SUBURBAN PROPANE, L.P. — Notice of Amendment

party submissionOfficial PDF32024006NOA_Operator Response to Notice_02122024_(23-264475).pdf#

32024006NOA_Closure Letter_05142024_(23-264475)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: konderdonk@suburbanpropane.com; emoreno@suburbanpropane.com; minglett@suburbanpropane.com May 14, 2024 Keith Onderdonk Vice President of Operational Support Suburban Propane, L.P. 240 Route 10 West Whippany, NJ 07961 RE: CPF 3-2024-006-NOA Dear Mr. Onderdonk: From April 24 - 27, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an on-site pipeline safety inspection of Suburban Propane, L.P’s (Suburban) procedures for operations and integrity management in West Salem, Wisconsin. As a result of the inspection, Suburban was issued a Notice of Amendment on January 11, 2024, which proposed amendment of its procedures. Suburban submitted its amended procedures on February 12, 2024. My staff has reviewed the amended procedures and it appears that the inadequacies outlined in the Notice of Amendment have been corrected. This letter is to inform you that no further action is necessary, and this case is now closed. Thank you for your cooperation. Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration cc: Ed Moreno, Senior Executive Division President, Suburban Propane, L.P. (emoreno@suburbanpropane.com) Matt Inglett, DOT Compliance Asst., Suburban Propane, L.P. (minglett@suburbanpropane.com)#

32024006NOA_Notice of Amendment_01112024_(23-264475)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: konderdonk@suburbanpropane.com; emoreno@suburbanpropane.com; minglett@suburbanpropane.com January 11, 2024 Keith Onderdonk Vice President of Operational Support Suburban Propane, L.P. 240 Route 10 West Whippany, NJ 07961 CPF 3-2024-006-NOA Dear Mr. Onderdonk: From April 24-27, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an onsite inspection of Suburban Propane, L.P’s (Suburban) Procedures for operations and integrity management in West Salem, Wisconsin. As a result of the inspection, PHMSA has identified the apparent inadequacies found within Suburban’s plans or procedures. The items inspected and the inadequacies are described below: 1. § 192.605 Procedural manual for operations, maintenance, and emergencies (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted.#

32024006NOA_Notice of Amendment_01112024_(23-264475)_text.pdf, page 2(b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and Subpart M of this part. The Suburban Propane, L.P Operations and Maintenance Manual, last revised December 14, 2022, is inadequate because it does not require that leakage surveys be conducted with calibrated leak detector equipment outside business districts as frequently as necessary, but at least once every 5 calendar years at intervals not exceeding 63 months as required by § 192.723(b)(2). 2. § 192.613 Continuing surveillance. (a) Each operator shall have a procedure for continuing surveillance of its facilities to determine and take appropriate action concerning changes in class location, failures, leakage history, corrosion, substantial changes in cathodic protection requirements, and other unusual operating and maintenance conditions. (b) If a segment of pipeline is determined to be in unsatisfactory condition but no immediate hazard exists, the operator shall initiate a program to recondition or phase out the segment involved, or, if the segment cannot be reconditioned or phased out, reduce the maximum allowable operating pressure in accordance with § 192.619 (a) and (b). The Suburban Propane, L.P Operations and Maintenance Manual last revised December 14, 2022, is inadequate because it does not to require documentation of a program to recondition, phase out, or reducing the MAOP in a pipeline segment that is determined to be in unsatisfactory condition but for which no immediate hazard exists. 3. § 192.1007 What are the required elements of an integrity management plan? A written integrity management plan must contain procedures for developing and implementing the following elements:. . . . Suburban Propane did not develop a written integrity management plan as specified in § 192.1007. Suburban’s integrity management program incorrectly utilized § 192.1015 for a small liquefied propane gas (LPG) operator. The Suburban Terlingua system has 121 customers from a single source which exceeds the 100-customer-count specified by § 192.1001. Therefore, Suburban cannot be considered a small LPG operator.#

32024006NOA_Notice of Amendment_01112024_(23-264475)_text.pdf, page 3Response 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 Enforcement 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 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 30 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 Suburban Propane, 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 Gregory A. Ochs, Director, Central, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 3-2024-006-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Gregory A. Ochs Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Ed Moreno, Senior Executive Division President, Suburban Propane, L.P. (emoreno@suburbanpropane.com) Matt Inglett, DOT Compliance Asst., Suburban Propane, L.P. (minglett@suburbanpropane.com)#