{"operation":"document","citation":"CPF 32021074WL","title":"SUNOCO PIPELINE L.P. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-09-01","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(3), 195.583(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021074wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021074wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021074wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021074WL","body":"Warning Letter involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(3),  195.583(a). The case was opened on 2021-09-01 and is reported as closed as of 2021-09-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021074WL_Warning Letter_09012021_(20-172129).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021074WL/32021074WL_Warning%20Letter_09012021_(20-172129).pdf\n\n32021074WL_Warning Letter_09012021_(20-172129)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021074WL/32021074WL_Warning%20Letter_09012021_(20-172129)_text.pdf\n\n32021074WL_Warning Letter_09012021_(20-172129)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: : Matthew.Ramsey@energytransfer.com;\nGregory.Mcilwain@energytransfer.com; Eric.Amundsen@energytransfer.com;\nTodd.Nardozzi@energytransfer.com\nSeptember 1, 2021\nMatt Ramsey\nChief Operating Officer\nEnergy Transfer\n8111 Westchester\nDallas, TX 75225\nCPF 3-2021-074-WL\nDear Mr. Ramsey:\nFrom February 24th, 2020 to February 25th , 2021 a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected your Sunoco Pipeline L.P. (Sunoco’s) Mariner East 1 (ME1) Pipeline from\nPittsburgh to Philadelphia, Pennsylvania.\nAs a result of the inspection, it is alleged that Sunoco has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n\n\n\n2\n(1)…\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section)\nSunoco failed to consider geohazards in its information analysis of pipeline integrity and the\nconsequences of a failure. Specific geohazards like landslides, subsidence from mines and other\nhazards associated with mountainous terrains through which sections of the pipeline traverses\nwere not considered in the integrity analysis.\nSince the inspection, Sunoco has added a geotechnical engineer to the staff, drafted and\nimplemented additional Engineering Standards and adjusted SOPs to more clearly describe how\nto assess and address geohazards during construction as well as for ongoing operations.\nEngineering Standards Implemented in 2020:\nHL2.0202 Design Guidelines for Geotechnical Investigations\nHL2.0203 Geohazard Evaluations for Pipeline Projects\nSOPs with components of ROW Inspection for possible geohazard conditions:\nHLA.20 Field Response to Natural Hazards & Potential Disasters\nHLI.21 Inspection of ROW Crossings under Navigable Waters, Post Extreme Weather and\nNatural Disasters\nHLI.24 Management of Depth of Cover and Evaluation HLI.29 Right of Way Maintenance.\nThe Risk Model used in conjunction with the IMP is being updated to be more quantitative. As\nthe related data is collected from the updated SOPs, it will begin to be integrated in with the risk\nmodel.\n2. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but with intervals not\nexceeding 39 months.\nOffshore At least once each calendar year, but with intervals not\nexceeding 15 months.\nSunoco failed to perform up close inspections for atmospheric corrosion of piping installed on\nelevated support racks inside the Marcus Hook facility and the pipe bridge across 10th\navenue. Inspections are performed visually from the ground surface approximately 20-25 feet\nunder the support racks which preludes top side or close visual inspection of the pipe and hold\ndowns. ILI inspection results may supplement atmospheric corrosion inspections; however, the\n\n\n\n3\natmospheric corrosion check is a stand-alone requirement. In addition, ILI tools are unlikely to\nfind atmospheric corrosion at flanges, fittings, side taps, sensing lines etc.\nCurrently, in the event Sunoco personnel detect that there is visual evidence of coating\ndeterioration, additional measures would be taken to further assess the elevated parts of the line.\nSafe work methods to further evaluate the elevated pipe support locations may include but are\nnot limited to use of aerial man-lift, scaffolding, and possibly remote imaging via drone or pole-\nmounted cameras. Sunoco will evaluate whether better inspection methods can be implemented.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a\nrelated series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring\nprior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per\nday, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nSunoco Pipeline being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2021-074-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nGregory Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Gregory Mcilwain, Senior VP Liquids Operations, Gregory.Mcilwain@energytransfer.com\nEric Amundsen, Senior VP Gas Operations, Eric.Amundsen@energytransfer.com\nTodd Nardozzi, Director Regulatory Compliance, todd.nardozzi@energytransfer.com","truncated":false,"body_characters":7383}