPLP
Corsicana facility as part of the Permian Express II construction project. This project was
managed by the same West Texas Gulf department responsible for projects upon which the
West Texas Gulf February 19, 2013 accident and the June 19, 2015 accidents occurred.
• On November 10, 2015, a failure of a control valve and release of crude oil occurred
while piping associated with the June 19, 2015 release was being replaced. Five people
were transported to the hospital for treatment of crude oil exposure to the face and eyes as
well as bruises and contusions after a relief valve failed when it was improperly
disconnected while under pressure. The accident was a result of improper isolation and
failure to follow instructions for safely de-energizing the valve before its removal.
• Taken together, the accidents described above raised serious concerns to PHMSA about
the overall safety of the West Texas Gulf Pipeline System, the processes by which West
Texas Gulf makes decisions about safety, how different parts of the company discuss and
learn from past mistakes, and whether there are sufficient measures in place for the
company to have an effective safety culture.
• On September 4, 2015, PHMSA issued an Amendment to the Original CAO (Amended
CAO), with preliminary findings describing the events that had occurred since the Original
CAO was issued in February 2015, and ordering West Texas Gulf to prepare a
comprehensive written plan to improve the safety performance of the Affected Segment to
hire an independent third party to review and oversee implementation of the plan, and other
corrective actions.
• West Texas Gulf has filed the required monthly reports regarding the actions taken to
address the issues in the CAO. The most recent report, dated April 15, 2016, indicates the
pipeline has returned to service and is limited to the 80% operating pressure based on
approvals provided by PHMSA.
The West Texas Gulf Pipe Line System is approximately 580 miles in length and transports crude
oil from Colorado City, Texas, to terminals in Longview and Nederland, Texas.
Respondent requested a hearing, but PHMSA and Respondent agreed that settlement of this
proceeding will avoid further administrative proceedings or litigation of this Notice and that entry
into this Consent Agreement is the most appropriate means of resolving issues raised in the
Amended CAO and in the public interest. Therefore, pursuant to 49 C.F.R. Part 190, without
adjudication of any issue of fact or law, and upon consent and agreement of Respondent and the
PHMSA (the Parties), the Parties agree as follows:



I. General Provisions
1. Respondent acknowledges that its pipeline system is subject to the jurisdiction of
the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative
orders issued thereunder. For purposes of this Consent Agreement, Respondent acknowledges that
it received proper notice of PHMSA's action in this proceeding and that the Amended CAO states
claims upon which relief may be granted pursuant to 49 U.S.C. 60101, et seq., and the regulations
and orders issued thereunder.
2. Respondent agrees to take the actions specified in Section II of this Agreement
(Corrective Measures) and to abide by the terms of this Consent Agreement. These actions,
including any work plans and schedules, shall automatically be incorporated into this Consent
Agreement. This Consent Agreement does not constitute a finding of violation of any Federal law
or regulation and may not be used in any civil or administrative proceeding of any kind as evidence
or proof of any fact, fault or liability, or as evidence of the violation of any law, rule, regulation or
requirement, except in a proceeding to enforce the provisions of this Consent Agreement.
3. After Respondent returns this signed Agreement, the PHMSA's representative will
present it to the Associate Administrator for Pipeline Safety recommending that the Associate
Administrator adopt the terms of this Agreement and Order. The terms of this Agreement and
Order constitute an offer of settlement until accepted by the Associate Administrator.
4. Respondent consents to the issuance of a Consent Agreement and Order, and hereby
waives any further procedural requirements with respect to its issuance. Respondent waives all
rights to contest the adequacy of notice, or the validity of the Consent Agreement and Order,
including all rights to administrative or judicial hearings or appeals. Upon issuance of a Consent
Agreement and Order for this matter, Respondent’s Request for Hearing will be deemed
withdrawn. The Original CAO will continue in full force and effect according to its terms, and the
Amended CAO will be deemed withdrawn upon issuance of a Consent Agreement and Order.
5. This Consent Agreement and Order shall apply to and be binding upon the PHMSA,
and upon Respondent, its officers, directors, and employees, and its successors, assigns, or other
entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Consent
Agreement and Order and any incorporated work plans and schedules to all of Respondent's
officers, employees, and agents whose duties might reasonably include compliance with this
Consent Agreement and Order.
6. For all transfers of ownership or operating responsibility of Respondent’s pipeline,
Respondent shall provide a copy of this Consent Agreement and Order to the prospective
transferee at least 30 days prior to such transfer and simultaneously provide written notice of the
prospective transfer to the PHMSA Region Director (Director) who issued the Notice.
7. This Consent Agreement and Order constitutes the final, complete and exclusive
agreement and understanding between the Parties with respect to the settlement embodied in this
Consent Agreement. The Parties acknowledge that there are no representations, agreements or



understandings relating to the settlement other than those expressly contained in this Consent
Agreement and Order, except that the terms of this Consent Agreement and Order may be
construed by reference to the original Corrective Action Order.
8. Nothing in this Consent Agreement and Order affects or relieves Respondent of its
responsibility to comply with all applicable requirements of the Federal pipeline safety laws, 49
U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. Nothing in this Consent
Agreement and Order alters PHMSA's right of access, entry, inspection, and information gathering
or the PHMSA's authority to bring enforcement actions against Respondent pursuant to the Federal
pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal
or State law.
9. This Consent Agreement and Order does not waive or modify any Federal, State,
or local laws or regulations that are applicable to Respondent's pipeline systems. This Consent
Agreement and Order is not a permit, or a modification of any permit, under any Federal, State, or
local laws or regulations. Respondent remains responsible for achieving and maintaining
compliance with all applicable Federal, State, and local laws, regulations and permits.
10. This Consent Agreement and Order does not create rights in, or grant any cause of
action to, any third party not party to this Consent Agreement and Order. The U.S. Department of
Transportation is not liable for any injuries or damages to persons or property arising from acts or
omissions of Respondent or its officers, employees, or agents carrying out the work required by
this Consent Agreement and Order. Respondent agrees to hold harmless the U.S. Department of
Transportation, its officers, employees, agents, and representatives from any and all causes of
action arising from any acts or omissions of Respondent or its contractors in carrying out any work
required by this Consent Agreement and Order.
II. Corrective Measures
11. Upon issuance of the Consent Agreement and Order, Respondent agrees to
perform the Corrective Measures set forth below.
12. Regarding the entire West Texas Gulf Pipe Line System, its operation, and the
Operating, Maintenance and Construction policies and procedures under which it operates,
including all aspects for which the regulations in 49 C.F.R. §195 apply to the pipeline system
and its operator, Respondent must:
(1) submit, for prior review and approval of the Director, a comprehensive written
plan, including timelines for specific actions to improve the safety record of
Respondent’s West Texas Gulf Pipe Line System; and
(2) hire an independent third-party pipeline expert in safety management systems
(SMS) to review and assess the written plan, which third-party expert must oversee the
creation, execution and implementation of the actions identified in the plan, and must
provide bi-monthly monitoring summaries to PHMSA and Respondent concurrently.
The specific role of the third-party SMS consultant is to review the creation, execution



and implementation of the SMS, by performing a gap analysis, recommending
improvements, observing the phases of implementation, providing consultation, and
communicating via written reports concurrently to PHMSA and Respondent.
13. Respondent must address any deficiencies or risks identified in the third party’s
assessment, including modifying repair procedures and implementing corrective actions related
to safety culture and safety management processes. If PHMSA disapproves of Respondent’s
rationale for deferment, the agency must provide written notice to Respondent in accordance
with Section III below. The plan must be sufficiently detailed with specific tasks, milestones and
completion dates. At a minimum, the plan must address:
(1) Organizational issues, including creation of a Safety Management System
promoting a safety culture that is equivalent to the elements considered essential in the
American Petroleum Institute (API) Recommended Practice (RP) 1173, including:
i. Management Commitment and Leadership
ii. Risk Management
iii. Operational Controls
iv. Incident Investigation, Evaluation and Lessons Learned
v. Safety Assurance and Continuous Improvement
vi. Competence, Training, Qualification and Development
vii. Emergency Preparedness and Response
viii. Documentation and Record Keeping
ix. Stakeholder Engagement;
(2) Contractor oversight and inspection of construction activities while
performing construction in existing or operating facilities, whether the facilities are
owned or operated by Respondent or other pipeline operators transporting hazardous
materials and subject to the requirements of 49 C.F.R. §195, and the commitment to
ensure adequate resources are provided to maintain safety during construction activities.
Specific attention shall be given to:
i. ii. iii. Adherence to Respondent’s Operations and Maintenance procedures
required by 49 C.F.R. 195 Subpart F,
Operator Qualification regulations in 49 C.F.R.§ 195 Subpart G, and
Drug and Alcohol Post Accident Testing regulations in 49 C.F.R.§199;
(3) Work planning process and requirements to define the appropriate level of
preparation, review, and approval to ensure safe performance of activities if the scope of
work is not in an existing O&M procedure;
(4) Any other task, issue, or item that is necessary to promote and sustain the
safety of the West Texas Gulf Pipe Line System.
14. The actions required by this Consent Agreement are in addition to and do not
waive any requirements that apply to Respondent’s pipeline system under the Original CAO, and
under 49 C.F.R. Parts 190, 194, 195 and 199, as applicable, or any other Order issued to
Respondent under authority of 49 U.S.C. § 60101, et seq., or under any other provision of



Federal or State law.
15. Consent Order Documentation Report (CODR). Respondent must create and
submit on a quarterly basis, a CODR. The intent is for the CODR to summarize all activities and
documentation associated with the Consent Order and to identify any activities or documentation
for the period reflected in previous report activities so the status of each item in the Consent Order
is reflected in each report. When the Respondent has concluded all of the required items in the
Consent Order, it will submit a final CODR to the Director. This will allow the Director to
complete a thorough review of all actions taken by the Respondent with regards to the Consent
Order prior to approving the closure of the Consent Order.
16. It is requested that Respondent maintain documentation of the costs associated with
implementation of this Agreement, and include in each report submitted pursuant to Item 15, the
to-date total costs associated with: (1) preparation and revision of procedures, studies and analyses;
(2) physical changes to pipeline infrastructure, including repairs, replacements and other
modifications; and (3) environmental remediation, if applicable.
17. The Director may grant an extension of time for compliance with any of the terms
of the Consent Order upon a written request, timely submitted, demonstrating good cause for an
extension.
18. For all submissions based upon this Consent Agreement that requires the approval
of the Director, the Director may (a) approve the submission in whole or in part; (b) impose specific
conditions; (c) modify the submission to cure any deficiencies; (d) reject the submission in whole
or in part; or (e) any combination of the above.
19. Respondent may appeal any decision of the Director to the Associate Administrator
for Pipeline Safety. Decisions of the Associate Administrator are final.
III. Review and Approval Process
20. With respect to any submission under Section II of this Consent Agreement that
requires the approval of the Director, the Director may: (a) approve, in whole or in part, the
submission, (b) approve the submission on specified conditions, (c) disapprove, in whole or in
part, the submission, or (d) any combination of the foregoing. If the Director approves, approves
in part, or approves with conditions, Respondent will take all action as approved by the Director,
subject to Respondent's right to invoke the dispute resolution procedures in Section IV with respect
to any conditions the Director identifies. If the Director disapproves all or any portion of the
submission, the Director will provide Respondent with a written notice of the deficiencies.
Respondent will correct all deficiencies within the time specified by the Director and resubmit it
for approval.
IV. Dispute Resolution
21. The Director and Respondent will informally attempt to resolve any disputes arising
under this Consent Agreement. If Respondent and the Director are unable to informally resolve
the dispute within 15 days, Respondent may request in writing, within 10 days, a written
determination resolving the dispute from the Associate Administrator for Pipeline Safety providing



all information that Respondent believes is relevant to the dispute. If the request is submitted as
provided herein, the Associate Administrator will issue a final determination in writing. The
existence of a dispute and the PHMSA's consideration of matters placed in dispute will not excuse,
toll, or suspend any term or timeframe for completion of any work to be performed under this
Agreement during the pendency of the dispute resolution process except as agreed by the Director
or the Associate Administrator in writing.
V. Enforcement
22. This Consent Agreement and Order is subject to all enforcement authorities
available to the PHMSA under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190. All work plans
and associated schedules set forth or referenced in Section II will be automatically incorporated
into this Consent Agreement and are enforceable in the same manner.
VI. Recordkeeping and Information Disclosure
23. Unless otherwise required in this Consent Agreement, Respondent agrees to
maintain records demonstrating compliance with all requirements of this Consent Agreement for
a period of at least five years following completion of all work to be performed. For any reports,
plans, or other deliverables required to be submitted to the PHMSA pursuant to this Consent
Agreement, Respondent may assert a claim of business confidentiality or other protections
applicable to the release of information by the PHMSA, covering part or all of the information
required to be submitted to the PHMSA pursuant to this agreement in accordance with 49 C.F.R.
Part 7. Respondent must mark the claim of confidentiality in writing on each page, and include a
statement specifying the grounds for each claim of confidentially. The PHMSA determines release
of any information submitted pursuant to this Consent Agreement in accordance with 49 C.F.R.
Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and/or the PHMSA policies, and
other applicable regulations and Executive Orders.
VII. Effective Date
24. The “Effective Date” as used herein is the date on which the Consent Order is issued
by the Associate Administrator incorporating the terms of this Agreement. Unless specified to the
contrary, all deadlines for actions required by this Consent Agreement run from the Effective Date
of the Consent Order.
VIII. Modification
25. The terms of this Consent Agreement may be modified by mutual agreement of the
Parties. Such modifications must be in writing and signed by both parties.
IX. Termination
26. This Consent Agreement terminates upon completion of all terms set forth in
Section II (Corrective Measures) as determined by the Director, Southwest Region. Respondent
may request written confirmation from the PHMSA when this Consent Agreement is terminated.



To the extent ongoing monitoring is required, PHMSA may terminate this Consent Agreement
with respect to all other requirements with the exception of such monitoring. Nothing in this
Consent Agreement prevents Respondent from completing any of the obligations earlier than the
deadlines provided for in this Agreement.
X. Ratification
27. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Consent Agreement and to execute and legally bind such
party to this document.
28. The Parties hereby agree to all conditions and terms of this Consent Agreement:
[SIGNATURES ON NEXT PAGE]



For Respondent:
__________________________
NAME
ADDRESS
WEST TEXAS GULF
______________________
Date
For PHMSA:
_________________________
Rodrick Seeley
Director, Office of Pipeline Safety
PHMSA Southwest Region
U.S. Department of Transportation
_________________________
Date

420155005H_Consent Order_03242017_text.pdf

March 24, 2017
Mr. Michael J. Hennigan
President and CEO
Sunoco Logistics Partners, LP
3807 West Chester Pike
Newtown Square, PA 19073
Re: CPF No. 4-2015-5005H
Dear Mr. Hennigan:
Enclosed please find the Consent Order issued in the above-referenced case, incorporating the terms
of the Consent Agreement signed by the Southwest Region Director, PHMSA, and your subsidiary,
West Texas Gulf Pipe Line Company, on September 29, 2016. Service of the Consent Order by
certified mail is deemed effective upon the date of mailing, or as otherwise 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. Rodrick Seeley, Director, Southwest Region, PHMSA
Mr. Mike Prince, President, West Texas Gulf Pipe Line Company
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 )
)
West Texas Gulf Pipe Line Company, ) CPF No. 4-2015-5005H
)
Respondent. )
____________________________________)
CONSENT ORDER
On March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a
Corrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas
Gulf or Respondent), which is owned and operated by Sunoco Pipeline, LP (SPLP), to take the
necessary corrective actions to protect the public, property, and the environment from potential
hazards associated with Respondent’s West Texas Gulf Pipeline. The West Texas Gulf Pipe Line
System is approximately 580 miles in length and transports crude oil from Colorado City, Texas,
to terminals in Longview and Nederland, Texas.
Since that time, additional accidents on the West Texas Gulf Pipeline have heightened PHMSA’s
concerns regarding the safety of the West Texas Gulf System as a whole. On September 4, 2015,
PHMSA issued an Amendment to the Original CAO (Amended CAO), that included preliminary
findings describing the events that had occurred since the issuance of the Original CAO and that
ordered West Texas Gulf to complete additional remedial actions.
On September 14, 2015, SPLP responded to the Amended CAO on behalf of West Texas Gulf,
contesting the Amended CAO and requesting a hearing. Since that time, however, PHMSA and
Respondent have held discussions and agreed that settlement of this proceeding would serve to
avoid further administrative proceedings or litigation regarding the Amended CAO, that entry of
ratification of the attached Consent Agreement would be the most appropriate means of resolving
the issues raised in the Amended CAO, and that settlement would best serve the public interest.
Accordingly, the foregoing Consent Agreement, dated October 3, 2016, is hereby attached
hereto and incorporated by reference into this Consent Order. Respondent is ordered to
comply with the terms of the Consent Agreement, effective immediately.



CPF No. 4-2015-5005H
Page 2
Pursuant to 49 U.S.C. 60101 et seq. and 49 C.F.R § 190.221, failure to comply with this
Consent Order may result in the assessment of civil penalties, or in the referral of the case for
judicial enforcement. The terms and conditions of this Consent Order are effective upon
service in accordance with 49 C.F.R. § 190.5.
March 24, 2017
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator for Pipeline Safety

420155005H_Closure Letter_02122020_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 12, 2020
Greg McIlwain
Senior Vice President, Operations
West Texas Gulf Pipeline Company
1300 Main Street
Houston, Texas 77002
CPF 4-2015-5005H
Dear Mr. McIlwain:
On March 12, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to West Texas Gulf Pipeline Company (WTG) a Corrective Action Order (CAO). The CAO
required WTG develop a restart plan, effect a pressure restriction on the affected segment, develop
an integrity verification and remediation plan for the pipeline system, and implement mitigative
actions necessary for the safe operation of the pipeline. An amendment to the CAO issued by
PHMSA on September 4, 2015 reinstated an operating pressure restriction and directed WTG to
complete additional remedial actions. The resulting Consent Order (CO), issued March 24, 2017,
included requirements to apply corrective measures to improve the safety record of WTG.
WTG has completed all requirements of the CAO and CO. This letter is to inform you that no
further action is contemplated with respect to the matters involved in this case, and this case is
now closed. Thank you for your cooperation.
Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420155005H>
- Source ID: `phmsa-enforcement`
- SHA-256: `c4d80c1b46b415ce3fb2390ad0b2041beb50109ea5d3d2b672a4d534eae0e275`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T19:56:24.846Z
- Document slug: `phmsa-enforcement-420155005h`

### Source metadata

```json
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  "operator": "WEST TEXAS GULF PIPELINE CO",
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  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 10,
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