{"operation":"document","citation":"CPF 120175024M","title":"SUNOCO PIPELINE L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-09-01","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175024m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175024m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120175024m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120175024M","body":"Notice of Amendment involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2017-09-01 and is reported as closed as of 2017-11-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120175024M_Closure letter_11202017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175024M/120175024M_Closure%20letter_11202017.pdf\n\n120175024M_Closure letter_11202017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175024M/120175024M_Closure%20letter_11202017_text.pdf\n\n120175024M_Notice of Amendment_09012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175024M/120175024M_Notice%20of%20Amendment_09012017.pdf\n\n120175024M_Notice of Amendment_09012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175024M/120175024M_Notice%20of%20Amendment_09012017_text.pdf\n\n120175024M_Operator Response To Notice_10052017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120175024M/120175024M_Operator%20Response%20To%20Notice_10052017.pdf\n\n120175024M_Closure letter_11202017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nNovember 20, 2017\nRyan Coffey\nExecutive Vice President of Operations\nSunoco Pipeline L. P.\n800 East Sonterra Boulevard\nSan Antonio, TX 78258\nCPF 1-2017-5024M\nDear Mr. Coffey:\nBetween April 11, 2016 and November 18, 2016, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Sunoco Pipeline’s procedures at Company\nfacilities in Delaware, Michigan, New Jersey, New York, Ohio, and Pennsylvania. As a result of\nthe inspection, Sunoco Pipeline, L. P. was issued a Notice of Amendment on September 1, 2017,\nwhich proposed amendment of your procedures.\nSunoco Pipeline, L. P. submitted its amended procedures on October 5, 2017. My staff reviewed\nthe amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120175024M_Notice of Amendment_09012017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nSeptember 1, 2017\nRyan Coffey\nExecutive Vice President of Operations\nSunoco Pipeline\n800 East Sonterra Boulevard\nSan Antonio, TX 78258\nCPF 1-2017-5024M\nDear Mr. Coffey:\nBetween April 11, 2016 and November 18, 2016; representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Sunoco Pipeline L.P.’s (Sunoco) procedures and records for operations, maintenance,\nand integrity management as part of an integrated inspection of Sunoco assets in Delaware,\nMichigan, New York, New Jersey, Ohio, and Pennsylvania.\nBased on the inspection, PHMSA has identified the apparent inadequacies found within Sunoco’s\nplans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nSunoco’s procedures for operating, maintaining, and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of 49 C.F.R. Part 195 were inadequate.\nSpecifically, Sunoco’s procedure was inadequate for the inspection of main line valves as per\n§ 195.420(b).\n\n\n\nCPF 1-2017-5024M\nDuring the inspection, the PHMSA representative reviewed Sunoco’s DOT 195 Maintenance\nManual, SECTION 195.420. Valve Maintenance (Procedure). The Procedure states in part in the\n“Notes or Remarks” section:\n2. Any Main Line Valve that could not be operated during the inspection and is marked as number\n5, ‘Not Operated Due To Operations Scheduling’, under the operating condition shall be partially\noperated as soon as operating conditions permit and the date of partial operation documented in\nthe remarks area of the Valve Inspection Report where the number 5 was reported.\nThis Procedure fails to provide details such as:\n1. 2. A process for determination of when “operating conditions permit”\nRoles and Responsibility for rescheduling the inspection “as soon as operating conditions\npermit” in accordance with the requirements of § 195.420(b)\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nSunoco’s procedures for operating, maintaining, and repairing the pipeline system in accordance\nwith each of the requirements of this subpart and subpart H of 49 C.F.R. Part 195 were\ninadequate. Specifically, Sunoco’s procedure was inadequate for the inspection of in-service steel\naboveground breakout tanks pursuant to § 195.432(c).\nSection 195.432(c) states:\nEach operator must inspect the physical integrity of in-service steel aboveground breakout tanks\nbuilt to API Std 2510 (incorporated by reference, see §195.3) according to section 6 of API Std 510\n(incorporated by reference, see § 195.3).\nDuring the inspection, the PHMSA representative reviewed Sunoco’s procedure Section 195.432.\nInspection of In-Service Breakout Tanks, Last Revised 3-27-15. The procedure addresses the\ninspection of aboveground steel low pressure or atmospheric pressure storage tanks pursuant to\nAPI Standard 653, but does not provide guidance for the inspection of in-service steel aboveground\nbreakout tanks built to API Standard 2510. The PHMSA inspection included 1 breakout tank, Lima\nTank 7, that was built to ASME Section VIII standard for pressure vessels and thus the tank would\nbe subject to inspection in accordance with § 195.432(c).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\n120175024M_Notice of Amendment_09012017_text Page 2 of 3\n\n\n\nCPF 1-2017-5024M\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Sunoco Pipeline maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern\nRegion, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please reference\nCPF 1- 2017-5024M on each document you submit, and whenever possible provide a signed PDF\ncopy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files\nshould be sent on a CD accompanied by the original paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120175024M_Notice of Amendment_09012017_text Page 3 of 3","truncated":false,"body_characters":9290}