# SUNOCO PIPELINE L.P. — Safety Order

**Citation:** CPF 42025054NOPSO  
**Type / status:** enforcement / current  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2025-02-13

OPEN safety order.

## Document text

Safety Order involving SUNOCO PIPELINE L.P.. The dataset does not identify a cited regulation for this case. The case was opened on 2025-02-13 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42025054NOPSO_Consent Agreement and Order_05022025_(25-332048).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025054NOPSO/42025054NOPSO_Consent%20Agreement%20and%20Order_05022025_(25-332048).pdf

42025054NOPSO_Consent Agreement and Order_05022025_(25-332048)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025054NOPSO/42025054NOPSO_Consent%20Agreement%20and%20Order_05022025_(25-332048)_text.pdf

42025054NOPSO_Notice of Proposed Safety Order_02132025_(25-332048).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025054NOPSO/42025054NOPSO_Notice%20of%20Proposed%20Safety%20Order_02132025_(25-332048).pdf

42025054NOPSO_Notice of Proposed Safety Order_02132025_(25-332048)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025054NOPSO/42025054NOPSO_Notice%20of%20Proposed%20Safety%20Order_02132025_(25-332048)_text.pdf

42025054NOPSO_Operator Response to Notice and Request for Informal Consultation_02192025_(25-332048).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025054NOPSO/42025054NOPSO_Operator%20Response%20to%20Notice%20and%20Request%20for%20Informal%20Consultation_02192025_(25-332048).pdf

42025054NOPSO_Consent Agreement and Order_05022025_(25-332048)_text.pdf

May 2, 2025
VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
Thomas Long
Chief Executive Officer
Energy Transfer LP
8111 Westchester Drive
Dallas, TX 75225
CPF No. 4-2025-054-NOPSO
Dear Mr. Long:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Sunoco Pipeline, LP,
which was executed on April 30, 2025. Service of the Consent Order and Consent Agreement by
electronic mail is deemed effective upon the date of transmission and acknowledgement of receipt,
or as otherwise provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Greg McIlwain, Executive Vice President, Operations, Energy Transfer, LP,
gregory.mcilwain@energytransfer.com
Eric Amundsen, Senior Vice President, Operations, Energy Transfer, LP,



eric.amundsen@energytransfer.com
Todd Stamm, Senior Vice President, Operations, Energy Transfer LP,
todd.stamm@energytransfer.com
Jennifer Street, Senior Vice President, Operations Services, Energy Transfer, LP,
jennifer.street@energytransfer.com
Keegan Pieper, Assistant General Counsel, Energy Transfer, LP,
keegan.pieper@energytransfer.com
Matthew Stork, Vice President, Technical Services, Energy Transfer, LP,
matthew.stork@energytransfer.com
Todd Nardozzi, Director, DOT Compliance, Energy Transfer, LP,
todd.nardozzi@energytransfer.com
Susie Sjulin, Director, DOT Compliance, Energy Transfer, LP,
susie.sjulin@energytransfer.com
Vince Murchison, Murchison O’Neill PLLC, vince.murchison@pipelinelegal.com
Haley O’Neill, Murchison O’Neill PLLC, haley.oneill@pipelinelegal.com
CONFIRMATION OF 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 )
)
Sunoco Pipeline LP, ) CPF No. 4-2025-054-NOPSO
a subsidiary of Energy Transfer, LP, )
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated February 13, 2025 the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Proposed Safety Order (Notice) to
Sunoco Pipeline, LP (Sunoco or Respondent).1
In accordance with 49 CFR § 190.239, the Notice alleged that conditions exist on the Twin Oaks
Discharge Pipeline System that pose an integrity risk to public safety, property, or the
environment. The Notice also proposed that Respondent take certain corrective measures to
remedy the alleged conditions and ensure that the public, property, and the environment are
protected from the potential risk.
In response to the Notice, Respondent requested an informal consultation, whereupon the parties
engaged in good-faith settlement discussions that have resulted in the Consent Agreement
attached to this Consent Order that settles all of the allegations in the Notice.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order. Sunoco is hereby ordered to comply with the terms of the Consent Agreement
pursuant to its terms.
Pursuant to 49 U.S.C. § 60101, et seq., failure to comply with this Consent Order may result in
the assessment of civil penalties as set forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in
referral to the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 CFR § 190.5.
______________________ ______________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
1 Sunoco is a subsidiary of Energy Transfer, LP.



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Sunoco Pipeline LP, ) CPF No. 4-2025-054-NOPSO
a subsidiary of Energy Transfer, LP, )
)
Respondent. )
____________________________________)
CONSENT AGREEMENT
On January 31, 2025, pursuant to Chapter 601 of title 49, United States Code, the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated
an investigation of Sunoco Pipeline, LP’s (Sunoco or Respondent)2 Twin Oaks Discharge
Pipeline system (Twin Oaks Pipeline or Pipeline) in Upper Makefield Township, Bucks County,
Pennsylvania. The Twin Oaks Pipeline is a 14-inch diameter pipeline that transports petroleum
products, including jet fuel, diesel, and gasoline, from the Twin Oaks Terminal in Aston,
Pennsylvania, to the Newark Terminal in Newark, New Jersey.
As a result of the investigation, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated February 13, 2025, a Notice of Proposed Safety Order (Notice). In
accordance with 49 CFR § 190.239, the Notice alleged that conditions exist on Respondent’s
pipeline system that pose a pipeline integrity risk to public safety, property, or the environment.
The Notice also proposed that Sunoco take certain corrective measures to remedy the alleged
conditions and ensure that the public, property, and the environment are protected from the
alleged integrity risk.
On February 19, 2025, Sunoco responded to the Notice by submitting a written response and
request for an informal consultation under 49 CFR § 190.239(b)(2). The first informal
consultation was held on March 5, 2025. As a result of the informal consultation, PHMSA and
Respondent (the Parties) agree that settlement of this proceeding by entry into this Consent
Agreement (Agreement) is the most appropriate means of resolving the issues raised in the
Notice, will avoid further administrative proceedings or litigation, and is in the public interest.
Therefore, pursuant to 49 CFR §§ 190.219 and 190.239(b)(2), without adjudication of any issue
of law or fact, and upon consent and agreement, the Parties agree to the following terms and
conditions.
2 Sunoco is a subsidiary of Energy Transfer, LP.



I. General Provisions
1. Respondent acknowledges that as the operator of the pipeline facilities subject to
the Notice, Respondent and its referenced pipeline facilities are 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 Agreement, Respondent acknowledges that it
received proper notice of PHMSA’s action in this proceeding and that the Notice 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, for purposes of this Agreement, to address integrity risk on the
Twin Oaks Pipeline by completing the actions specified in Section II of this Agreement
(Corrective Measures) and to abide by the terms of this Agreement.
3. After Respondent returns this signed Agreement to PHMSA, the Agency’s
representative will present it to the Associate Administrator for Pipeline Safety, recommending
that the Associate Administrator adopt the terms of this Agreement by issuing an administrative
order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement
constitute an offer of settlement until accepted by the Associate Administrator. Once accepted,
the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement.
4. Respondent consents to the issuance of the Consent 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 Order or this Agreement, including
all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution
provisions set forth herein.
5. This Agreement shall apply to and be binding upon PHMSA and Respondent, its
officers, directors, and employees, and its successors and assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
6. For all transfers of ownership or operating responsibility of Respondent’s pipeline
system referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice of the
transfer to the Director no later than 60 days after the transfer occurs.
7. This Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this Agreement.
The Parties acknowledge that there are no representations, agreements or understandings relating
to settlement other than those expressly contained in this Agreement.
8. Nothing in this Agreement 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 Agreement alters



PHMSA's right of access, entry, inspection, and information gathering or 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 law.
9. This Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent’s Twin Oaks pipeline. This Agreement 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 Agreement does not create rights in, or grant any cause of action to, any third
party not a party to this Agreement. 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 Agreement. The U.S.
Department of Transportation, its officers, employees, agents, and representatives shall not be
liable for any cause of action arising from any acts or omissions of Respondent or its contractors
in carrying out any work required by this Agreement.
11. This 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 Agreement.
II. Corrective Measures:
For the purposes of this Agreement:
“Affected Pipeline” refers to the entire Twin Oaks Pipeline, which is approximately 105.5
miles in length from the Twin Oaks Terminal in Aston, Pennsylvania, to the Newark
Terminal in Newark, New Jersey.
“Failure” refers to the failure of the Affected Pipeline in Upper Makefield Township,
Bucks County, Pennsylvania, discovered on January 31, 2025.
12. Upon issuance of the Consent Order, Respondent agrees to perform the
Corrective Measures set forth below.
13. Operating Pressure Restriction. Sunoco must implement and maintain a twenty
percent (20%) pressure reduction in the highest actual operating pressure along the entire length
of the Affected Pipeline, such that the operating pressure does not exceed eighty percent (80%) of
the highest actual operating pressure in effect within the 60-days prior to the discovery of the Failure
on January 31, 2025. Specifically, the pressure may not exceed the currently restricted pressure
of 880 pounds per square inch (psi).
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. Within 15 days of receipt of the Consent Order, Sunoco must provide the Director the
actual operating pressures of each pump station and each main line pressure regulating
station on the Affected Pipeline at the time of the Failure discovered on January 31,
2025, and the reduced pressure restriction set points at these same locations.
c. 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.
d. When determining the pressure restriction set-points, Sunoco must consider any in-line
inspection (ILI) features or anomalies present in the Affected Pipeline to provide for
continued safe operation while further corrective actions are completed.
e. Sunoco must review the pressure restriction monthly by analyzing the operating
pressure data, considering any ILI features or anomalies present in the Affected Pipeline.
Sunoco must immediately reduce the operating pressure to maintain the safe operations
of the Affected Pipeline, if warranted by the monthly review. Further, Sunoco must
submit the results of the monthly review to the Director including, at a minimum, the
current discharge set-points (including any additional pressure reductions), and
any pressure exceedance at discharge set-points.
14. Type A Sleeve Integrity Plan. Within 90 days of receipt of the Consent Order,
Sunoco must provide to the Director for approval a plan to evaluate the integrity of each Type A
sleeve on the Affected Pipeline. For each Type A sleeve, this must include the most accurate
information available regarding, at a minimum, the year of installation, a summary of the basis
for the original application (i.e., remediated condition), and identification of any scheduled
follow-up actions. The plan must also provide for the removal of each Type A sleeve on the
Affected Pipeline whose integrity cannot be reasonably assured. The plan must be part of the
Remedial Work Plan developed in Item 15 below. For any sleeve not removed, the plan must
provide a technical justification for the Type A Sleeve remaining on the Affected Pipeline and
describe the additional pipeline integrity management measures to be implemented to ensure the
safety and integrity of the Affected Pipeline in light of any integrity risk related to the sleeve.
15. Remedial Work Plan (RWP). Within 90 days of receipt of the Consent Order,
Sunoco must submit a Remedial Work Plan (RWP) to the Director for prior approval. The initial
RWP will be updated as needed to incorporate new and relevant information obtained during the
failure investigation and remedial activities undertaken pursuant to the Consent Order, and/or to
incorporate reasonable and technically supported modifications required by the Director. Sunoco
will submit any plan revisions to the Director for approval.
a. b. The Director may approve the RWP incrementally without approving the entire RWP.
Upon approval by the Director, the RWP becomes incorporated by reference into the
Consent Order.
c. d. Sunoco will implement the RWP as it is approved by the Director, including any
revisions to the plan.
The RWP must specify the tests, inspections, assessments, evaluations, and remedial
measures Respondent will use to verify the integrity of the Affected Pipeline. It must



e. address all known or suspected factors and causes of the Failure discovered on January
31, 2025. Sunoco must consider the risks and consequences of another failure to
develop a prioritized schedule for RWP-related work along the Affected Pipeline.
The RWP must include a procedure or process to:
i. Identify pipe in the Affected Pipeline with characteristics similar to the
contributing factors identified for the Failure discovered on January 31, 2025.
ii. Gather all data necessary to review the failure history (in service and pressure test
failures) of the Affected Pipeline and to prepare a written report containing all the
available information such as the locations, dates, and causes of leaks and
failures.
iii. iv. Integrate the results of the metallurgical testing, root cause failure analysis, and
other corrective actions required by the Consent Order with all relevant pre-
existing operational and assessment data for the Affected Pipeline. Pre-existing
operational data includes, but is not limited to, design, construction, operations,
maintenance, testing, repairs, prior metallurgical analyses, and any third-party
consultation information. Pre-existing assessment data includes, but is not limited
to, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval
surveys, and DCVG/ACVG surveys.
Determine if conditions similar to those contributing to the Failure discovered on
January 31, 2025, are likely to exist elsewhere on the Affected Pipeline.
v. Conduct additional field tests, inspections, assessments, and evaluations to
determine whether, and to what extent, the conditions associated with the Failure
discovered on January 31, 2025, and other failures from the failure history (see
(e)(ii) above) on the Affected Pipeline. At a minimum, this process must consider
all failure causes and specify the use of one or more of the following:
1) ILI tools that are technically appropriate for assessing the pipeline system
based on the cause of the Failure discovered on January 31, 2025, and that
can reliably detect and identify anomalies,
2) Hydrostatic pressure testing,
3) Stress corrosion cracking surveys; and
4) Other tests, inspections, assessments, and evaluations appropriate for the
failure causes.
Note: Sunoco may use the results of previous tests, inspections, assessments, and
evaluations if approved by the Director, provided the results of the tests,
inspections, assessments, and evaluations are analyzed with regard to the factors
known or suspected to have caused the Failure discovered on January 31, 2025.
vi. Describe the inspection and repair criteria Sunoco will use to prioritize, excavate,
evaluate, and repair anomalies, imperfections, and other identified integrity
threats. Include a description of how any defects will be graded and a schedule
for repairs or replacement.



f. vii. Based on the known history and condition of the Affected Pipeline, describe the
methods Sunoco will use to repair, replace, or take other corrective measures to
remediate the conditions associated with the pipeline Failure discovered on January
31, 2025, and to address other known integrity threats along the Affected Pipeline.
The repair, replacement, or other corrective measures must meet the criteria
specified in (e)(vi) above.
Include a proposed schedule for completion of the RWP.
16. Failure History Evaluation. Within 120 days of receipt of the Consent Order,
Sunoco must complete an investigation to determine to the extent possible when the Failure
discovered on January 31, 2025 began. This investigation must include a comprehensive
analysis of any odor complaints, SCADA, leak detection, surveillance, and other monitoring
systems on the Affected Pipeline. A final report of this investigation will be provided to the
Director and the conclusions of such will provide structure to the subsequent evaluation of the
effectiveness and capability of the current leak detection system employed on the Affected
Pipeline (Item 17).
17. Evaluation of the Leak Detection System. Within 120 days of the completion
of Item 16, Sunoco must complete an evaluation of the effectiveness and capability of Sunoco’s
leak detection system on the Affected Pipeline, including main lines, stub lines, and delivery
lines with particular focus on the conditions surrounding the Failure discovered on January 31,
2025 and those identified via the completion of Item 16. At a minimum, Sunoco’s evaluation
must consider the following factors; length and size of the pipeline, type of product carried, the
swiftness of leak detection, limitations on detectable quantities, location of nearest response
personnel, and leak history. This evaluation must also consider maximum operating pressure
(MOP), normal operating pressures, flow rates (or throughput), and impacts from any pressure
cycles or operational changes. For mainline segments that could affect high consequence areas
(HCAs), Sunoco’s evaluation must consider the pipeline’s proximity to the HCA and risk
assessment results.
a. Based on the collective findings of Items 16 and 17, evaluate potential corrective
measures to improve the effectiveness of Sunoco’s leak detection system where
possible on the Affected Pipeline. Sunoco must consider the latest advancements in
technology that present the potential to improve the capability of its leak detection
system on the Affected Pipeline to detect the type of leak for the Failure discovered on
January 31, 2025. To the extent any corrective measures are identified that would
demonstrably result in improving the capability of the leak detection system to detect
leaks that could potentially affect public safety, property, or the environment, similar
to leaks with characteristics common to the Failure discovered on January 31, 2025,
Sunoco will implement such corrective measures.
b. Evaluate Sunoco’s written plans and procedures for inspection and maintenance that
address leak detection, right-of-way inspection and repairs and determine the extent to
which the written plans contribute to the prevention of hazardous leaks. Based on the
findings, determine appropriate amendments to improve the extent to which the plans
contribute to the elimination of hazardous leaks.



c. Evaluate the effectiveness of Sunoco’s ROW inspection program as it pertains to leak
detection. This evaluation must consider any geographic regions or features (i.e., HCAs
and other sensitive areas) that may require specific or additional means of patrol. Based
on the findings, determine corrective measures to improve the effectiveness of
Sunoco’s ROW inspection program relative to leak detection.
d. Implement continuing long-term periodic testing and integrity verification measures to
ensure the ongoing safe operation of the Affected Pipeline considering the results of the
analyses, inspections, evaluations, and corrective measures undertaken pursuant to the
Order.
18. Third-Party Facilitator. Items 16 and 17 must each be facilitated by separate
personnel from a third-party with relevant expertise approved by the Director. Any
documentation from the third-party facilitators must be included in each required submission
to the Director.
19. Instrumented Leakage Survey. Within 30 days after the Consent Order is
issued, Sunoco must perform a ground instrument leakage survey or an excavation and evaluation
of the remaining Type A sleeve locations on the Affected Pipeline. Sunoco must investigate all
leak indications and remedy all leaks discovered. Sunoco must submit documentation of this
survey to the Director within 45 days after the Consent Order is issued.
20. Mechanical and Metallurgical Testing. Within 45 days after the Consent Order
is issued, Sunoco must complete mechanical and metallurgical testing and failure analysis of the
failed pipe, including an analysis of soil samples and any foreign materials. Mechanical and
metallurgical testing must be conducted by an independent third-party acceptable to the Director
and must document the decision-making process and all factors contributing to the Failure.
Respondent must complete the testing and analysis as follows:
a. Document the chain-of-custody when handling and transporting the failed pipe section
and other evidence from the Failure site.
b. c. Within 10 days of receipt of the Consent Order, develop and submit the testing protocol
and the proposed testing laboratory to the Director for prior approval.
Prior to beginning the mechanical and metallurgical testing, provide the Director with
the scheduled date, time, and location of the testing to allow for an OPS representative
to witness the testing.
d. 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.
21. Root Cause Failure Analysis. Within 120 days after the Consent Order is issued,
complete a root cause failure analysis (RCFA) and submit a final report of this RCFA to
the Director. The RCFA must be supplemented or facilitated by an independent third-party
acceptable to the Director and must document the decision-making process and all factors
contributing to the Failure. The final report must include findings, and any lessons learned and
whether the findings and lessons learned are applicable to other locations within the Affected
Pipeline system.



22. Emergency Response Plan and Training Review. Within 90 days of receipt of
the Consent Order, Sunoco must review and assess the effectiveness of its emergency response
plan with regards to the Failure. Sunoco must include in the review and assessment the on- scene
response and support, coordination, and communication with emergency responders and public
officials. Sunoco must also include a review and assessment of the effectiveness of its
emergency training program. Sunoco must amend its emergency response plan and emergency
training, if necessary, to reflect the results of this review. The documentation of this Emergency
Response Plan and Training Review must be available for inspection by OPS or provided to the
Director, if requested.
23. Public Awareness Program Review. Sunoco must review and assess the
effectiveness of its Public Awareness program with regards to the Failure. Sunoco must amend
its Public Awareness Program, if necessary, to reflect the results of this review. The
documentation of this Public Awareness Plan Program Review must be available for inspection
by OPS or provided to the Director, if requested.
24. Extensions of Time. The Director may grant an extension of time for compliance
with any of the terms of the Agreement upon a written request timely submitted demonstrating
good cause for the extension. The Director shall respond in writing to any such request.
III. Review and Approval Process:
25. With respect to any submission under Section II (Corrective Measures) of this
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, reasonable 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
actions 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 a
written notice of the deficiencies. Respondent will correct all deficiencies within the time
specified by the Director and resubmit the submission for approval.
IV. Dispute Resolution:
26. The Director and Respondent will informally attempt to resolve any disputes
arising under this Agreement, including any decision of the Director under the terms of Section
II (Corrective Measures). If Respondent and the Director are unable to informally resolve the
dispute within 15 business days after the dispute is first raised, in writing, to the Director,
Respondent may submit a written request for a determination resolving the dispute from the
Associate Administrator for Pipeline Safety. Such request must be made in writing and provided
to the Director, counsel for the Southwest Region, and to the Associate Administrator, no later
than 10 business days following the 15-day deadline for informal resolution referenced in this
paragraph. Along with its request, Respondent must provide the Associate Administrator with
all information Respondent believes is relevant to the dispute. Decisions of the Associate
Administrator under this paragraph will constitute final agency action and be subject to judicial



review. The existence of a dispute and 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
Respondent and the Director or the Associate Administrator in writing.
V. Enforcement:
27. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties
under 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues and
referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that
Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil
penalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All work plans and
associated schedules set forth or referenced in Section II are automatically incorporated into this
Agreement and are enforceable in the same manner.
VI. Effective Date:
28. The term “Effective Date,” as used herein, is the date on which the Consent Order
is executed by the Associate Administrator incorporating the terms of this Agreement. The
Director shall consider the actions that Respondent performed after the Failure and prior to the
Effective Date of this Agreement in determining whether Respondent has satisfied the terms and
conditions in Section II (Corrective Measures) of this Agreement.
VII. Recordkeeping and Information Disclosure:
29. Unless otherwise required in this Agreement, Respondent agrees to maintain
records demonstrating compliance with all requirements of this Agreement for a period of at
least five (5) years following completion of all work to be performed, unless a longer period of
time is required pursuant to 49 CFR parts 190-199. For any reports, plans, or other deliverables
required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim
of business confidentiality or other protections applicable to the release of information by
PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to
this Agreement in accordance with 49 CFR 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. PHMSA determines release of any information submitted pursuant to
this Agreement in accordance with 49 CFR Part 7, the Freedom of Information Act, 5 U.S.C. §
552, DOT and PHMSA policies, and other applicable regulations and Executive Orders.
VIII. Modification:
30. The terms of this Agreement may be modified by mutual agreement of the Parties.
Such modifications must be in writing and signed by both parties.



IX. Termination:
31. This Agreement will remain in effect until the Corrective Measures in Section II
are satisfied, as determined by the Director. The Agreement shall not terminate until the
Director confirms, in writing, that the Agreement is terminated in accordance with this
paragraph. Nothing in this Agreement prevents Respondent from completing any of the
obligations earlier than the deadlines provided for in this Agreement.
X. Ratification:
32. The Parties’ undersigned representatives certify that they are fully authorized to
enter into the terms and conditions of this Agreement and to execute and legally bind such party
to this document.
33. The Parties hereby agree to all findings, conditions, and terms of this Agreement.
[Signature Lines on Following Page]



For Sunoco Pipeline LP:
_______________________________
Todd Stamm, Senior Vice President - Operations
________________________
Date
For PHMSA:
________________________________________
Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety
________________________
Date

42025054NOPSO_Notice of Proposed Safety Order_02132025_(25-332048)_text.pdf

VIA ELECTRONIC MAIL TO: tom.long@energytransfer.com
February 13, 2025
Thomas Long
Chief Executive Officer
Energy Transfer LP
8111 Westchester Drive
Dallas, TX 75225
CPF No. 4-2025-054-NOPSO
Dear Mr. Long:
Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The
Notice proposes that Sunoco Pipeline, LP, take certain measures with respect to the Sunoco Twin
Oaks Discharge pipeline system to ensure pipeline safety. Your options for responding are set
forth in the Notice. Service of this Notice by electronic mail is deemed effective upon the date of
transmission, or as otherwise provided under 49 CFR § 190.5.
We look forward to a successful resolution to ensure pipeline safety. Please direct any questions
on this matter to me at (713) 773-7215.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Notice of Proposed Safety Order
Copy of 49 C.F.R. § 190.239
Cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Greg McIlwain, Executive Vice President, Operations, Energy Transfer LP
Eric Amundsen, Senior Vice President, Operations, Energy Transfer LP
Todd Stamm, Senior Vice President, Operations, Energy Transfer LP
Jennifer Street, Senior Vice President, Operations Services, Energy Transfer LP
Keegan Pieper, Assistant General Counsel, Energy Transfer LP
Mr. Matthew Stork, Vice President, Technical Services, Energy Transfer LP



Mr. Todd Nardozzi, Director – DOT Compliance, Energy Transfer LP
Ms. Susie Sjulin, Director – DOT Compliance, Energy Transfer LP
Mr. Vince Murchison, Murchison O’Neill PLLC



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
SOUTHWEST REGION
HOUSTON, TEXAS
____________________________________
)
In the Matter of )
)
Sunoco Pipeline LP, ) CPF No. 4-2025-054-NOPSO
)
Respondent )
____________________________________)
NOTICE OF PROPOSED SAFETY ORDER
Introduction and Purpose
The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), is issuing this Notice of Proposed Safety Order (NOPSO or Notice) to Sunoco Pipeline LP
(Sunoco or Respondent)1 pursuant to the authority provided in 49 U.S.C. § 60117 and 49 CFR §
190.239. As explained in more detail below, PHMSA has initiated an investigation of the safety
of Sunoco’s Twin Oaks Discharge pipeline system (Twin Oaks Pipeline or Pipeline) in Upper
Makefield Township, Bucks County, Pennsylvania. PHMSA initiated the investigation in
response to a release on the Twin Oaks Pipeline that Sunoco discovered on January 31, 2025
(Failure).2 The Twin Oaks Pipeline is a hazardous liquid pipeline facility that is subject to
PHMSA’s jurisdiction pursuant to the Pipeline Safety Act, 49 U.S.C. § 60101 et seq., and Pipeline
Safety Regulations, 49 CFR Parts 190 to 199.
PHMSA’s ongoing investigation indicates that conditions may exist on the Twin Oaks Pipeline
that pose a pipeline integrity risk to public safety, property, or the environment. Specifically,
PHMSA’s preliminary investigation indicates that the Pipeline experienced a leak in a high
consequence area for at least 16 months, resulting in the release of jet fuel that has migrated into
several adjacent water wells and caused additional impacts to property and the environment.
PHMSA’s preliminary investigation also indicates that the leak originated at a sleeve installed in
the mid-1990s, that there are at least 44 other sleeves of a similar vintage installed at other locations
on the Pipeline, and that these locations may be at risk of experiencing a similar leak in the future.
For these reasons, it appears that the continued operation of the Twin Oaks Pipeline without
corrective measures would pose a pipeline integrity risk to public safety, property, or the
environment.
1 Sunoco is a subsidiary of Energy Transfer LP.
2 Sunoco became aware of the release on January 31, 2025, however, the first day of the release is unknown.



This NOPSO notifies Sunoco of the preliminary findings of the investigation and proposes that
Sunoco take measures to ensure that the public, property, and the environment are protected from
the potential risk.
Background
On September 25, 2023, the Pennsylvania Public Utilities Commission (PAPUC) notified PHMSA
of an odor complaint that a resident at 128 Walker Road, Upper Makefield Township,
Pennsylvania, previously reported to the Pennsylvania Department of Environmental Protection
(PADEP). The resident’s report indicated that there was a strange taste and the smell of gasoline
in their well water.
After being notified of the odor complaint, PHMSA directed Sunoco to conduct an investigation.
Sunoco responded by testing additional local wells, performing soil testing, and excavating a 25-
foot section of the Twin Oaks Pipeline. Sunoco did not discover a leak at that time, and all samples
indicated a negative result for hydrocarbons.
On January 21, 2025, PADEP informed PHMSA that samples obtained from a well at the property
located at 107 Spencer Road, Upper Makefield Township, Pennsylvania, indicated the presence of
kerosene (a major component of JP-8 jet fuel). PHMSA Accident Investigation Division (AID)
notified Sunoco of these results and directed Sunoco to conduct another investigation.
On January 31, 2025, Sunoco identified a leak on the Twin Oaks Pipeline after excavating a
previously repaired location adjacent to 121 Glenwood Drive, at pipeline station 52/4170
(2787+30). The leak appeared to be a slow drip from a sleeved portion of the pipeline. The sleeve
had been installed in 1995 to reinforce a dent.
After locating the leak, Sunoco shut-in a segment of the Twin Oaks Pipeline by closing valves at
Bucks pump Station, Delaware River (West), Delaware River (East), and Hopewell. High and low
point vent and extraction vent thread-o-ring fittings (TORs) were installed to drain the jet fuel
product to vacuum trucks and tankers at the extraction points. Sunoco cut out the failed section
without removing the Type A sleeve and transported that section to Columbus, Ohio, for inspection
and metallurgical analysis by a third party, DNV.
Sunoco notified the National Response Center (NRC) of the release on the Twin Oaks Pipeline at
16:25 Eastern Time on January 31, 2025. Sunoco made a second report to the NRC on February
2, 2025, at 16:03 Eastern Time and provided an estimated release amount of 156 barrels. Sunoco
also notified PADEP.
On February 2, 2025, Sunoco completed its repair of the failed section and returned the Twin Oaks
Pipeline to service. The Twin Oaks Pipeline is currently operating at a reduced pressure of 880
pounds per square inch gauge (psig), which is 20 percent below the operating pressure at the time
Sunoco discovered the failure.
The preliminary findings of PHMSA’s ongoing investigation are as follows:



Preliminary Findings:
• The Twin Oaks Pipeline is a 14-inch diameter pipeline that transports petroleum
products, including jet fuel, diesel, and gasoline, from the Twin Oaks Terminal in
Aston, Pennsylvania, to the Newark Terminal in Newark, New Jersey. The Twin Oaks
Pipeline includes one break out tank in the Newark Terminal, and one pump station in
Bucks County, Pennsylvania.
• The Twin Oaks Pipeline was originally constructed in 1958. The pipe at the failure
location is 0.25 inches thick, API 5L grade X-52, seamless, and was manufactured by
National Tube Supply Company. The pipeline has a somastic (asphalt mastic) coating
and cathodic protection. The maximum operating pressure (MOP) of the Twin Oaks
Pipeline is 1200 psig. When Sunoco discovered the failure, the operating pressure was
1100 psig.
• On September 25, 2023, PHMSA notified Sunoco of an odor complaint that PADEP
received from a resident at 128 Walker Road. Sunoco investigated the complaint as
follows:
o Respondent dispatched a pipeline technician to probe with a photoionization
detector (PID) Gas detector along the pipeline behind 121 Glenwood and in
front of 128 Walker and 123 Glenwood; all results were reported as non-detect.
o Respondent hired a contractor to test the well water at 128 Walker Road; results
were reported as non-detect. The contractor also tested the well water for 121
and 123 Glenwood Drive, and 126 Walker Road; all results were reported as
non-detect.
o Respondent excavated about 25 feet of the pipeline located behind 121
Glenwood Drive with no issues or concerns detected. Respondent performed
soil testing in the excavation and those results were reported as non-detect.
o The operator performed a 4-hour static pressure test to check for lowering
pressure indicative of a pipeline leak; Respondent has indicated that the results
were reported to be within acceptable limits.
• On June 28, 2024, Respondent received an odor complaint from 108 Spencer Road.
Respondent investigated the complaint as follows:
o Respondent dispatched a pipeline technician with a 4 - Gas detector to the site;
all results were reported as non-detect. No dead vegetation or anything out of
the ordinary was observed above the pipeline.
o Respondent did not report this odor complaint to PHMSA.



• On July 21, 2024, Respondent received an odor complaint from 121 Glenwood Drive.
Respondent investigated the complaint as follows:
o Respondent dispatched a pipeline technician to the site and probed with a 4 -
Gas detector; all results were reported as non-detect. No dead vegetation or
anything out of the ordinary was observed above the pipeline.
o Respondent did not report this odor complaint to PHMSA.
• On November 21, 2024, Respondent received an odor complaint from 107 Spencer
Road. Respondent investigated the complaint as follows:
o Respondent dispatched a pipeline technician and probed with a 4 - Gas detector
to the site; all results were reported as non-detect. No dead vegetation or
anything out of the ordinary was observed above the pipeline.
o Respondent performed a 4-hour static pressure test to check for lowering
pressure indicative of a pipeline leak; the results were reported to be within
acceptable limits (although acceptance criteria were not reported by the
operator).
o Respondent did not report this odor complaint to PHMSA.
• On January 21, 2025, PADEP informed PHMSA that samples obtained from a well at
107 Spencer Road indicated the presence of kerosene (a major component of JP-8 jet
fuel). PHMSA AID notified Sunoco of the test results and directed Sunoco to
investigate.
• From January 22 through January 31, 2025, Respondent proceeded to probe the entire
pipeline from 121 Glenwood Drive to 155 Glenwood Drive using a PID Gas detector;
all results were non-detect. Respondent had a contractor sample about twenty-five (25)
landowners’ well water for hydrocarbons. Three (3) landowners’ wells were identified
as having positive results for hydrocarbons at 107 Spencer Road, 108 Spencer Road,
and 128 Glenwood Drive.
• On January 31, 2025, Respondent identified the leak location after excavating a
previously repaired location on the pipeline adjacent to 121 Glenwood Drive, at station
52/4170 (2787+30). Visual inspection revealed that the leak was a slow drip from a
Type A sleeve originally installed in 1995. Type A sleeves are used to reinforce a
portion of pipe with a non-leaking defect, with the goal of restoring the pipeline’s
original strength.
• The Failure occurred adjacent to 126 Walker Rd, Upper Makefield Township, Bucks
County, Pennsylvania. The exact start date of the Failure is unknown. The failure
occurred in a High Consequence Area (HCA) as defined in 49 CFR § 195.450, located
in a residential subdivision just to the west of the Delaware River. The Twin Oaks



Pipeline runs through mostly suburban areas. It travels in a northeast direction from
Philadelphia, Pennsylvania, to Newark, New Jersey. The pipeline crosses numerous
rivers and waterways and runs adjacent to numerous state and local parks.
• Sunoco notified the National Response Center (NRC) of the Failure at 16:25 Eastern
Time on January 31, 2025, and reported a release of 156 barrels of jet fuel.
• After locating the leak, Sunoco shut in a segment of the Twin Oaks Pipeline, closing
valves at Bucks pump Station, Delaware River (West), Delaware River (East), and
Hopewell. High and low point vent and extraction vent thread-o-ring fittings (TORs)
were installed to drain the jet fuel product to vacuum trucks and tankers at the extraction
points.
• Sunoco cut out the failed section of the Twin Oaks Pipeline without removing the Type
A sleeve and transported the pipe to DNV in Columbus, Ohio, for inspection and
metallurgical analysis.
• On February 2, 2025, PHMSA Southwest Region Director by email informed Sunoco
he did not object to the repair plan and return to service plan for the pipeline.
• Sunoco completed the repairs and returned the pipeline to service on February 2, 2025.
• Local drinking water wells are contaminated with JP-8 jet fuel to varying degrees. Jet
fuel apparently has entered the aquafer and is detected in various quantities in
surrounding drinking water wells to the east of the Failure location.
• The release of jet fuel poses a risk to public safety, property, or the environment. Jet
fuel is a colorless flammable liquid that ignites at certain temperatures; jet fuel exposure
can lead to skin irritation and drowsiness or dizziness in affected populations; and jet
fuel ingestion may cause harm to the respiratory tract, gastrointestinal tract, and
nervous systems.3
• During a public meeting held on February 6, 2025, residents of other neighborhoods
located in the vicinity of the Failure reported a gasoline smell in their water.
• On February 8 and February 10, 2025, Sunoco excavated five (5) locations immediately
upstream of the Failure location to evaluate the condition of six (6) Type A sleeves that
had been installed in 1989 to reinforce a variety of defect types. These excavations
discovered no additional leaks and no abnormal conditions were noted.
• On February 12, 2025, PHMSA investigators witnessed the preliminary phase of the
metallurgical testing of the portion of the pipeline that Sunoco sent to DNV for further
3 “Public Health Statement: JP-5, JP-8, and Jet A Fuels,” Agency for Toxic Substances and Disease Registry,
Division of Toxicology and Human Health Services, March 2017, https://www.atsdr.cdc.gov/ToxProfiles/tp121-c1-
b.pdf. These hazards are confirmed by the Safety Data Sheets (SDS) for the JP-8 jet fuel transported in the Twin
Oaks Pipeline.



analysis. The preliminary testing indicates that the failure occurred as a result of a 2.5-
inch axial crack associated with a bottom-side dent.
• Sunoco has advised PHMSA that there are at least forty-four (44) other Type A sleeves
on the Twin Oaks Pipeline that were installed in the late 1980s and early 1990s.
PHMSA understands some of those Type A sleeves were installed to reinforce dents.
• PHMSA is aware of a gasoline release in Huntersville, North Carolina, discovered on
August 14, 2020, in which 28,571 barrels were released through a through-wall crack
which developed in a shallow dent reinforced with a Type A sleeve. The release was
also not detected by the pipeline operator’s leak detection system.
• Prior to this Failure, there have been two (2) reportable failures on the Twin Oaks
Pipeline since 1986.
o On October 7, 1986, a failure occurred in Montgomery County, Pennsylvania,
which was caused by a crack in the pipeline, resulting in the release of 5260 barrels
of refined product.
o On March 19, 2004, a failure occurred in Delaware County, Pennsylvania, which
was caused by external corrosion, resulting in the release of 50 barrels of refined
product.
• The investigation of the Failure is on-going, and information could change. These
preliminary findings may be amended based on further findings during the
investigation.
Proposed Issuance of Safety Order
Section 60117(m) of Title 49, United States Code, provides for the issuance of a safety order, after
reasonable notice and the opportunity for a hearing, requiring corrective measures, which may
include physical inspection, testing, repair, or other action, as appropriate. The basis for making
the determination that a pipeline facility has a condition or conditions that pose a pipeline integrity
risk to public safety, property, or the environment is set forth both in the above-referenced statute
and 49 CFR § 190.239, a copy of which is enclosed.
After evaluating the foregoing preliminary findings of fact, and having considered the
characteristics of the pipeline, including prior Type-A sleeve repairs involving dents and other
defects; the prior failures of the pipeline; the hazardous nature of the petroleum products, including
jet fuel, transported; the uncertainty as to the root cause(s) of the failure; the proximity of the
pipeline to residential dwellings and water wells; the existing and potential additional impacts to
property, the environment, and wildlife; and the possibility that the same condition(s) that may
have caused the failure remain present in the pipeline and could lead to additional failures; it
appears that the continued operation of the Twin Oaks Discharge pipeline system without
corrective measures would pose a pipeline integrity risk to public safety, property, or the
environment. The conditions and threats described above potentially exist throughout the Twin



Oaks Pipeline. Further, Sunoco’s apparent inability to effectively detect the leak has potentially
exacerbated the impacts of the release over an extended period of time. Accordingly, corrective
measures are necessary to mitigate the pipeline integrity risk of the pipeline system to protect
public safety, property, and the environment.
Accordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the
proposed issuance of a safety order and to propose that Respondent take measures specified herein
to address the potential risk.
Proposed Corrective Measures
Pursuant to 49 U.S.C. § 60117(m) and 49 CFR § 190.239, PHMSA proposes to issue to Sunoco a
safety order incorporating the following remedial requirements with respect to the affected
pipeline.
For the purposes of this Notice, “Director” means the Director, PHMSA, Office of Pipeline Safety,
Southwest Region. “Affected Pipeline” refers to the entire Twin Oaks Pipeline, which is
approximately 105.5 miles in length from the Twin Oaks Terminal in Aston, Pennsylvania, to the
Newark Terminal in Newark, New Jersey.
1. Operating Pressure Restriction. Sunoco must reduce and maintain a twenty percent
(20%) pressure reduction in the actual operating pressure along the entire length of the
Affected Pipeline, such that the operating pressure does not exceed eighty percent (80%)
of the actual operating pressure in effect immediately prior to the Failure discovered on
January 31, 2025.
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.
Within 15 days of receipt of the Safety Order, Sunoco must provide the Director the
actual operating pressures of each pump station and each main line pressure
regulating station on the Affected Pipeline at the time of the Failure discovered on
January 31, 2025, and the reduced pressure restriction set-points at these same
locations.
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.
When determining the pressure restriction set-points, Sunoco must take into account
any in-line inspection (ILI) features or anomalies present in the Affected Pipeline to
provide for continued safe operation while further corrective actions are completed.
e. Sunoco must review the pressure restriction monthly by analyzing the operating
pressure data, taking into account any ILI features or anomalies present in the Affected
Pipeline. Sunoco must immediately reduce the operating pressure to maintain the safe
operations of the Affected Pipeline, if warranted by the monthly review. Further,
Sunoco must submit the results of the monthly review to the Director including, at a
a. b. c. d.



minimum, the current discharge set-points (including any additional pressure
reductions), and any pressure exceedance at discharge set-points.
2. Type A Sleeve Integrity Plan. Within 90 days of receipt of the Safety Order, Sunoco
must provide to the Director for approval a plan to evaluate the integrity of each Type A
sleeve on the Affected Pipeline. In preparing that plan, Sunoco must consider type,
characteristics (size, depth, orientation), and other integrity considerations of the
anomaly(ies) or defect(s) reinforced by the sleeve; sleeve characteristics (age, grade,
length, thickness, coating, wrap, use of epoxy); cathodic protection; inline inspection
results; nondestructive evaluation or testing records; and any other relevant factors in
evaluating the integrity of a Type A sleeve. The plan must also provide for the removal
of each Type A sleeve on the Affected Pipeline whose integrity cannot be reasonably
assured. The plan must be part of the Remedial Work Plan developed in Item 3 below.
For any sleeve not removed, the plan must provide a technical justification for the Type
A Sleeve remaining on the Affected Pipeline and describe the additional pipeline integrity
management measures to be implemented to ensure the safety and integrity of the Affected
Pipeline in light of any integrity risk related to the sleeve.
3. Remedial Work Plan (RWP).
a. Within 90 days of receipt of the Safety Order, Sunoco must submit a Remedial Work
Plan (RWP) to the Director for prior approval.
b. c. The Director may approve the RWP incrementally without approving the entire RWP.
Upon approval by the Director, the RWP becomes incorporated by reference into the
Safety Order.
d. The RWP must specify the tests, inspections, assessments, evaluations, and remedial
measures Respondent will use to verify the integrity of the Affected Pipeline. It must
address all known or suspected factors and causes of the Failure discovered on January
31, 2025. Sunoco must consider the risks and consequences of another failure to
develop a prioritized schedule for RWP-related work along the Affected Pipeline.
e. The RWP must include a procedure or process to:
i. Identify pipe in the Affected Pipeline with characteristics similar to the
contributing factors identified for the Failure discovered on January 31, 2025.
ii. Gather all data necessary to review the failure history (in service and pressure
test failures) of the Affected Pipeline and to prepare a written report containing
all the available information such as the locations, dates, and causes of leaks
and failures.
iii. 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 Pipeline. Pre-existing operational
data includes, but is not limited to, design, construction, operations, maintenance,
testing, repairs, prior metallurgical analyses, and any third-party consultation
information. Pre-existing assessment data includes, but is not limited to, ILI tool
runs, hydrostatic pressure testing, direct assessments, close interval surveys, and



iv. vi. vii. DCVG/ACVG surveys.
Determine if conditions similar to those contributing to the Failure discovered
on January 31, 2025, are likely to exist elsewhere on the Affected Pipeline.
v. Conduct additional field tests, inspections, assessments, and evaluations to
determine whether, and to what extent, the conditions associated with the Failure
discovered on January 31, 2025, and other failures from the failure history (see
(e)(ii) above) or any other integrity threats are present elsewhere on the Affected
Pipeline. At a minimum, this process must consider all failure causes and specify
the use of one or more of the following:
1) ILI tools that are technically appropriate for assessing the pipeline system
based on the cause of Failure discovered on January 31, 2025, and that can
reliably detect and identify anomalies,
2) Hydrostatic pressure testing,
3) Close-interval surveys,
4) Cathodic protection surveys, to include interference surveys in coordination
with other utilities (e.g., underground utilities, overhead power lines, etc.) in
the area,
5) Coating surveys,
6) Stress corrosion cracking surveys,
7) Selective seam corrosion surveys; and
8) Other tests, inspections, assessments, and evaluations appropriate for the
failure causes.
Note: Sunoco may use the results of previous tests, inspections, assessments,
and evaluations if approved by the Director, provided the results of the tests,
inspections, assessments, and evaluations are analyzed with regard to the
factors known or suspected to have caused the January 31, 2025 Failure.
Describe the inspection and repair criteria Sunoco will use to prioritize, excavate,
evaluate, and repair anomalies, imperfections, and other identified integrity
threats. Include a description of how any defects will be graded and a schedule
for repairs or replacement.
Based on the known history and condition of the Affected Pipeline, describe the
methods Sunoco will use to repair, replace, or take other corrective measures to
remediate the conditions associated with the pipeline failure on January 31, 2025,
and to address other known integrity threats along the Affected Pipeline. The
repair, replacement, or other corrective measures must meet the criteria specified
in (e)(vi) above.
viii. Evaluate the effectiveness and capability of Sunoco’s leak detection system on
the Affected Pipeline, including main lines, stub lines, and delivery lines. At a
minimum, Sunoco’s evaluation must consider the following factors—length and
size of the pipeline, type of product carried, the swiftness of leak detection,
limitations on detectable quantities, location of nearest response personnel, and



4. leak history. This evaluation must also consider maximum operating pressure
(MOP), normal operating pressures, flow rates (or throughput), and impacts from
any pressure cycles or operational changes. For mainline segments that could
affect high consequence areas (HCAs), Sunoco’s evaluation must consider the
pipeline’s proximity to the HCA and risk assessment results.
ix. Based on the findings of the evaluation pursuant to paragraph viii of this
subparagraph, determine corrective measures to improve the effectiveness of
Sunoco’s leak detection system. Sunoco must consider latest advancements in
technology that present the potential to improve the capability of its leak
detection system to detect the type of leak that occurred. The corrective measures
must result in improving the capability of the leak detection system to detect
leaks that could potentially affect public safety, property, or the environment,
similar to (but not limited to) leaks with characteristics common to those
referenced above.
x. Evaluate Sunoco’s written plans and procedures for inspection and maintenance
that address leak detection, right-of-way inspection and repairs and determine the
extent to which the written plans contribute to the elimination of hazardous leaks.
Based on the findings, determine appropriate amendments to improve the extent
to which the plans contribute to the elimination of hazardous leaks.
xi. Evaluate the effectiveness of Sunoco’s ROW inspection program as it pertains to
leak detection. This evaluation must consider any geographic regions or features
(i.e., HCAs and other sensitive areas) that may require specific or additional
means of patrol. Based on the findings, determine corrective measures to
improve the effectiveness of Sunoco’s ROW inspection program relative to leak
detection.
xii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Pipeline
considering the results of the analyses, inspections, evaluations, and corrective
measures undertaken pursuant to the Order.
f. g. Include a proposed schedule for completion of the RWP.
Sunoco 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 the Safety Order, and/or to incorporate modifications
required by the Director.
i. ii. Submit any plan revisions to the Director for prior approval.
The Director may approve plan revisions incrementally.
h. Implement the RWP as it is approved by the Director, including any revisions to
the plan.
Third-Party Facilitator. Paragraphs (e)(viii) through (e)(xi) of the Work Plan must be
facilitated by an independent third-party with relevant expertise approved by the Director.



5. 6. 7. 8. Any documentation from the third-party facilitator must be included in each required
submission to the Director.
Instrumented Leakage Survey. Within 30 days after the Safety Order is issued, Sunoco
must perform a ground instrument leakage survey of the Affected Pipeline. Sunoco must
investigate all leak indications and remedy all leaks discovered. Sunoco must submit
documentation of this survey to the Director within 45 after the Safety Order is issued.
Review of Prior In-line Inspection (ILI) Results.
a. Within 30 days after the Safety Order is issued, Respondent must conduct a review of
any previous ILI results of the Affected Pipeline. In its review, Sunoco must re-evaluate
all ILI results from the past 10 calendar years, including a review of the ILI vendors'
raw data and analysis. Sunoco must determine whether any features were present in
the failed pipe joint and any other pipe removed. Also, Respondent must determine if
any features with similar characteristics are present elsewhere on the Affected Pipeline.
Sunoco must submit documentation of this ILI review to the Director within 45 days
after the Safety Order is issued as follows:
i. List all ILI tool runs, tool types, and the calendar years of the tool runs.
ii. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features present in the failed joint and other pipe removed.
iii. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features with similar characteristics present elsewhere on the Affected Pipeline.
iv. Explain the process used to review the ILI results and the results of the reevaluation.
a. Mechanical and Metallurgical Testing. Within 45 days after the Safety Order is issued,
Sunoco must complete mechanical and metallurgical testing and failure analysis of the
failed pipe, including an analysis of soil samples and any foreign materials. Mechanical
and metallurgical testing must be conducted by an independent third-party acceptable to
the Director and must document the decision-making process and all factors contributing
to the failure. Respondent must complete the testing and analysis as follows:
Document the chain-of-custody when handling and transporting the failed pipe section
and other evidence from the Failure site.
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.
Prior to beginning the mechanical and metallurgical testing, provide the Director with
the scheduled date, time, and location of the testing to allow for an OPS representative
to witness the testing.
d. 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.
Root Cause Failure Analysis. Within 90 days after the Safety Order is issued, complete
a root cause failure analysis (RCFA) and submit a final report of this RCFA to the



Director. The RCFA must be supplemented or facilitated by an independent third-party
acceptable to the Director and must document the decision-making process and all factors
contributing to the Failure. The final report must include findings and any lessons learned
and whether the findings and lessons learned are applicable to other locations within
Sunoco’s pipeline system.
9. Leak Detection Plan. Within 90 days after the Safety Order is issued, Sunoco must
perform a review and submit to the Director a written plan to improve the leak detection
capability on the Affected Pipeline. This review must include a comprehensive analysis
of any SCADA, leak detection, surveillance, and other monitoring systems on the Affected
Pipeline. The written plan must include a schedule for improving the leak detection
capability of the Affected Pipeline through additional instrumentation, updated hardware
or software, installation of a computational pipeline monitoring system and associated
software programming, additional surveillance, pipeline control staffing, ongoing leak
surveys, and any other appropriate measures.
10. Emergency Response Plan and Training Review. Within 90 of receipt of the Safety
Order, Sunoco must review and assess the effectiveness of its emergency response plan
with regards to the Failure. Sunoco must include in the review and assessment the on-
scene response and support, coordination, and communication with emergency responders
and public officials. Sunoco must also include a review and assessment of the
effectiveness of its emergency training program. Sunoco must amend its emergency
response plan and emergency training, if necessary, to reflect the results of this review.
The documentation of this Emergency Response Plan and Training Review must be
available for inspection by OPS or provided to the Director, if requested.
11. Public Awareness Program Review. Sunoco must review and assess the effectiveness
of its Public Awareness program with regards to the Failure. Sunoco must amend its
Public Awareness Program, if necessary, to reflect the results of this review. The
documentation of this Public Awareness Plan Program Review must be available for
inspection by OPS or provided to the Director, if requested.
Other Requirements:
12. Approvals. With respect to each submission under the Safety Order that requires the
approval of the Director, the Director may: (a) approve, in whole or part, the submission;
(b) approve the submission on specified conditions; (c) modify the submission to cure any
deficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent
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 the submission, Respondent must correct all
deficiencies within the time specified by the Director and resubmit it for approval.
13. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of the Safety Order upon a written request timely submitted



demonstrating good cause for an extension.
14. Reporting. Submit quarterly 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 quarterly
report is due on April 1, 2025. The Director may change the interval for the submission
of these reports.
15. Documentation of the Costs. It is requested that Respondent maintain documentation of
the costs associated with implementation of the Safety Order. Include in each monthly
report submitted, 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.
The actions proposed by this Notice of Proposed Safety Order are in addition to and do not waive
any requirements that apply to Respondent’s pipeline system under 49 CFR Parts 190 through 199,
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.
After receiving and analyzing additional data in the course of this proceeding and implementation
of the corrective measures, PHMSA may identify other safety measures that need to be taken. In
that event, Respondent will be notified of any proposed additional measures and, if necessary,
amendments to the Safety Order.
Response to this Notice
In accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written
response to the official who issued the Notice. If you do not respond within 30 days, this
constitutes a waiver of your right to contest this Notice and authorizes the Associate Administrator
for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue
a Safety Order. In your response, you may notify that official that you intend to comply with the
terms of the Notice as proposed, or you may request that an informal consultation be scheduled
(you will also have the opportunity to request an administrative hearing before a safety order is
issued). Informal consultation provides you with the opportunity to explain the circumstances
associated with the risk condition(s) alleged in the notice and, as appropriate, to present a proposal
for a work plan or other remedial measures, without prejudice to your position in any subsequent
hearing.
If you and PHMSA agree within 30 days of informal consultation on a plan and schedule for you
to address each identified risk condition, we may enter into a written consent agreement (PHMSA
would then issue an administrative consent order incorporating the terms of the agreement). If a
consent agreement is not reached, or if you have elected not to request informal consultation, you
may request an administrative hearing in writing within 30 days following receipt of the Notice or
within 10 days following the conclusion of an informal consultation that did not result in a consent
agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to



have a condition that poses a pipeline integrity risk to the public, property, or the environment in
accordance with § 190.239, the Associate Administrator may issue a safety order.
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).
In your correspondence on this matter, please refer to CPF No. 4-2025-054-NOPSO and for each
document you submit, please provide a copy in electronic format whenever possible.
___________________________________ February 13, 2025
Bryan Lethcoe Date issued
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/42025054NOPSO>
- Source ID: `phmsa-enforcement`
- SHA-256: `1beebd0a35a0b89d86ce16af19cca8e09796a62cc056debc2cb473c8aab39e64`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T22:09:54.128Z
- Document slug: `phmsa-enforcement-42025054nopso`

### Source metadata

```json
{
  "cpf": "42025054NOPSO",
  "operator": "SUNOCO PIPELINE L.P.",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID",
  "caseStatus": "OPEN",
  "citedSections": [],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
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  "extractedAgencyDocumentCount": 2,
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  "jurisdiction": "US",
  "operatorName": "SUNOCO PIPELINE L.P."
}
```