SUNOCO PIPELINE L.P. — Warning Letter

420075017W_warning letter_05212007.pdf, page 1Official PDFU.S. Department 8701 S. Gessner, Suite 1110 of Transportation Houston, TX 77074 Pipeline and Hazardous Materials Safety Administration WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED May 21, 2007 Vice President, Western Operations Paul S. Broker One Flour Daniel Drive Sunoco Pipeline, L.P. Sugarland, Texas 77478 Building A, Level 3 CPF 4-2007-5017W Dear Mr. Justin: On August 22-26, 2005, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the Black Hills Operating, LLC, Millenium Pipeline System in Longview, Texas. Sunoco Pipeline LP acquired these assets on March 1, 2006. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are:#

420075017W_warning letter_05212007.pdf, page 2§195.406 Maximum operating pressure. (a) Except for surge pressures and other variations from normal operations, no operator may operate a pipeline at a pressure that exceeds any of the following: (1) The internal design pressure of the pipe determined in accordance with §195.106. However, for steel pipe in pipelines being converted under §195.5, if following pressures is to be used as design pressure: one or more factors of the design formula (§195.106) are unknown, one of the (i) Eighty percent of the first test pressure that produces yield under section N5.0 of Appendix N of ASME B31.8, reduced by the appropriate factors in §§195.106(a) (il) If the pipe is 323.8mm (12¾ in) or less outside diameter and is not tested to and (e); or yield under this paragraph, 1379 kPa (200 psig). (2) The design pressure of any other component of the pipeline. (3) Eighty percent of the test pressure for any part of the pipeline which has been (4) Eighty percent of the factory test pressure or of the prototype test pressure for pressure tested under Subpart E of this part. any individually installed component which is exempted from testing under (5) For pipelines under §§195.302(b)(1) and (b)(2)(i), that have not been pressure §195.305. tested under Subpart E of this part, 80 percent of the test pressure or highest hours that can be demonstrated by recording charts or logs made at the time the operating pressure to which the pipeline was subjected for 4 or more continuous test or operations were conducted. variations from normal operations to exceed 110 percent of the operating (b) No operator may permit the pressure in a pipeline during surges or other must provide adequate controls and protective equipment to control the pressure pressure limit established under paragraph (a) of this section. Each operator within this limit. Review of the Reiber Station pump pressure discharge charts for September 2004 revealed that only allow for surge and other variations to exceed MOP. No references were made to discharge pressures exceeded your established MOP for 6-10 hours of operation. Regulations abnormal operating conditions or other variances for the occurrence. The duration exceeded any surge condition. or penalty assessment proceedings at this time. We advise you to correct the item identified in Failure to do so will result in Sunoco Pipeline LP being subject to additional 2#

420075017W_warning letter_05212007.pdf, page 3No reply to this letter is required. lf you choose to reply, in your correspondence please refer to *Ff 4-2*6?-SS"t7W. te advised that all material you submit in response to this enforcement action is subject to being made publicly available. lf you believe that any portion of your responsive material qralifies for confidential treatment under 5 {,J.S.fi. 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 confidentialtreatment under 5 U.S"C. 55?(b). Sincerely, ;: lt t r r ' . / / L d l l f s * f - . f / -ff-+'34' *'{i{d'W t;f R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#