{"operation":"document","citation":"CPF 120185031M","title":"SUNOCO PIPELINE L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-06","effective_on":null,"summary":"CLOSED notice of amendment citing 195.202, 195.214(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120185031m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120185031m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120185031m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120185031M","body":"Notice of Amendment involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.214(b). The case was opened on 2018-11-06 and is reported as closed as of 2019-07-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120185031M_Closure Letter_07022019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Closure%20Letter_07022019.pdf\n\n120185031M_Closure Letter_07022019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Closure%20Letter_07022019_text.pdf\n\n120185031M_Notice of Amendment_11062018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Notice%20of%20Amendment_11062018.pdf\n\n120185031M_Notice of Amendment_11062018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Notice%20of%20Amendment_11062018_text.pdf\n\n120185031M_Operator Response Notice_12072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Operator%20Response%20Notice_12072018.pdf\n\n120185031M_Notice of Amendment_11062018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nNovember 6, 2018\nMr. Greg McIlwain\nSenior Vice President, Operations\nSunoco Pipeline L.P.\n1300 Main Street\nHouston, TX 77002\nCPF 1-2018-5031M\nDear Mr. McIlwain:\nFrom June 30, 2017 to April 5, 2018, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nSunoco Pipeline L.P.’s (Sunoco) Delaware River HDD Bore procedures in Aston, PA.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSunoco’s plans or procedures, as described below:\n1. § 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nSunoco’s written specifications and standards for constructing each pipeline system were\ninadequate. Specifically, Sunoco’s construction standards did not address visually inspecting\nbored/horizontal directional drilled (HDD) pipe at the site of installation to ensure that the pipe\nand its coating were not damaged in a manner that could impair its strength or reduce its\nserviceability, as required by § 195.206.\nSection 195.206 Material inspection states: “No pipe or other component may be installed in a\npipeline system unless it has been visually inspected at the site of installation to ensure that it is\nnot damaged in a manner that could impair its strength or reduce its serviceability.”\nDuring the inspection, a PHMSA inspector requested procedures that would address damage to a\n\n\n\nCPF 1-2018-5031M\npipe and/or its coating that might be observed after pull-back during HDD, wherein such damage\nmight impair the pipe’s strength or reduce its serviceability. Sunoco failed to produce these\nprocedures.\n2. § 195.214 Welding Procedures.\n(b) Each welding procedure must be recorded in detail, including the results of the\nqualifying tests. This record must be retained and followed whenever the procedure\nis used.\nSunoco’s welding procedures for constructing each pipeline system were inadequate. Specifically,\nSunoco’s Weld Procedure SP-222Sc-5G Rev.:2 – 10/06/12 (Procedure) did not record adequate\ndetails regarding time between weld passes as required by API Standard 1104 – Welding of\nPipelines and Related Facilities, 20th Edition (API 1104), incorporated by reference (IBR) in\n§ 195.3(b)(20).\nThe Procedure stated, in part, under Time Between Passes, “Root/Hot Pass – 5 min.; Hot\nPass/Remaining Passes – All Passes completed without delay.”\nAPI 1104 (IBR), Section 5.3.210 states:\n“The maximum time between the completion of the root bead and the start of the second bead, as\nwell as the maximum time between the completion of the second bead and the start of other beads,\nshall be designated.”\nAlso, on January 15, 2016, API issued a technical interpretation clarifying the intent of Section\n5.3.2.10 of API 1104 20th Edition, which stated “Yes, the intent of API 1104, Section 5.3.2.10 is\nto identify the maximum time between the 1st pass and 2nd pass and the maximum time between\nthe 2nd pass and 3rd pass.”\nSunoco’s Procedure did not designate the maximum time between the completion of hot pass and\nthe remaining passes.\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\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\n120185031M_Notice of Amendment_11062018_text Page 2 of 3\n\n\n\nCPF 1-2018-5031M\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 60 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 L.P. 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, Director, PHMSA Eastern Region,\n840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2018-5031M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na 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.\nPlease note, the address for the PHMSA Eastern Region, Office of Pipeline Safety, has changed:\nPHMSA, Eastern Region, Office of Pipeline Safety\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\nPlease make a note of this new information in your records. If you have any questions, please\ncontact us at 609-771-7800.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120185031M_Notice of Amendment_11062018_text Page 3 of 3\n\n120185031M_Closure Letter_07022019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 2, 2019\nMr. Greg McIlwain\nSenior Vice President, Operations\nSunoco Pipeline L.P.\n1300 Main Street\nHouston, TX 77002\nCPF 1-2018-5031M\nDear Mr. McIlwain:\nFrom June 30, 2017 to April 5, 2018, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an\non-site pipeline safety inspection of Sunoco Pipeline L.P.’s (Sunoco) procedures in Aston, PA. As\na result of the inspection, Sunoco was issued a Notice of Amendment on November 6, 2018, which\nproposed amendment of your procedures.\nSunoco submitted its amended procedures on December 7, 2018 and May 20, 2019. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have 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\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8755}