# SUNOCO PIPELINE L.P. — Warning Letter

- **operation:** document
- **citation:** CPF 120125020W
- **title:** SUNOCO PIPELINE L.P. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-11-26
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.573(c).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120125020W
**body:**

Warning Letter involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulation as 195.573(c). The case was opened on 2012-11-26 and is reported as closed as of 2012-11-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120125020W_Warning Letter_11262012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120125020W/120125020W_Warning%20Letter_11262012.pdf

120125020W_Warning Letter_11262012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120125020W/120125020W_Warning%20Letter_11262012_text.pdf

120125020W_Warning Letter_11262012_text.pdf

U.S. Department Of Transportation Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
820 Bear Tavern Road, Suite 103
West Trenton, NJ 08628
WARNING LETTER
OVERNIGHT EXPRESS MAIL
November 26, 2012
Mr. David Chalson, Vice President of Operations
Sunoco Pipeline L.P.
2700 West Passyunk Avenue
Philadelphia, PA 19145
CPF 1-2012-5020W
Dear Mr. Chalson:
During the week of September 17, 2012, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected your pipelines in East Boston, MA.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
1. §195.573 What must I do to monitor external corrosion control?
(c) Rectifiers and other devices. You must electrically check for proper
performance each device in the first column at the frequency stated in the second
column.
Device Check frequency
Rectifier……………….. At least six times each calendar year, but with
Reverse current switch intervals not exceeding 2 ½ months
Diode
Interference bond whose failure would
jeopardize structural protection



1-2012-5020W
Sunoco failed to inspect each cathodic protection rectifier six times each calendar year, but with
intervals not exceeding 2 1/2 months, to ensure that it was operating.
Sunoco missed 2 rectifier readings between 9/15/2011 and 3/13/2012 at Station 9+00 Frankford
Street and Lowell Street Rectifier.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item identified in this letter.
Failure to do so will result in Sunoco Pipeline LP being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, please address your correspondence to:
Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W.
Trenton, NJ 08628 and please refer to CPF 1-2012-5020W. 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).
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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