{"operation":"document","citation":"CPF 420155005H","title":"WEST TEXAS GULF PIPELINE CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-03-12","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155005h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155005h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420155005h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420155005H","body":"Corrective Action Order involving WEST TEXAS GULF PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2015-03-12 and is reported as closed as of 2020-02-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420155005H_Amended Corrective Action Order_09042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Amended%20Corrective%20Action%20Order_09042015.pdf\n\n420155005H_Amended Corrective Action Order_09042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Amended%20Corrective%20Action%20Order_09042015_text.pdf\n\n420155005H_Closure Letter_02122020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Closure%20Letter_02122020.pdf\n\n420155005H_Closure Letter_02122020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Closure%20Letter_02122020_text.pdf\n\n420155005H_Consent Agreement_10032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Agreement_10032016.pdf\n\n420155005H_Consent Agreement_10032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Agreement_10032016_text.pdf\n\n420155005H_Consent Order_03242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Order_03242017.pdf\n\n420155005H_Consent Order_03242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Order_03242017_text.pdf\n\n420155005H_Corrective Action Order_03122015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Corrective%20Action%20Order_03122015.pdf\n\n420155005H_Corrective Action Order_03122015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Corrective%20Action%20Order_03122015_text.pdf\n\n420155005H_Corrective Action Order_03122015_text.pdf\n\nMarch 12, 2015\nMr. Michael J. Hennigan\nPresident and Chief Executive Officer\nSunoco Logistics Partners L.P.\n1818 Market Street, Suite 1500\nPhiladelphia, Pennsylvania 19103\nRe: CPF No. 4-2015-5005H\nDear Mr. Hennigan:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires your\nsubsidiary, West Texas Gulf Pipe Line Company, to take certain corrective actions with respect\nto the West Texas Gulf System #1, Unit 8514, Blum to Wortham Segment, which failed on\nFebruary 25, 2015, at mile post (MP) 257 in Navarro County near the Town of Dawson, Texas.\nService is being made by certified mail and facsimile. Service by electronic transmission is\ndeemed complete upon transmission and acknowledgement of receipt, or as otherwise provided\nunder 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion\nof service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. R. M. Seeley, Director, Southwest Region, OPS\nMr. David Chalson, Vice President, Operations, Sunoco Logistics Partners L.P.,\n4041 Market Street, Aston, PA 19014\nMr. Todd Nardozzi, DOT Compliance Manager, Sunoco Logistics Partners L.P.\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\n)\n)\nWest Texas Gulf Pipe Line Company, a subsidiary of Sunoco Logistics )\nPartners L.P., )\n)\nRespondent. )\n___________________________________ )\n) CPF No. 4-2015-5005H\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to\nrequire West Texas Gulf Pipe Line Company (West Texas Gulf or Respondent), a subsidiary of\nSunoco Logistics Partners L.P., to take the necessary corrective actions to protect the public,\nproperty, and the environment from potential hazards associated with the recent failure on\nRespondent’s West Texas Gulf Pipeline.\nOn February 25, 2015, a reportable accident occurred on the West Texas Gulf Pipeline System\n#1, Unit 8514, at mile post (MP) 257 on the Blum to Wortham Segment, resulting in the release\nof approximately 50 barrels of crude oil (Failure). The West Texas Gulf Pipeline is\napproximately 580 miles in length and transports crude oil from Colorado City, Texas, to\nterminals in Longview and Nederland, Texas. The probable cause of the Failure is external\nmetal loss due to corrosion. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an\ninvestigation of the accident. The preliminary findings of the ongoing investigation are as\nfollows.\nPreliminary Findings:\n• Respondent, a wholly-owned subsidiary of Sunoco Logistics Partners L.P., operates\napproximately 580 miles of pipeline and delivers crude-oil from Colorado City, Texas, to\nterminals in Longview and Nederland, Texas.\n• Sunoco Logistics Partners L.P. (Sunoco Logistics) is a master limited partnership and\nparent company of Respondent. Sunoco Logistics’ crude-oil Pipeline System consists of\n\n\n\nCPF No. 4-2015-5005H\nPage 2\napproximately 5,300 miles of crude-oil trunk pipelines for high-volume, long-distance\ntransportation, and approximately 500 miles of crude-oil gathering lines that supply the\ntrunk lines. Sunoco Logistics’ general partner is owned by Energy Transfer Partners,\nL.P.1\n• The Affected Segment was originally constructed in 1952. It consists of Grade X-46 26-\ninch diameter seamless pipe manufactured by National Tube and has a wall thickness of\n0.312,” with a coal tar coating. It transports crude-oil from Blum, Texas, to Wortham,\nTexas, a distance of approximately 63 miles (Affected Segment).\n• The maximum operating pressure (MOP) of the pipeline is 750 psig. The MOP was\nestablished using a risk-based alternative to hydrotesting. The operating pressure at the\ntime of the Failure was 625 psig.\n• At approximately 12:00 a.m. Central Time (C.T.), on February 25, 2015, a Failure\noccurred on the Affected Segment at MP 257 near the Town of Dawson, Texas (Failure\nSite). The failed pipeline segment is a 26-inch diameter line. The release occurred\ndownstream of the company’s Blum Pump Station and upstream of the Wortham Pump\nStation.\n• As a result of the Failure, approximately 50 barrels of crude-oil flowed onto the ground\nand approximately 1 barrel of crude oil flowed into a nearby pond. The Failure was\nreported to the National Response Center (NRC Report # 1109008) on February 25,\n2015, at approximately 3:33 a.m. Eastern Time (E.T.).\n• Respondent was notified of the release at approximately 12:00 a.m. C.T. when local\nemergency responders contacted the Sunoco Logistics Control Room to report crude oil\nbeing released at Farm to Market (FM) Road 709 in Navarro, Texas. The report\nindicated that crude-oil was being released from a casing vent onto the ground and in the\nbar ditch adjacent to the pipeline crossing in that location.\n• In response, Respondent shut down the pump units and immediately dispatched field\npersonnel to the Failure Site. Once on-site, Respondent’s field personnel deployed\nbooms and stationed vacuum trucks to collect oil from the roadway bar ditches, an\nadjacent field, and a pond.\n• The probable cause of the Failure is external metal loss due to corrosion.\n• The accident did not cause any known fatalities, injuries, or evacuations.\n• As a result of the Failure, the Farm to Market Road 709 was temporarily closed so that\nRespondent’s field personnel could collect oil from the roadway. Additionally,\napproximately 1 barrel of crude oil reached a nearby pond, and some oil traveled to an\nadjacent field. The Failure Site is located in Navarro County, Texas, which has a\n1 See http://www.sunocologistics.com/Investors/Company-Information/32/ (last accessed March 9, 2015).\n\n\n\nCPF No. 4-2015-5005H\nPage 3\npopulation of approximately 48,000 people. Specifically, the release occurred near the\nTown of Dawson, which has a population of approximately 800 people.\n• PHMSA, Southwest Region (SW), Office of Pipeline Safety (OPS), made initial contact\nwith Respondent on February 25, 2015. Respondent advised PHMSA, SW, OPS, that it\nwould be notified prior to the pipeline being placed back in service.\n• On February 25, 2015, Respondent exposed the pipeline and began repairs. At that time,\nan 80% metal loss anomaly was discovered in close proximity to the Failure location on\nthe same pipeline joint.\n• During repair of the failure location, Respondent installed a leak clamp on the newly-\ndiscovered 80% metal loss anomaly.\n• On February 26, 2015, Respondent returned the line to service at full operating pressure\nwithout notice to PHMSA, SW, OPS.\n• PHMSA, SW, OPS, requested repair records and In-line Inspection (ILI) data from the\nRespondent and reviewed them between February 27, 2015, and March 6, 2015.\n• According to Respondent’s ILI data, the Affected Segment was inspected in 2006 and\n2011 using ILI tools to perform an assessment of the geometry and metal loss conditions\nof the pipeline. The next assessment was scheduled for 2016.\n• Further review revealed that there was 17% metal loss at the site of the Failure in 2006\nand that by 2011 the metal loss had grown to 68%. The corrosion growth rate for this\nfeature predicted failure prior to Respondent’s next scheduled assessment in 2016.\n• The newly-discovered 80% metal loss anomaly was not identified in the 2011\nassessment.\n• The cause and proliferation of the accelerated metal loss growth rates along the Affected\nSegment is unknown at this time.\n• Review of Respondent’s repair records revealed that the leak clamp used to repair the\nnewly-discovered 80% metal loss anomaly was not installed in accordance with the\nmanufacturer’s specifications and was not an appropriate application with respect to this\ntype of anomaly.\n• Upon subsequent questioning by PHMSA, Respondent chose to take a voluntary 20%\noperating pressure reduction and committed to removal of the 80% metal loss anomaly\nrepair on March 6, 2015.2\n2 See Sunoco Logistics Partners L.P. email and attachments, (March 6, 2015).\n\n\n\nCPF No. 4-2015-5005H\nPage 4\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, having considered the nature of the failure; the unexplained\naccelerated metal loss growth rates; the existence of at least one immediate repair anomaly not\npreviously identified; the location of the failure; the proximity to a public roadway and pond; the\nage of the pipeline, and the threat of further failures and detrimental environmental impact due to\nuncertainty in Respondent’s integrity management processes along this segment, I find that a\nfailure to issue this Order expeditiously to require immediate corrective action would result in\nthe likelihood of serious harm to life, property, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,\nPHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person\nin Southwest Region Office or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order West Texas Gulf to immediately take the\nfollowing corrective actions for the Affected Segment:\n\n\n\nCPF No. 4-2015-5005H\nPage 5\nDefinitions:\n“Affected Segment” – The “Affected Segment” means approximately 63 miles of West Texas\nGulf’s 26-inch pipeline designated as the Blum to Wortham segment located in rural East Texas.\n“Director” – “Director” means the Director, Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety, Southwest Region, 8701 South Gessner,\nSuite 1110, Houston, Texas 77074.\n1. Operating Pressure Restriction. Respondent must maintain a twenty percent (20%)\npressure reduction in the actual operating pressure along the Affected Segment such\nthat the operating pressure on this segment will not exceed eighty percent (80%) of the\nactual operating pressure in effect immediately prior to the failure on February 25,\n2015.\na. This pressure restriction is to remain in effect until written approval to increase\nthe pressure or return the pipeline to its pre-failure operating pressure is\nobtained from the Director.\nb. This pressure restriction requires any relevant remote or local alarm limits,\nsoftware programming set-points or control points, and mechanical over-\npressure devices to be adjusted accordingly.\n2. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction\nupon a written request from Respondent demonstrating that restoring the\nAffected Segment to its pre-failure operating pressure is justified, based on a\nreliable engineering analysis showing that the pressure increase is safe,\nconsidering all known defects, anomalies, and operating parameters of the\npipeline.\n3. Mechanical and Metallurgical Testing. Within 30 days of receipt of this Order, West\nTexas Gulf must complete mechanical and metallurgical testing and failure analysis of\nthe failed pipe, including an analysis of water samples and any foreign materials related\nto the casing and pipeline failure environment. Complete the testing and analysis as\nfollows:\na. b. c. Within 10 days of receipt of this Order, develop and submit the testing protocol\nand the proposed testing laboratory to the Director for prior approval.\nProvide the Director with the scheduled date, time, and location of the testing to\nallow for an OPS representative to witness the testing.\nEnsure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to Respondent.\n4. Root Cause Failure Analysis (RCFA). Within 45 days following receipt of the final\nreport from the metallurgical testing laboratory, Respondent must submit a Report\nsummarizing the results of the Root Cause Failure Analysis performed by the\nRespondent or its Third Party. The Root Cause Failure Analysis shall include, at a\n\n\n\nCPF No. 4-2015-5005H\nPage 6\nminimum, a structured method to evaluate the causal factors and perform an\ninvestigation of the following management processes and the role they may have had in\nthe failure:\na. Respondent’s ILI specifications and instructions to its vendors and the timing\nand detail of the information provided by the ILI vendor;\nb. Respondent’s evaluation of corrosion growth rates, interaction criteria,\nevaluation of ILI vendor data, determination of assessment schedules, processes\nto confirm assumptions used in determining the assessment schedules (corrosion\ngrowth rates, tool uncertainty, correlation, etc.); and\nc. Respondent’s proposed corrective actions, including revisions to its Integrity\nManagement Plan and Pipeline Repair Procedures, as necessary, to prevent\nrecurrence of such a failure.\n5. Remedial Work Plan.\na. Within 15 days following submittal of the Root Cause Failure Analysis Report,\nRespondent must submit a Remedial Work Plan (RWP) to the Director for\napproval.\nb. The Director may approve the RWP incrementally without approving the entire\nRWP.\nc. Once approved by the Director, the RWP will be incorporated by reference into\nthis Order.\nd. The RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures Respondent will use to verify the integrity of the Affected\nSegment. It must address all known or suspected factors and causes of the\nFebruary 25, 2015 failure.\ne. The RWP must include a procedure or process to:\ni. Perform an ILI inspection of the Affected Segment.\nii. Evaluate the results of the ILI inspection using appropriately\nconservative interaction criteria and corrosion growth rates to determine\nthe features to be evaluated by direct examination, and the next\nassessment schedule.\niii. Revise procedures, as identified in the RCFA Report, and complete\ntraining of personnel on the revised procedures.\niv. Integrate the results of the metallurgical testing, root cause failure\nanalysis, and other corrective actions required by this Order with all\nrelevant pre-existing operational and assessment data for the Affected\nSegment.\nv. Determine if conditions similar to those contributing to the failure on\nFebruary 25, 2015 are likely to exist elsewhere on the West Texas Gulf\nPipeline.\nf. Describe the inspection and repair criteria Respondent will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats along the Affected Segment. Include a description of how any\ndefects will be graded and a schedule for repairs or replacement.\ng. Respondent shall include a proposed schedule for completion of the activities\nincluded in the RWP.\n\n\n\nCPF No. 4-2015-5005H\nPage 7\nh. Respondent must revise the RWP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate\nthe results of actions undertaken pursuant to this Order, and/or to incorporate\nmodifications required by the Director.\ni. Submit any plan revisions to the Director for prior approval.\nj. Respondent shall implement the RWP as it is approved by the Director,\nincluding any revisions to the plan.\n6. Monthly Reports to the Director. Respondent shall submit written reports to the\nDirector, detailing the status of the work associated with this Order, and providing a list\nof upcoming work involving live-line welding, tie-ins or other activities that will\ninvolve the submittal of Job Plans to the Director for approval. The first Report will be\ndue April 15, 2015, and monthly thereafter, on the 15th of each month until such time\nthat the schedule is adjusted and approved by the Director or this Order is closed.\nOther Requirements:\n1. Reporting. Submit monthly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first monthly report is due\non April 15, 2015. The Director may change the interval for the submission of these\nreports.\n2. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure,\nincluding repairs, replacements and other modifications; and (3) environmental\nremediation, if applicable.\nApprovals. With respect to each submission requiring the approval of the Director, the\nDirector may: (a) approve the submission in whole or in part; (b) approve the submission\non specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove the submission in whole or in part and direct Respondent to modify the\nsubmission; or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission, as approved or modified by the Director. If the Director\ndisapproves all or any portion of a submission, Respondent must correct all deficiencies\nwithin the time specified by the Director and resubmit it for approval.\n4. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted and demonstrating\ngood cause for an extension.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part [195, 193, 192],\n3.\n\n\n\nCPF No. 4-2015-5005H\nPage 8\nunder any other order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or\nunder any other provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 4-2015-5005H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420155005H_Amended Corrective Action Order_09042015_text.pdf\n\nSeptember 4, 2015\nMr. Michael J. Hennigan\nPresident and Chief Executive Officer\nSunoco Logistics Partners L.P.\nc/o Mr. David Chalson\n4041 Market Street\nAston, PA 19014\nRe: CPF No. 4-2015-5005H\nDear Mr. Hennigan:\nEnclosed is an Amendment to the Corrective Action Order issued in the above-referenced case\non March 12, 2015. Service by electronic transmission is deemed complete upon transmission\nand acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms\nand conditions of this Order are effective upon completion of service.\nPlease direct any questions on this matter to Rod Seeley, Director, Southwest Region, Office of\nPipeline Safety, PHMSA at (713) 272-2852.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. R. M. Seeley, Director, Southwest Region, OPS\nMr. David Chalson, Vice President, Operations, Sunoco Logistics Partners, L. P., 4041\nMarket Street, Aston, PA 19014\nMr. Todd Nardozzi, Compliance Manager, Sunoco Logistics Partners, L. P., Sugar Land,\nTX\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\n)\n)\nWest Texas Gulf Pipe Line Company, a subsidiary of Sunoco Logistics )\nPartners L.P., )\n)\nRespondent. )\n___________________________________ )\n) CPF No. 4-2015-5005H\nAMENDMENT\nTO THE CORRECTIVE ACTION ORDER\nBackground and Purpose:\nOn March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for\nPipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a\nCorrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas\nGulf or Respondent), a subsidiary of Sunoco Logistics Partners L.P., to take the necessary\ncorrective actions to protect the public, property, and the environment from potential hazards\nassociated with Respondent’s West Texas Gulf Pipeline.\n1 PHMSA issued the Original CAO in\nresponse to a failure that occurred on February 25, 2015, on the West Texas Gulf Pipeline\nSystem #1, Unit 8514, at mile post (MP) 257 on the Blum to Wortham Segment, resulting in the\nrelease of approximately 50 barrels of crude oil (Failure).\nThe West Texas Gulf Pipeline is approximately 580 miles in length and transports crude oil from\nColorado City, Texas, to terminals in Longview and Nederland, Texas.\nAdditional Preliminary Findings:\nThe preliminary findings in the Original CAO noted the failure and related information on\nRespondent’s West Texas Gulf Pipe Line and details about the defect discovered as a result of\nthe February 25, 2015 failure. Since that time, the following events have occurred:\n1 In the Matter of West Texas Gulf Pipe Line Company, Corrective Action Order (CPF No. 4-2015-5005H) dated\nMarch 12, 2015.\n\n\n\nCPF No. 4-2015-5005H\nPage 2\n• On April 8, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil\nPenalty and Compliance Order (NOPV1) to West Texas Gulf Pipe Line for failure to\nreport a serious accident that was alleged to have occurred on February 19, 2013.2\n• On April 27, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil\nPenalty (NOPV2)3 to West Texas Gulf Pipe Line alleging improper pipeline repair\nmethods and failing to correct a metal loss condition that was known to exist prior to its\nfailure related to the accident for which the Original CAO was issued.\n• On May 8, 2015, West Texas Gulf’s operator, Sunoco Pipeline, L.P. (SPLP), responded\nto the NOPV, submitted an accident report for the reportable accident that occurred on\nFebruary 19, 2013, submitted a copy of the internal investigation report and stated that\nthe proposed civil penalties associated with the Probable Violations had been paid via\nwire transfer on May 7, 2015.\n• On June 7, 2015, a second leak of the same nature as the leak of February 25, 2015 was\nreported to PHMSA by the Respondent at a location approximately seven (7) miles\ndownstream from the original leak for which the Original CAO was issued.\n• On June 19, 2015, a major release of crude oil occurred at the Wortham Facility where\nmore than 3,000 barrels of crude oil leaked from a failed flanged connection on piping\nthat was installed in 2013 and associated with the project in which the serious accident\noccurred.\n• On May 28, 2015 and June 23, 2015, two reportable accidents4 occurred at the Sunoco\nPipeline, L. P. Corsicana facility as part of the Permian Express II construction project\nwhich was managed by the same construction manager, and pipeline operator responsible\nfor projects upon which the West Texas Gulf February 19, 2013 accident and the June 19,\n2015 accidents occurred.\nThe preliminary findings, additional failures and subsequent investigation into the events on the\nWest Texas Gulf Pipe Line system indicate that potential hazards associated with the operation\nof this system remain. PHMSA has communicated its concerns about this pattern of failures\nwith Respondent since an accident similar to the 2013 accident subject of NOPV1 occurred on\nthe Respondent’s system in 2009.5\n2 In the Matter of West Texas Gulf Pipe Line Company, Notice of Probable Violation and Proposed Civil Penalty\nand Compliance Order (CPF No. 4-2015-5009) dated April 8, 2015.\n3 In the Matter of West Texas Gulf Pipe Line Company, Notice of Probable Violation and Proposed Civil Penalty\nand Compliance Order (CPF No. 4-2015-5012) dated April 27, 2015.\n4 Reference OPID 19718, Sunoco Pipeline, L. P., Accident Reports filed on Form 7000-1, Report Numbers\n20150230–20542, and 20150266–20613 for accidents occurring on May 28, 2015 and June 23, 2015, respectively.\n5 In the Matter of West Texas Gulf Pipe Line Company, Final Order (CPF No. 4-2010-5010) dated August 1, 2012,\nand Decision on Petition for Reconsideration (CPF No. 4-2010-5010) dated December 31, 2012.\n\n\n\nCPF No. 4-2015-5005H\nPage 3\nFinding of Hazardous Condition\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, including amendments, after reasonable notice and the opportunity for a hearing,\nrequiring the operator of a pipeline determined to pose a hazard to take corrective actions to\nprotect people and the environment. These may include the suspended or restricted use of a\npipeline facility, physical inspection, testing, repair, replacement, or other action, as appropriate.\nThe basis for making a determination that a pipeline facility is or would be hazardous, requiring\ncorrective action, is set forth both in the above-referenced statute and 49 C.F.R. § 190.233, a\ncopy of which is enclosed.\nAfter evaluating all available information regarding the safety of the West Texas Gulf Pipe Line\nSystem, including the foregoing additional preliminary findings, and considering the nature,\ncircumstances, and gravity surrounding the pattern of accidents, the hazardous nature of the\nproduct transported, the serious nature of the injury that went unreported, and the ongoing\ninvestigation to determine the root cause of the multiple failures reported on Respondent’s\npipeline system, I find that the continued operation of the West Texas Gulf Pipe Line without\nadditional corrective measures would be hazardous to life, property, and the environment.\nAccordingly, PHMSA hereby issues this Amendment to the CAO requiring the additional\nactions specified herein be taken to protect life, property, and the environment. The additional\nactions set forth in this Amendment to the CAO are in addition to the actions set forth in the\nOriginal CAO and do not suspend or eliminate the requirements of the Original CAO, unless\notherwise specifically provided herein.\nAmendments to Required Corrective Action\nPursuant to 49 U.S.C. § 60112 and 49 C.F.R. §190.233, West Texas Gulf Pipe Line, and its\noperator Sunoco Pipeline, L. P. are ordered to comply with this Amendment to the CAO and take\nthe following additional corrective actions with respect to the West Texas Gulf Pipe Line. The\nfollowing item is added to the Corrective Action Order:\n7. Before the Director, Southwest Region, OPS, approves the return to normal operating\npressure under Item 2 of the Original CAO, Respondent must complete the following:\nA. Reinstate the 20% Operating Pressure Restriction ordered in the Original CAO, and\nmaintain that pressure restriction until the actions in Item 7B of this Amended CAO have\nbeen completed.\nB. For the entire West Texas Gulf Pipe Line System, its operation, and the Operating,\nMaintenance and Construction policies and procedures under which it operates, including all\naspects for which the regulations in 49 C.F.R. §195 apply to the pipeline system and its\noperator, SPLP must: (1) submit, for prior review and approval of the Director, a\ncomprehensive written plan, including timelines for specific actions to improve the safety\nperformance of Respondent’s West Texas Gulf Pipe Line System; and (2) hire an\nindependent third party pipeline expert in safety management systems to review and assess\n\n\n\nCPF No. 4-2015-5005H\nPage 4\nthe written plan, which third party expert must oversee the creation, execution and\nimplementation of the actions identified in the plan, and must provide bi-monthly monitoring\nsummaries to PHMSA and Respondent concurrently.\nRespondent must address any deficiencies or risks identified in the third party’s\nassessment, including completing repairs and implementing corrective actions related to\nsafety culture and safety management processes. The plan must be sufficiently detailed with\nspecific tasks, milestones and completion dates. At a minimum, the plan must address:\na. Organizational issues, including creation of a Safety Management System\npromoting a safety culture that is equivalent to the elements considered essential\nin the American Petroleum Institute (API) Recommended Practice (RP) 1173\nincluding:\ni. Management Commitment and Leadership\nii. Risk Management\niii. Operational Controls\niv. Incident Investigation, Evaluation and Lessons Learned\nv. Safety Assurance and Continuous Improvement\nvi. Competence, Training, Qualification and Development\nvii. Emergency Preparedness and Response\nviii. Documentation and Record Keeping\nix. Stakeholder Engagement\nb. Contractor oversight and inspection of construction activities while performing\nconstruction in existing or operating facilities, whether the facilities are owned or\noperated by Respondent or other pipeline operators transporting hazardous\nmaterials and subject to the requirements of 49 C.F.R. §195, and the commitment\nto ensure adequate resources are provided to maintain safety during construction\nactivities. Specific attention shall be given to:\nii. iii. i. Adherence to Respondent’s Operations and Maintenance procedures\nrequired by 49 C.F.R. 195 Subpart F,\nOperator Qualification regulations in 49 C.F.R.§ 195 Subpart G, and\nDrug and Alcohol Post Accident Testing regulations in 49 C.F.R.§199\nc. Work Plans and the requirement for preparation of and adherence to a detailed\nWork Plan when performing activities for which an existing Operations and\nMaintenance procedure does not exist.\nd. Any other risk, task, issue, or item that is necessary to promote and sustain the\nsafety of its pipeline system.\nThe actions required by this Amendment to the CAO are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under the Original CAO, and under 49\nC.F.R. Parts 190, 194, 195 and 199, as applicable, or any other Order issued to Respondent under\nauthority of 49 U.S.C. § 60101, et seq., or under any other provision of Federal or State law.\n\n\n\nCPF No. 4-2015-5005H\nPage 5\nAfter receiving and analyzing additional data in the course of this and the subject related\ninvestigations, PHMSA may identify other corrective actions that need to be taken. In that event,\nRespondent will be notified of any additional measures required and further amendment of the\nCAO will be considered. To the extent consistent with safety, Respondent will be afforded\nnotice and an opportunity for a hearing prior to the imposition of any additional corrective\nmeasures.\nThe terms and conditions of this Amended Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420155005H_Consent Agreement_10032016_text.pdf\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\nIn the Matter of )\nWest Texas Gulf Pipe Line Company, Respondent. )\n_\n)\n)\n)\n)\n) CPF No. 4-2015-5005H\nCONSENT AGREEMENT\nOn March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for\nPipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a\nCorrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas\nGulf or Respondent), owned and operated by Sunoco Pipeline, LP (SPLP), to take the necessary\ncorrective actions to protect the public, property, and the environment from potential hazards\nassociated with Respondent’s West Texas Gulf Pipeline. PHMSA issued the Original CAO in\nresponse to a failure that occurred on February 25, 2015, on the West Texas Gulf Pipeline System\n#1, Unit 8514, at mile post (MP) 257 on the Blum-to-Wortham Segment, which resulted in the\nrelease of approximately 30 barrels of crude oil (Failure).\nSince that time, there have been additional accidents on the West Texas Gulf Pipeline that have\ncaused the expansion of PHMSA’s concerns regarding the safety of the West Texas Gulf System.\nThe following events have occurred:\n• On April 8, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil\nPenalty and Compliance Order 4-2015-5009 (NOPV1) to Respondent for failure to report\na serious accident that occurred on February 19, 2013, at its Wortham, Texas Facility\n(2013 Failure). Respondent has complied with the terms of the proposed Compliance\nOrder and paid the proposed penalty, so PHMSA issued a Final Order and closed the case\non November 3, 2015.\n• On April 27, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil\nPenalty 4-2015-5012 (NOPV2) to Respondent for certain violations arising out of the\nFailure, alleging improper pipeline repair methods and the failure to correct a metal-loss\ncondition that was known by Respondent to exist prior to the Failure. Respondent paid a\nportion of the proposed penalty in that case and is awaiting the issuance of a Final Order.\n• On June 7, 2015, West Texas Gulf experienced a second leak on the Affected Segment\ninvolving external metal loss due to corrosion was reported to PHMSA by the Respondent\nat a location approximately seven miles downstream from the original leak and nine and\n\n\n\none-half miles upstream of the Wortham, Texas Facility for which the Original CAO was\nissued.\n• On June 19, 2015, a major release of crude oil occurred at Respondent’s Wortham Facility,\nwhere an estimated 3,300 barrels of crude oil leaked from a failed flanged connection on\npiping that was installed in 2013 and associated with the construction/modification project\nin which the February 19, 2013 accident occurred.\n• On May 28, 2015 and June 23, 2015, two reportable accidents occurred at the SPLP\nCorsicana facility as part of the Permian Express II construction project. This project was\nmanaged by the same West Texas Gulf department responsible for projects upon which the\nWest Texas Gulf February 19, 2013 accident and the June 19, 2015 accidents occurred.\n• On November 10, 2015, a failure of a control valve and release of crude oil occurred\nwhile piping associated with the June 19, 2015 release was being replaced. Five people\nwere transported to the hospital for treatment of crude oil exposure to the face and eyes as\nwell as bruises and contusions after a relief valve failed when it was improperly\ndisconnected while under pressure. The accident was a result of improper isolation and\nfailure to follow instructions for safely de-energizing the valve before its removal.\n• Taken together, the accidents described above raised serious concerns to PHMSA about\nthe overall safety of the West Texas Gulf Pipeline System, the processes by which West\nTexas Gulf makes decisions about safety, how different parts of the company ","truncated":true,"body_characters":62615}