SUNOCO PIPELINE L.P. — Notice of Amendment

party submissionOfficial PDF120185027M_Operator Response to Notice_09212018.pdf#

120185027M_Notice of Amendment_08222018_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY August 22, 2018 Mr. Greg McIlwain Senior Vice President of Operations Sunoco Pipeline L.P. 1300 Main Street Houston, TX 77002 CPF 1-2018-5027M Dear Mr. McIlwain: From April 3, 2017 to August 11, 2017, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Sunoco Pipeline, L.P.’s (Sunoco) Mariner East 1 pipeline procedures for operations, maintenance, and emergencies in Washington County, Pennsylvania. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Sunoco’s plans or procedures, as described below: 1. § 195.402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. Sunoco’s procedures for operating, maintaining and repairing its pipeline system in accordance with each requirement of subpart F of Part 195 were inadequate. Specifically, Sunoco’s O&M procedure SEC. 195.420. Valve Maintenance (Procedure) lacked detailed instructions necessary for maintaining each valve that is necessary for the safe operation of its pipeline system, as required by § 195.420(a).#

120185027M_Notice of Amendment_08222018_text.pdf, page 2CPF 1-2018-5027M Section 195.420(a) states: “Each operator shall maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times.” During the inspection, the PHMSA inspector reviewed Sunoco’s mainline valve (MLV) inspection records for the PHMSA Delmont to Plainfield unit. Several of the MLV inspection records listed as “check valve # V-183.5C”; however, the check valve inspection information was missing for several MLV inspection cycles required under § 195.420(b). Sunoco explained that due to the unique design of the check valve it is difficult to inspect to determine if it is functioning properly, as required by § 195.420(b). In a post-inspection letter dated August 18, 2017, Sunoco stated: “SPLP… plans to remove the check valves from the CMMS “DOT-Required” valve inspection category and forms. SPLP will continue to conduct the regularly planned site inspections and list these valves in the preventative maintenance category to document maintenance as a “facility valve”, following SPLP O&M Manual Section 195.420.” Regarding “facility valves”, Sunoco’s Procedure stated in part (emphasis added): SPLP Requirements/Process Description… 2. Facility Valves (and other non-Main Live Valves) I… II. Facility valves shall be maintained as determined by SPLP to insure the safe operation of the pipeline system. The statement “Facility valves shall be maintained as determined by SPLP…” is inadequate because it lacks detailed instructions necessary for maintaining each valve that is necessary for the safe operation of its pipeline system, as required by § 195.420(a). Therefore, Sunoco’s procedures did not adequately address the requirements of § 195.420(a). Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice 120185027M_Notice of Amendment_08222018_text Page 2 of 3#

120185027M_Notice of Amendment_08222018_text.pdf, page 3CPF 1-2018-5027M and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Sunoco maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2018-5027M on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120185027M_Notice of Amendment_08222018_text Page 3 of 3#

120185027M_Closure letter_10052018_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY October 5, 2018 Mr. Greg McIlwain Senior Vice President of Operations Sunoco Pipeline L.P. 1300 Main Street Houston, TX 77002 CPF 1-2018-5027M Dear Mr. McIlwain: From April 3 to August 11, 2017, a representative from the Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Saftey pursuant to Chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Sunoco Pipeline, L.P. (Sunoco) Mariner East 1 pipeline for operations, maintenance and emergencies in Washington County, PA. As a result of the inspection, Sunoco was issued a Notice of Amendment (NOA) on August 22, 2018, which proposed amendment of its procedures. On September 21, 2018, Sunoco submitted Energy Transfer’s Standard Operating Procedure HLM.01, which replaced Sunoco’s previous procedure. My staff reviewed these procedures, and it appears that the inadequacies outlined in this NOA have been corrected as a result. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#