{"operation":"document","citation":"CPF 120135015W","title":"SUNOCO PIPELINE L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-07-29","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120135015w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120135015w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120135015w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120135015W","body":"Warning Letter involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2013-07-29 and is reported as closed as of 2013-07-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120135015W_Warning Letter_ 07292013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120135015W/120135015W_Warning%20Letter_%2007292013_text.pdf\n\n120135015W_Warning Letter_07292013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120135015W/120135015W_Warning%20Letter_07292013.pdf\n\n120135015W_Warning Letter_ 07292013_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nEXPRESS OVERNIGHT MAIL\nJuly 29, 2013\nDavid Chalson, VP Operations\nSunoco Pipeline LP\n4041 Market Street\nAston, PA 19014\nCPF 1-2013-5015W\nDear Mr. David Chalson:\nFrom September 4, 2012 to September 7, 2012, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your operation and maintenance records and procedures in Trenton, NJ.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n1. 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\n1-2013-5015W\nSunoco Pipeline did not follow its manual of written procedures for conducting normal\nmaintenance activities. Specifically, Sunoco Pipeline failed to follow its procedure for section\n195.432 – inspection of in-service breakout tanks that requires the operator to record deficiencies\non Sunoco form 42445.3 (Sunoco Tank Maintenance Report) when they were noted on Sunoco\nform 42446A (Sunoco Logistics Monthly Tank Inspection Report).\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Sunoco Pipeline being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2013-5015W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n1-2013-5015W_Warning Letter_07292013 Page 2 of 2\n\n120135015W_Warning Letter_07292013.pdf\n\nU.S. Department\n820 Bear Tavern Road, Suite 103\nPipeline and\nOf Transportation\nWest Trenton, NJ 08628\nSafety Administration\nHazardous Materials\n609.989.2171\nWARNING LETTER\nEXPRESS OVERNIGHT MAIL\nJuly 29, 2013\nDavid Chalson, VP Operations\nSunoco Pipeline LP\n4041 Market Street\nAston, PA 19014\nCPF 1-2013-5015W\nDear Mr. David Chalson:\nFrom September 4, 2012 to September 7, 2012, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your operation and maintenance records and procedures in Trenton, NJ.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation is:\n195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\n1-2013-5015W\nSunoco Pipeline did not follow its manual of written procedures for conducting normal\nmaintenance activities. Specifically, Sunoco Pipeline failed to follow its procedure for section\n195.432 - inspection of in-service breakout tanks that requires the operator to record deficiencies\non Sunoco form 42445.3 (Sunoco Tank Maintenance Report) when they were noted on Sunoco\nform 42446A (Sunoco Logistics Monthly Tank Inspection Report).\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items) identified in this letter.\nFailure to do so will result in Sunoco Pipeline being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2013-5015W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n1-2013-5015W Warning Letter 07292013\nPage 2 of 2","truncated":false,"body_characters":7685}