# SUNOCO PIPELINE L.P. — Notice of Amendment - **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:** Not available - **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. Official case documents: 120185031M_Closure Letter_07022019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Closure%20Letter_07022019.pdf 120185031M_Closure Letter_07022019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Closure%20Letter_07022019_text.pdf 120185031M_Notice of Amendment_11062018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Notice%20of%20Amendment_11062018.pdf 120185031M_Notice of Amendment_11062018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Notice%20of%20Amendment_11062018_text.pdf 120185031M_Operator Response Notice_12072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185031M/120185031M_Operator%20Response%20Notice_12072018.pdf 120185031M_Notice of Amendment_11062018_text.pdf NOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY November 6, 2018 Mr. Greg McIlwain Senior Vice President, Operations Sunoco Pipeline L.P. 1300 Main Street Houston, TX 77002 CPF 1-2018-5031M Dear Mr. McIlwain: From June 30, 2017 to April 5, 2018, a representative 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) Delaware River HDD Bore procedures in Aston, PA. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Sunoco’s plans or procedures, as described below: 1. § 195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. Sunoco’s written specifications and standards for constructing each pipeline system were inadequate. Specifically, Sunoco’s construction standards did not address visually inspecting bored/horizontal directional drilled (HDD) pipe at the site of installation to ensure that the pipe and its coating were not damaged in a manner that could impair its strength or reduce its serviceability, as required by § 195.206. Section 195.206 Material inspection states: “No pipe or other component may be installed in a pipeline system unless it has been visually inspected at the site of installation to ensure that it is not damaged in a manner that could impair its strength or reduce its serviceability.” During the inspection, a PHMSA inspector requested procedures that would address damage to a CPF 1-2018-5031M pipe and/or its coating that might be observed after pull-back during HDD, wherein such damage might impair the pipe’s strength or reduce its serviceability. Sunoco failed to produce these procedures. 2. § 195.214 Welding Procedures. (b) Each welding procedure must be recorded in detail, including the results of the qualifying tests. This record must be retained and followed whenever the procedure is used. Sunoco’s welding procedures for constructing each pipeline system were inadequate. Specifically, Sunoco’s Weld Procedure SP-222Sc-5G Rev.:2 – 10/06/12 (Procedure) did not record adequate details regarding time between weld passes as required by API Standard 1104 – Welding of Pipelines and Related Facilities, 20th Edition (API 1104), incorporated by reference (IBR) in § 195.3(b)(20). The Procedure stated, in part, under Time Between Passes, “Root/Hot Pass – 5 min.; Hot Pass/Remaining Passes – All Passes completed without delay.” API 1104 (IBR), Section 5.3.210 states: “The maximum time between the completion of the root bead and the start of the second bead, as well as the maximum time between the completion of the second bead and the start of other beads, shall be designated.” Also, on January 15, 2016, API issued a technical interpretation clarifying the intent of Section 5.3.2.10 of API 1104 20th Edition, which stated “Yes, the intent of API 1104, Section 5.3.2.10 is to identify the maximum time between the 1st pass and 2nd pass and the maximum time between the 2nd pass and 3rd pass.” Sunoco’s Procedure did not designate the maximum time between the completion of hot pass and the remaining passes. 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 and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice 120185031M_Notice of Amendment_11062018_text Page 2 of 3 CPF 1-2018-5031M 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 60 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 Pipeline L.P. 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, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2018-5031M 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. Please note, the address for the PHMSA Eastern Region, Office of Pipeline Safety, has changed: PHMSA, Eastern Region, Office of Pipeline Safety 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 Please make a note of this new information in your records. If you have any questions, please contact us at 609-771-7800. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120185031M_Notice of Amendment_11062018_text Page 3 of 3 120185031M_Closure Letter_07022019_text.pdf OVERNIGHT EXPRESS DELIVERY July 2, 2019 Mr. Greg McIlwain Senior Vice President, Operations Sunoco Pipeline L.P. 1300 Main Street Houston, TX 77002 CPF 1-2018-5031M Dear Mr. McIlwain: From June 30, 2017 to April 5, 2018, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Sunoco Pipeline L.P.’s (Sunoco) procedures in Aston, PA. As a result of the inspection, Sunoco was issued a Notice of Amendment on November 6, 2018, which proposed amendment of your procedures. Sunoco submitted its amended procedures on December 7, 2018 and May 20, 2019. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. 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 - **truncated:** false - **body characters:** 8755