# MID - VALLEY PIPELINE CO — Corrective Action Order

- **operation:** document
- **citation:** CPF 320145002H
- **title:** MID - VALLEY PIPELINE CO — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-03-25
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320145002H
**body:**

Corrective Action Order involving MID - VALLEY PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2014-03-25 and is reported as closed as of 2016-11-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320145002H_Closure Letter_11042016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145002H/320145002H_Closure%20Letter_11042016.pdf

320145002H_Closure Letter_11042016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145002H/320145002H_Closure%20Letter_11042016_text.pdf

320145002H_Corrective Action Order_03252014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145002H/320145002H_Corrective%20Action%20Order_03252014.pdf

320145002H_Corrective Action Order_03252014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145002H/320145002H_Corrective%20Action%20Order_03252014_text.pdf

320145002H_Closure Letter_11042016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 4, 2016
Mr. David R. Chalson
Sr. Vice President, Operations
Sunoco Pipeline L.P.
4041 Market Street
Aston, PA 19014
CPF 3-2014-5002H
Dear Mr. Chalson:
On March 25, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Mid-Valley Pipeline Co. a Corrective Action Order (CAO) in the above-referenced
case. This Order included required actions to be taken on and along your pipeline. Based on our
review of the documentation you provided, it has been determined that you have complied with
the terms of this Order.
Accordingly, this case is now closed. Thank you for your cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
cc: Gary MacDonald
President, Mid-Valley Pipeline Co.
1 Fluor Daniel Dr. Bldg A, Level 3
Sugar Land, TX 77478

320145002H_Corrective Action Order_03252014_text.pdf

March 25, 2014
VIA CERTIFIED MAIL [Mr. Charles Maser] AND FACSIMILE
Charles E. Maser
President of Mid-Valley Pipeline Co.
1818 Market Street, Suite 1500
Philadelphia, PA 19103
Re: CPF No. 3-2014-5002H
Dear Mr. Maser:
Enclosed please find the Corrective Action Order issued by the Associate Administrator for
Pipeline Safety in the above-referenced case. It requires Mid-Valley Pipeline Co. to take
immediate corrective actions with respect to its hazardous liquid pipeline failure discovered on
March 18, 2014, in Colerain, Hamilton County, Ohio. Service is being made by certified mail
and facsimile. Your receipt of this Corrective Action Order constitutes service of that document
under 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon receipt.
We look forward to a successful resolution of the concerns arising out of this recent pipeline
failure and to ensure the safety of the line. Please direct any questions on this matter to Linda
Daugherty, Director, Central Region, OPS, at (816) 329-3821.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosures: Corrective Action Order and Copy of 49 C.F.R. § 190.233
cc: Mr. Michael Hennigan, President and Chief Executive Officer
Ms. Linda Daugherty, Director, Central Region, OPS



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
___________________________________
-------------------------------------------------------
)
In the Matter of ) )
Mid-Valley Pipeline Company, ) CPF No. 3-2014-5002H
)
Respondent. ) )
-------------------------------------------------------
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (Order) is being issued, under authority of 49 U.S.C. § 60112, to
require Mid-Valley Pipeline Company (Mid-Valley or Respondent), to take necessary corrective
action to protect the public, property, and the environment from potential hazards associated
with a failure involving Respondent's 20-inch-diameter hazardous liquid pipeline running from
Hebron, Kentucky, to Lima, Ohio (Affected Pipeline).
On March 18, 2014, a failure was identified on the Affected Pipeline in Hamilton County, Ohio,
resulting in the release of at least 364 barrels of crude oil. The commodity exited the pipeline
through a bottom-side dent that contained a 5-inch axial through-wall crack containing some
metal loss. The cause of the failure has not yet been determined. Pursuant to 49 U.S.C. § 60117,
the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline
Safety (OPS), initiated an investigation of the accident. The preliminary findings of the agency's
ongoing investigation are as follows:
Preliminary Findings
• Mid-Valley is a subsidiary of Sunoco Logistics Partners, LP, which operates both crude
and refined product pipelines. The Sunoco Logistics Crude Oil Pipeline System
consists of approximately 4,900 miles of crude oil trunk pipelines and 500 miles of
crude oil gathering pipelines in the southwest and midwest regions of the United
States. The pipelines in the southwest United States consist of approximately 2,950
miles of crude oil trunk pipelines and approximately 300 miles of crude oil gathering
pipelines in Texas. The Texas system is connected to the Mid-Valley pipeline system.
1
• The Mid-Valley Pipeline system (approximately 1000 miles) starts in Longview, Texas
and continues on to Samaria, Michigan. The Affected Pipeline is part of the Mid-
Valley Pipeline system.
1 See Sunoco Logistics Partners, LP., website, available at http://www.sunocologistics.com/Customers/Business-
Lines/Crude-Oil-Pipeline-System/55/ (last accessed March 24, 2014).



2
• The Affected Pipeline is approximately 121 miles in length. Portions of the pipeline,
including the failure site, are located in high consequence areas (HCAs) or could affect
areas. The line crosses various roadways, the Ohio River, Great Miami River, several
populated areas, and numerous streams. The Affected Pipeline includes one section of
20-inch loop line that remains activated from Headapohl to Lima (begins at Headapohl
MP 898 and ends at Lima MP 912).
• The Affected Pipeline moves crude oil from Hebron, Kentucky, to Lima, Ohio.
• The manufacturer of the failed pipe is National Tube. The steel pipe at the failure
location was constructed in 1950, is 20” in diameter, 0.358” wall thickness, grade
X52, and seamless with a coal-tar coating. It has an impressed current cathodic
protection system.
• The pressure at the Hebron, Kentucky, pump station prior to the failure was 927 psig.
The maximum operating pressure (MOP) of this line segment is 936 psig.
• A portion of the pipeline running between Hedapohl and Lima was hydrotested in
August 2005. However, other portions of the pipeline between Hebron and Lima
were built prior to hydrotesting requirements and as a result are operated under the
risk based alternative selection criteria as set forth in § 195.303.
• At approximately 01:02 am EDT on March 18, 2014, Respondent discovered that
a failure had occurred on the Affected Pipeline, resulting in the release of an
estimated 240 barrels of crude oil. The release volume has since been estimated to be
greater than 364 barrels. The failure occurred at Mile Post 807 in the township of
Colerain, Hamilton County, Ohio. The incident was reported by Sunoco to the
National Response Center at 03:41 EDT am on March 18, 2012 (NRC Report No.
1076964).
• The accident occurred in a heavily wooded area adjacent to the Oak Glen Nature
Preserve and other highly populated HCAs located less than a mile from the Great
Miami River. The crude oil migrated off the pipeline right-of-way, contaminating the
Oak Glen Nature Preserve. The last reported count of wildlife treated for
contamination was 36. An unnamed creek bed continues to be washed down.
• Various state and federal agencies, including the United States Coast Guard, the
Colerain Fire Department, EPA Region V, Ohio EPA and Ohio DNR, U.S. Fish and
Wildlife, Department of Interior, Great Parks of Hamilton County, Hamilton County
Public Health, numerous contractors working on behalf of the operator, and various
operating personnel are continuing to perform clean-up, remediation, and
monitoring activities.
• Spilled crude oil from Respondent's pipeline migrated into a ravine near the failure site
and into a pond in the Oak Glen Nature Preserve. Removal of crude oil from the pond



3
is underway. The Great Miami River, located less than a mile away from the failure
site, has not shown signs of being affected at the time of this order.
• The pipeline had been shut down prior to the failure due to normal operations. The
pipeline was static at the time the failure was discovered. Public odor complaints led
to the discovery of the crude oil spill. After becoming aware of the failure,
Respondent's personnel isolated the pipeline using mainline block valves located at
MP 802 and MP 808.
• The Affected Pipeline was more recently inspected using an in-line inspection (ILI)
technology for deformation and metal loss anomalies in February of 2013. Three
bottom-side deformation anomalies were reported in the area of the failure as being less
than 2%. The ILI summary data presented to PHMSA on March 20, 2014 (several days
after the initial failure) included findings that similar dents or larger had been identified
in an additional 28 locations that had not yet been excavated as of the date of the
failure.
• At least two major spills have occurred on the Mid-Valley Pipeline system in recent
years. A large spill occurred in Florence, Kentucky, in October 2008 (20080331),
when 3,650 barrels were released, with an incursion into the sanitary sewer system
and nearby Gunpowder Creek. The same line had previously ruptured in January
2005 (20050073), causing a release of 6,909 barrels, mostly into the Kentucky River.
• Four days after the March 18 2014, failure, Mid-Valley provided a repair and restart
plan to PHMSA for review. Originally, the repair plan involved using a “PLIDCO”
repair fitting and three clocksprings. The repair plan that had been originally reviewed
by PHMSA and discussed with DNV, a third party consultant, was subsequently
modified such that a threaded o-ring (“TOR”) was included on the PLIDCO. This
revision occurred without initial review by DNV or PHMSA.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective
action, which may include the suspended or restricted use of a pipeline facility, physical
inspection, testing, repair, replacement, or other action, as appropriate. The basis for
making the determination that a pipeline facility is hazardous and requiring corrective action is
set forth both in the above-referenced statute and 49 C.P.R.§ 190.233, a copy of which is
enclosed.
Section 60112, and the regulations promulgated thereunder, provide for the issuance of a
Corrective Action Order without prior opportunity for notice and hearing upon a finding
that failure to issue the Order expeditiously will likely result in serious harm to life, property or
the environment. In such cases, an opportunity for a hearing will be provided as soon as
practicable after the issuance of the Order.



4
After evaluating the foregoing preliminary findings of fact, I find that the continued operation of
the Affected Pipeline without corrective measures would be hazardous to life, property and the
environment. Additionally, after considering the age of the pipe, the lack of original
hydrotesting on all portions of the Affected Pipeline, the circumstances surrounding this failure
(i.e., a crack in a dent), the temporary repair plan being modified without review by all necessary
parties, the presence of additional dents with similar characteristic on the Affected Pipeline as
that near the failure location, the proximity of the pipeline to populated areas, public
roadways, river crossings and other High Consequence Areas, the hazardous nature of the
product being transported, the pressure required for transporting the material, the uncertainties
as to the cause of the failure, and the ongoing investigation to determine the cause of the
failure, I find that a failure to issue this Order to require corrective action would result in
likely serious harm to life, property, and the environment and that additional dent indications
should be addressed as quickly as possible.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The terms and conditions of this Order are
effective upon receipt.
Within 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as
practicable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy
to the Director, Central Region, PHMSA (Director). If a hearing is requested, it will be held
telephonically or in-person in Kansas City, Missouri.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and amendment of this Order will be considered. To the extent
consistent with safety, Respondent will be afforded notice and an opportunity for a hearing prior
to the imposition of any additional corrective measures.
Required Corrective Actions
Pursuant to 49 U.S.C. § 60112, I hereby order Mid-Valley Pipeline Company to immediately
take the following corrective actions with respect to the Affected Pipeline:
1. Maintain a twenty percent (20%) pressure reduction in the operating pressure of the
Affected Pipeline. At the time of the failure, the pipeline was flowing from Hebron,
Kentucky, to Lima, Ohio. The pipeline must not reverse operations on a planned basis.
The operating pressure may not exceed eighty percent (80%) of the operating pressure in
effect immediately prior to the failure (927 psig reduced to 743 psig). This pressure
restriction will remain in effect until written approval to increase the pressure or return
the pipeline to its pre-failure operating pressure is obtained from the Central Region
Director.
2. Within 90 days of receipt of this Order, cut out the failed pipeline section and complete
mechanical and metallurgical testing, and perform failure analysis of the failed pipe,
including analysis of soil samples and any foreign materials. Complete the testing and



5
analysis as follows:
A. Document the chain-of-custody when handling and transporting the failed pipe
section and other evidence from the failure site;
B. Within 10 days of receipt of this Order, develop and submit the testing protocol,
including selection of the testing laboratory, to the Central Region Director for
prior approval.
C. Prior to commencing the mechanical and metallurgical testing, provide the
Central Region Director with the scheduled date, time, and location of the testing to
allow a PHMSA representative to witness the testing; and
D. Ensure that the testing laboratory distributes all resulting reports in their entirety
(including all media), whether draft or final, to the Central Region Director at the
same time as they are made available to Respondent.
3. Within 60 days following receipt of this Order, complete a root cause failure analysis for
the March 18, 2014 accident that is supplemented and facilitated by an independent third
party approved by the Director. Within 10 days of receipt of this Order, submit the
name of the independent third-party contractor for approval by the Central Region
Director. Elements of the root cause analysis must include, but not be limited to: a
scoping document of the root cause analysis; procedures associated with root cause
analysis; multiple methods used for the analysis and periodic (not to exceed monthly)
updates on each method as it progresses. This root cause failure analysis shall include a
detailed review of the failure mechanism, the control room activities prior to, during and
after the failure discovery, including manual calculations associated with over and short
material balance efforts, emergency response procedures and execution of these
procedures by all personnel, and associated personnel performing field operations and
maintenance response to the failure. Provide the Central Region Director with the
scheduled date, time, and location of personnel interviews and document these
interviews. The root cause analysis must document all contributory factors and the
decision-making process. Submit a final report of the root cause analysis results to the
Central Region Director, including any recommendations or lessons learned and whether
the findings are applicable to other locations within Respondent's Mid-Valley Pipeline
System.
4. Within 90 days following receipt of this order, submit a remedial work plan (RWP)
that includes integrity verification measures to the Central Region Director for
approval. The plan must provide for the verification of the integrity of the Affected
Pipeline and must address all factors known or suspected in the March 18, 2014 failure.
The plan must include:
A. Integration of the results of the metallurgical analysis performed pursuant to Item 2
and the root cause failure analysis required by Item 3, with all relevant data,



6
including all historical repair information, construction, operating, maintenance,
testing, metallurgical analysis or other third-party consultation information, and
assessment data for the line segment. Data-gathering activities must include a
review of the failure history (including both in-service and pressure-test failures) of
the pipeline and development of a written report containing all available information
regarding locations, dates, and causes of leaks and failures;
B. Measures to identify and analyze the extent to which the root cause and other
contributory factors apply to all pipe in the Affected Pipeline;
C. The performance of additional field testing, inspections, and evaluations to
determine whether, and to what extent, the conditions associated with the failure, or
any other integrity-threatening conditions are present elsewhere on the Affected
Pipeline. At a minimum within 6 months of the receipt of this order, run an In-Line
Inspection (ILI) on the Affected Pipeline capable of detecting cracks and consider
confirmatory hydrostatic testing. Include a detailed description of the criteria to be
used for the evaluation and a prioritization of any integrity threats and anomalies
that are identified and provide vendor summary reports to the Central Region
Director;
D. Include a detailed description of the inspection and repair criteria to be used in the
evaluation and prioritization of identified integrity threats. This is to include a
description of how any defects are to be graded and a schedule for repairs or
replacement;
E. Include provisions for continuing long-term periodic testing and integrity
verification measures, considering the results of the analyses, inspections, and
corrective measures undertaken pursuant to this Order, to ensure the ongoing safe
operation of the Affected Pipeline;
F. Identify all locations along the Affected Pipeline, by milepost, where PLIDCO
fittings or clocksprings have been utilized for repairs. Within 6 months of receipt
of this order, provide to the Central Region Director a table listing these
locations, date of the installation, identification of the reason for the repair, and
the specifics of any crack-like information (length and depth, if known). Include
information about the length of the clockspring or PLIDCO utilized and identify
whether the PLIDCO fitting has TORs installed directly on the fitting (size of the
TOR to be included) and is welded
G. Investigate and, where necessary upon field investigation, remediate all reported
dents on the Affected Pipeline, as identified in the 2013 ILI run, and repair or
replace any valves identified to be leaking or malfunctioning during the
emergency response efforts following the March 18, 2014 failure, the subsequent
repairs, or restart activities.



7
5. 6. 7. 8. H. Review existing procedures and include provisions to ensure that reviewed or
approved repair or restart plans are not modified unless the approving official or
agency has first reviewed the needed revision or activity and agreed with the
proposed action prior to implementation.
I. Include a proposed schedule for completion of the actions required by paragraphs A-
H of this Item.
Within 90 days of receipt of this order, provide a report to the Central Region Director
that summarizes possible enhancements that could be implemented to improve leak
detection capabilities, minimize operating over the maximum operating pressure “MOP”
for any length of time, and improve emergency response along the Affected Pipeline.
This should include, at minimum, a review of the deployment of an API 1130 compliant
leak detection system on an accelerated basis, additional pressure and flow
instrumentation, automated valve locations, automated calculations and associated
alarms.
Document and perform a detailed review of all local control room screens that have been
or will be used in an emergency or in failure response-related maneuvers to determine
consistency in equipment and location identifications between the Central Control room
and the local control room.
Upon approval by the Central Region Director, the remedial work plan becomes
incorporated into this order and shall be revised as necessary to incorporate the results of
actions undertaken pursuant to this order and, whenever necessary, to incorporate new
information obtained during the failure investigation and remedial activities. Submit any
such plan revisions to the Director for prior approval. The Central Region Director may
approve plan elements incrementally.
Implement the work plan as approved by the Central Region Director, including any
revisions to the plan.
Other Requirements:
1. 2. Reporting. Submit quarter reports to the Central Region Director that: (1) include all
available data and results of the testing and evaluations required by this Order; (2)
identify all excursions of MOP by location, date and time, and associated reason for
excursion and (3) describe the progress of the repairs or other remedial actions being
undertaken. The first quarterly report for the period from April 1, 2014, through June
30, 2014, shall be due by July 15, 2014. The Director may change the interval for the
submission of these reports.
Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this order. Include in each
monthly report the to-date total costs associated with: (1) preparation and revision of
procedures, studies and analyses; (2) physical changes to pipeline infrastructure,



8
including repairs, replacements and other modifications; and (3) environmental
remediation, if applicable.
3. Approvals. With respect to each submission requiring the approval of the Director, the
Director may: (a) approve the submission in whole or in part; (b) approve the submission
on specified conditions; (c) modify the submission to cure any deficiencies; (d)
disapprove the submission in whole or in part and direct Respondent to modify the
submission; or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission, as approved or modified by the Director. If the Director
disapproves all or any portion of a submission, Respondent must correct all deficiencies
within the time specified by the Director and resubmit it for approval.
4. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Order upon a written request timely submitted and demonstrating
good cause for an extension.
The actions required by this Corrective Action Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Part [195, 193, 192],
under any other order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or
under any other provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
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).
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
In your correspondence on this matter, please refer to CPF No. 3-2014-5002H and for each
document you submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Corrective Action Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
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