# SUNOCO PIPELINE L.P. — Warning Letter

- **operation:** document
- **citation:** CPF 420075017W
- **title:** SUNOCO PIPELINE L.P. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-05-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.406.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420075017w.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420075017w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420075017W
**body:**

Warning Letter involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulation as 195.406. The case was opened on 2007-05-21 and is reported as closed as of 2007-05-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075017W_warning letter_05212007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075017W/420075017W_warning%20letter_05212007.pdf

420075017W_warning letter_05212007.pdf

U.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:



§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



No 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
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L d l l f s * f - . f /
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R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
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