{"operation":"document","citation":"CPF 32021093WL","title":"WEST TEXAS GULF PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-11-30","effective_on":null,"summary":"CLOSED warning letter citing 195.422(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021093wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021093wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021093wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021093WL","body":"Warning Letter involving WEST TEXAS GULF PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.422(a). The case was opened on 2021-11-30 and is reported as closed as of 2021-11-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021093WL_Warning Letter_11302021_(20-172180).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021093WL/32021093WL_Warning%20Letter_11302021_(20-172180).pdf\n\n32021093WL_Warning Letter_11302021_(20-172180)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021093WL/32021093WL_Warning%20Letter_11302021_(20-172180)_text.pdf\n\n32021093WL_Warning Letter_11302021_(20-172180)_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\nNovember 30, 2021\nMatt Ramsey\nChief Operating Officer\nEnergy Transfer\n8111 Westchester\nDallas, TX 75225\nCPF 3-2021-093-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) Millenium Pipeline, Corsicana Area\nPipelines , West Texas Gulf System #2 and West Texas Gulf System #1 Pipelines from Midland\nto Nederland, Texas.\nAs a result of the inspection, it is alleged that you have committed probable violation(s) of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n1. § 195.422 Pipeline repairs\n(a) Each operator shall, in repairing its pipeline systems, insure that the repairs are\nmade in a safe manner and are made so as to prevent damage to persons or\nproperty.\nSunoco failed to comply with its approved methods of permanent repair for dent anomalies with\nstress concentrators or metal loss. The table of approved repair methods for various anomaly\ntypes listed in Appendix B of Energy Transfer’s standard operating procedure (SOP) HLI.05\nPipeline Repair does not include grinding as an approved repair method for dents with stress\nconcentrators or metal loss.\n\n\n\nA 0.43% dent with metal loss < 2% was reported on G-Form repair report ID 106938, RANG-\nBLUM Dig 19-1 Non-HCA immediate anomaly. The anomaly was on the West Texas Gulf\nPipeline System (WTG) 26” Colorado City to Wortham line segment. The metal loss was\nsanded out and the dent recoated. The list of approved repairs does not include grinding as an\napproved repair method for dents with stress concentrators or metal loss. Per Energy Transfer’s\nSOP HLI.05 Appendix B, the approved method of repair should have been a repair sleeve,\nhence, the repair performed did not comply with Energy Transfer's approved Permanent Repair\nmethods.\nSunoco has since updated its SOP HLI.05 to allow for grinding to be an approved repair method\nfor dents with stress concentrators or external corrosion (for dents = 6% of the pipe diameter\ncontaining external corrosion with depth < 12.5% of wall thickness (wt) or if stress concentrator\nafter removal remaining wt is not less than 87.5% of nominal wt as allowed by API B31.4 table\n451.6.2(b)-2.\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 item(s) 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 3-2021-071-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, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n2\n\n\n\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\n3","truncated":false,"body_characters":5463}