# SUNOCO PIPELINE L.P. — Warning Letter - **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:** Not available - **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. Official case documents: 120135015W_Warning Letter_ 07292013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120135015W/120135015W_Warning%20Letter_%2007292013_text.pdf 120135015W_Warning Letter_07292013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120135015W/120135015W_Warning%20Letter_07292013.pdf 120135015W_Warning Letter_ 07292013_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 EXPRESS OVERNIGHT MAIL July 29, 2013 David Chalson, VP Operations Sunoco Pipeline LP 4041 Market Street Aston, PA 19014 CPF 1-2013-5015W Dear Mr. David Chalson: From September 4, 2012 to September 7, 2012, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your operation and maintenance records and procedures in Trenton, NJ. 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. 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. 1-2013-5015W Sunoco Pipeline did not follow its manual of written procedures for conducting normal maintenance activities. Specifically, Sunoco Pipeline failed to follow its procedure for section 195.432 – inspection of in-service breakout tanks that requires the operator to record deficiencies on Sunoco form 42445.3 (Sunoco Tank Maintenance Report) when they were noted on Sunoco form 42446A (Sunoco Logistics Monthly Tank Inspection Report). 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(s) identified in this letter. Failure to do so will result in Sunoco Pipeline being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-2013-5015W. 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 1-2013-5015W_Warning Letter_07292013 Page 2 of 2 120135015W_Warning Letter_07292013.pdf U.S. Department 820 Bear Tavern Road, Suite 103 Pipeline and Of Transportation West Trenton, NJ 08628 Safety Administration Hazardous Materials 609.989.2171 WARNING LETTER EXPRESS OVERNIGHT MAIL July 29, 2013 David Chalson, VP Operations Sunoco Pipeline LP 4041 Market Street Aston, PA 19014 CPF 1-2013-5015W Dear Mr. David Chalson: From September 4, 2012 to September 7, 2012, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your operation and maintenance records and procedures in Trenton, NJ. 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: 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. 1-2013-5015W Sunoco Pipeline did not follow its manual of written procedures for conducting normal maintenance activities. Specifically, Sunoco Pipeline failed to follow its procedure for section 195.432 - inspection of in-service breakout tanks that requires the operator to record deficiencies on Sunoco form 42445.3 (Sunoco Tank Maintenance Report) when they were noted on Sunoco form 42446A (Sunoco Logistics Monthly Tank Inspection Report). 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 items) identified in this letter. Failure to do so will result in Sunoco Pipeline being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-2013-5015W. 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 1-2013-5015W Warning Letter 07292013 Page 2 of 2 - **truncated:** false - **body characters:** 7685