# WEST TEXAS GULF PIPELINE CO — Corrective Action Order

- **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:** Not available
- **summary:** CLOSED corrective action order.
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- **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.

Official case documents:

420155005H_Amended Corrective Action Order_09042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Amended%20Corrective%20Action%20Order_09042015.pdf

420155005H_Amended Corrective Action Order_09042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Amended%20Corrective%20Action%20Order_09042015_text.pdf

420155005H_Closure Letter_02122020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Closure%20Letter_02122020.pdf

420155005H_Closure Letter_02122020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Closure%20Letter_02122020_text.pdf

420155005H_Consent Agreement_10032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Agreement_10032016.pdf

420155005H_Consent Agreement_10032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Agreement_10032016_text.pdf

420155005H_Consent Order_03242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Order_03242017.pdf

420155005H_Consent Order_03242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Consent%20Order_03242017_text.pdf

420155005H_Corrective Action Order_03122015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Corrective%20Action%20Order_03122015.pdf

420155005H_Corrective Action Order_03122015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420155005H/420155005H_Corrective%20Action%20Order_03122015_text.pdf

420155005H_Corrective Action Order_03122015_text.pdf

March 12, 2015
Mr. Michael J. Hennigan
President and Chief Executive Officer
Sunoco Logistics Partners L.P.
1818 Market Street, Suite 1500
Philadelphia, Pennsylvania 19103
Re: CPF No. 4-2015-5005H
Dear Mr. Hennigan:
Enclosed is a Corrective Action Order issued in the above-referenced case. It requires your
subsidiary, West Texas Gulf Pipe Line Company, to take certain corrective actions with respect
to the West Texas Gulf System #1, Unit 8514, Blum to Wortham Segment, which failed on
February 25, 2015, at mile post (MP) 257 in Navarro County near the Town of Dawson, Texas.
Service is being made by certified mail and facsimile. Service by electronic transmission is
deemed complete upon transmission and acknowledgement of receipt, or as otherwise provided
under 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion
of service.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. R. M. Seeley, Director, Southwest Region, OPS
Mr. David Chalson, Vice President, Operations, Sunoco Logistics Partners L.P.,
4041 Market Street, Aston, PA 19014
Mr. Todd Nardozzi, DOT Compliance Manager, Sunoco Logistics Partners L.P.



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
)
)
West Texas Gulf Pipe Line Company, a subsidiary of Sunoco Logistics )
Partners L.P., )
)
Respondent. )
___________________________________ )
) CPF No. 4-2015-5005H
CORRECTIVE ACTION ORDER
Purpose and Background:
This Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to
require West Texas Gulf Pipe Line Company (West Texas Gulf or Respondent), a subsidiary of
Sunoco Logistics Partners L.P., to take the necessary corrective actions to protect the public,
property, and the environment from potential hazards associated with the recent failure on
Respondent’s West Texas Gulf Pipeline.
On February 25, 2015, a reportable accident occurred on the West Texas Gulf Pipeline System
#1, Unit 8514, at mile post (MP) 257 on the Blum to Wortham Segment, resulting in the release
of approximately 50 barrels of crude oil (Failure). The West Texas Gulf Pipeline is
approximately 580 miles in length and transports crude oil from Colorado City, Texas, to
terminals in Longview and Nederland, Texas. The probable cause of the Failure is external
metal loss due to corrosion. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an
investigation of the accident. The preliminary findings of the ongoing investigation are as
follows.
Preliminary Findings:
• Respondent, a wholly-owned subsidiary of Sunoco Logistics Partners L.P., operates
approximately 580 miles of pipeline and delivers crude-oil from Colorado City, Texas, to
terminals in Longview and Nederland, Texas.
• Sunoco Logistics Partners L.P. (Sunoco Logistics) is a master limited partnership and
parent company of Respondent. Sunoco Logistics’ crude-oil Pipeline System consists of



CPF No. 4-2015-5005H
Page 2
approximately 5,300 miles of crude-oil trunk pipelines for high-volume, long-distance
transportation, and approximately 500 miles of crude-oil gathering lines that supply the
trunk lines. Sunoco Logistics’ general partner is owned by Energy Transfer Partners,
L.P.1
• The Affected Segment was originally constructed in 1952. It consists of Grade X-46 26-
inch diameter seamless pipe manufactured by National Tube and has a wall thickness of
0.312,” with a coal tar coating. It transports crude-oil from Blum, Texas, to Wortham,
Texas, a distance of approximately 63 miles (Affected Segment).
• The maximum operating pressure (MOP) of the pipeline is 750 psig. The MOP was
established using a risk-based alternative to hydrotesting. The operating pressure at the
time of the Failure was 625 psig.
• At approximately 12:00 a.m. Central Time (C.T.), on February 25, 2015, a Failure
occurred on the Affected Segment at MP 257 near the Town of Dawson, Texas (Failure
Site). The failed pipeline segment is a 26-inch diameter line. The release occurred
downstream of the company’s Blum Pump Station and upstream of the Wortham Pump
Station.
• As a result of the Failure, approximately 50 barrels of crude-oil flowed onto the ground
and approximately 1 barrel of crude oil flowed into a nearby pond. The Failure was
reported to the National Response Center (NRC Report # 1109008) on February 25,
2015, at approximately 3:33 a.m. Eastern Time (E.T.).
• Respondent was notified of the release at approximately 12:00 a.m. C.T. when local
emergency responders contacted the Sunoco Logistics Control Room to report crude oil
being released at Farm to Market (FM) Road 709 in Navarro, Texas. The report
indicated that crude-oil was being released from a casing vent onto the ground and in the
bar ditch adjacent to the pipeline crossing in that location.
• In response, Respondent shut down the pump units and immediately dispatched field
personnel to the Failure Site. Once on-site, Respondent’s field personnel deployed
booms and stationed vacuum trucks to collect oil from the roadway bar ditches, an
adjacent field, and a pond.
• The probable cause of the Failure is external metal loss due to corrosion.
• The accident did not cause any known fatalities, injuries, or evacuations.
• As a result of the Failure, the Farm to Market Road 709 was temporarily closed so that
Respondent’s field personnel could collect oil from the roadway. Additionally,
approximately 1 barrel of crude oil reached a nearby pond, and some oil traveled to an
adjacent field. The Failure Site is located in Navarro County, Texas, which has a
1 See http://www.sunocologistics.com/Investors/Company-Information/32/ (last accessed March 9, 2015).



CPF No. 4-2015-5005H
Page 3
population of approximately 48,000 people. Specifically, the release occurred near the
Town of Dawson, which has a population of approximately 800 people.
• PHMSA, Southwest Region (SW), Office of Pipeline Safety (OPS), made initial contact
with Respondent on February 25, 2015. Respondent advised PHMSA, SW, OPS, that it
would be notified prior to the pipeline being placed back in service.
• On February 25, 2015, Respondent exposed the pipeline and began repairs. At that time,
an 80% metal loss anomaly was discovered in close proximity to the Failure location on
the same pipeline joint.
• During repair of the failure location, Respondent installed a leak clamp on the newly-
discovered 80% metal loss anomaly.
• On February 26, 2015, Respondent returned the line to service at full operating pressure
without notice to PHMSA, SW, OPS.
• PHMSA, SW, OPS, requested repair records and In-line Inspection (ILI) data from the
Respondent and reviewed them between February 27, 2015, and March 6, 2015.
• According to Respondent’s ILI data, the Affected Segment was inspected in 2006 and
2011 using ILI tools to perform an assessment of the geometry and metal loss conditions
of the pipeline. The next assessment was scheduled for 2016.
• Further review revealed that there was 17% metal loss at the site of the Failure in 2006
and that by 2011 the metal loss had grown to 68%. The corrosion growth rate for this
feature predicted failure prior to Respondent’s next scheduled assessment in 2016.
• The newly-discovered 80% metal loss anomaly was not identified in the 2011
assessment.
• The cause and proliferation of the accelerated metal loss growth rates along the Affected
Segment is unknown at this time.
• Review of Respondent’s repair records revealed that the leak clamp used to repair the
newly-discovered 80% metal loss anomaly was not installed in accordance with the
manufacturer’s specifications and was not an appropriate application with respect to this
type of anomaly.
• Upon subsequent questioning by PHMSA, Respondent chose to take a voluntary 20%
operating pressure reduction and committed to removal of the 80% metal loss anomaly
repair on March 6, 2015.2
2 See Sunoco Logistics Partners L.P. email and attachments, (March 6, 2015).



CPF No. 4-2015-5005H
Page 4
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous, requiring corrective action, is set
forth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
pipeline without corrective measures is or would be hazardous to life, property, or the
environment. Additionally, having considered the nature of the failure; the unexplained
accelerated metal loss growth rates; the existence of at least one immediate repair anomaly not
previously identified; the location of the failure; the proximity to a public roadway and pond; the
age of the pipeline, and the threat of further failures and detrimental environmental impact due to
uncertainty in Respondent’s integrity management processes along this segment, I find that a
failure to issue this Order expeditiously to require immediate corrective action would result in
the likelihood of serious harm to life, property, or the environment.
Accordingly, this Corrective Action Order mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The terms and conditions of this Order are
effective upon receipt.
Within 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited
review either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be
held as soon as practicable under the terms of such regulation, by notifying the Associate
Administrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,
PHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person
in Southwest Region Office or Washington, D.C.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, PHMSA will notify
Respondent of any additional measures that are required and an amended Order issued, if
necessary. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
Pursuant to 49 U.S.C. § 60112, I hereby order West Texas Gulf to immediately take the
following corrective actions for the Affected Segment:



CPF No. 4-2015-5005H
Page 5
Definitions:
“Affected Segment” – The “Affected Segment” means approximately 63 miles of West Texas
Gulf’s 26-inch pipeline designated as the Blum to Wortham segment located in rural East Texas.
“Director” – “Director” means the Director, Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety, Southwest Region, 8701 South Gessner,
Suite 1110, Houston, Texas 77074.
1. Operating Pressure Restriction. Respondent must maintain a twenty percent (20%)
pressure reduction in the actual operating pressure along the Affected Segment such
that the operating pressure on this segment will not exceed eighty percent (80%) of the
actual operating pressure in effect immediately prior to the failure on February 25,
2015.
a. This pressure restriction is to remain in effect until written approval to increase
the pressure or return the pipeline to its pre-failure operating pressure is
obtained from the Director.
b. This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-
pressure devices to be adjusted accordingly.
2. Removal of Pressure Restriction.
a. The Director may allow the removal or modification of the pressure restriction
upon a written request from Respondent demonstrating that restoring the
Affected Segment to its pre-failure operating pressure is justified, based on a
reliable engineering analysis showing that the pressure increase is safe,
considering all known defects, anomalies, and operating parameters of the
pipeline.
3. Mechanical and Metallurgical Testing. Within 30 days of receipt of this Order, West
Texas Gulf must complete mechanical and metallurgical testing and failure analysis of
the failed pipe, including an analysis of water samples and any foreign materials related
to the casing and pipeline failure environment. Complete the testing and analysis as
follows:
a. b. c. Within 10 days of receipt of this Order, develop and submit the testing protocol
and the proposed testing laboratory to the Director for prior approval.
Provide the Director with the scheduled date, time, and location of the testing to
allow for an OPS representative to witness the testing.
Ensure the testing laboratory distributes all reports whether draft or final in their
entirety to the Director at the same time they are made available to Respondent.
4. Root Cause Failure Analysis (RCFA). Within 45 days following receipt of the final
report from the metallurgical testing laboratory, Respondent must submit a Report
summarizing the results of the Root Cause Failure Analysis performed by the
Respondent or its Third Party. The Root Cause Failure Analysis shall include, at a



CPF No. 4-2015-5005H
Page 6
minimum, a structured method to evaluate the causal factors and perform an
investigation of the following management processes and the role they may have had in
the failure:
a. Respondent’s ILI specifications and instructions to its vendors and the timing
and detail of the information provided by the ILI vendor;
b. Respondent’s evaluation of corrosion growth rates, interaction criteria,
evaluation of ILI vendor data, determination of assessment schedules, processes
to confirm assumptions used in determining the assessment schedules (corrosion
growth rates, tool uncertainty, correlation, etc.); and
c. Respondent’s proposed corrective actions, including revisions to its Integrity
Management Plan and Pipeline Repair Procedures, as necessary, to prevent
recurrence of such a failure.
5. Remedial Work Plan.
a. Within 15 days following submittal of the Root Cause Failure Analysis Report,
Respondent must submit a Remedial Work Plan (RWP) to the Director for
approval.
b. The Director may approve the RWP incrementally without approving the entire
RWP.
c. Once approved by the Director, the RWP will be incorporated by reference into
this Order.
d. The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures Respondent will use to verify the integrity of the Affected
Segment. It must address all known or suspected factors and causes of the
February 25, 2015 failure.
e. The RWP must include a procedure or process to:
i. Perform an ILI inspection of the Affected Segment.
ii. Evaluate the results of the ILI inspection using appropriately
conservative interaction criteria and corrosion growth rates to determine
the features to be evaluated by direct examination, and the next
assessment schedule.
iii. Revise procedures, as identified in the RCFA Report, and complete
training of personnel on the revised procedures.
iv. Integrate the results of the metallurgical testing, root cause failure
analysis, and other corrective actions required by this Order with all
relevant pre-existing operational and assessment data for the Affected
Segment.
v. Determine if conditions similar to those contributing to the failure on
February 25, 2015 are likely to exist elsewhere on the West Texas Gulf
Pipeline.
f. Describe the inspection and repair criteria Respondent will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other identified
integrity threats along the Affected Segment. Include a description of how any
defects will be graded and a schedule for repairs or replacement.
g. Respondent shall include a proposed schedule for completion of the activities
included in the RWP.



CPF No. 4-2015-5005H
Page 7
h. Respondent must revise the RWP as necessary to incorporate new information
obtained during the failure investigation and remedial activities, to incorporate
the results of actions undertaken pursuant to this Order, and/or to incorporate
modifications required by the Director.
i. Submit any plan revisions to the Director for prior approval.
j. Respondent shall implement the RWP as it is approved by the Director,
including any revisions to the plan.
6. Monthly Reports to the Director. Respondent shall submit written reports to the
Director, detailing the status of the work associated with this Order, and providing a list
of upcoming work involving live-line welding, tie-ins or other activities that will
involve the submittal of Job Plans to the Director for approval. The first Report will be
due April 15, 2015, and monthly thereafter, on the 15th of each month until such time
that the schedule is adjusted and approved by the Director or this Order is closed.
Other Requirements:
1. Reporting. Submit monthly reports to the Director that: (1) include all available data and
results of the testing and evaluations required by this Order; and (2) describe the progress
of the repairs or other remedial actions being undertaken. The first monthly report is due
on April 15, 2015. The Director may change the interval for the submission of these
reports.
2. Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Order. Include in each
monthly report the to-date total costs associated with: (1) preparation and revision of
procedures, studies and analyses; (2) physical changes to pipeline infrastructure,
including repairs, replacements and other modifications; and (3) environmental
remediation, if applicable.
Approvals. With respect to each submission requiring the approval of the Director, the
Director may: (a) approve the submission in whole or in part; (b) approve the submission
on specified conditions; (c) modify the submission to cure any deficiencies; (d)
disapprove the submission in whole or in part and direct Respondent to modify the
submission; or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission, as approved or modified by the Director. If the Director
disapproves all or any portion of a submission, Respondent must correct all deficiencies
within the time specified by the Director and resubmit it for approval.
4. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Order upon a written request timely submitted and demonstrating
good cause for an extension.
The actions required by this Corrective Action Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Part [195, 193, 192],
3.



CPF No. 4-2015-5005H
Page 8
under any other order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or
under any other provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
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).
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.
§ 60120.
In your correspondence on this matter, please refer to CPF No. 4-2015-5005H and for each
document you submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Corrective Action Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420155005H_Amended Corrective Action Order_09042015_text.pdf

September 4, 2015
Mr. Michael J. Hennigan
President and Chief Executive Officer
Sunoco Logistics Partners L.P.
c/o Mr. David Chalson
4041 Market Street
Aston, PA 19014
Re: CPF No. 4-2015-5005H
Dear Mr. Hennigan:
Enclosed is an Amendment to the Corrective Action Order issued in the above-referenced case
on March 12, 2015. Service by electronic transmission is deemed complete upon transmission
and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms
and conditions of this Order are effective upon completion of service.
Please direct any questions on this matter to Rod Seeley, Director, Southwest Region, Office of
Pipeline Safety, PHMSA at (713) 272-2852.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. R. M. Seeley, Director, Southwest Region, OPS
Mr. David Chalson, Vice President, Operations, Sunoco Logistics Partners, L. P., 4041
Market Street, Aston, PA 19014
Mr. Todd Nardozzi, Compliance Manager, Sunoco Logistics Partners, L. P., Sugar Land,
TX



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
)
)
West Texas Gulf Pipe Line Company, a subsidiary of Sunoco Logistics )
Partners L.P., )
)
Respondent. )
___________________________________ )
) CPF No. 4-2015-5005H
AMENDMENT
TO THE CORRECTIVE ACTION ORDER
Background and Purpose:
On March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a
Corrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas
Gulf or Respondent), a subsidiary of Sunoco Logistics Partners L.P., to take the necessary
corrective actions to protect the public, property, and the environment from potential hazards
associated with Respondent’s West Texas Gulf Pipeline.
1 PHMSA issued the Original CAO in
response to a failure that occurred on February 25, 2015, on the West Texas Gulf Pipeline
System #1, Unit 8514, at mile post (MP) 257 on the Blum to Wortham Segment, resulting in the
release of approximately 50 barrels of crude oil (Failure).
The West Texas Gulf Pipeline is approximately 580 miles in length and transports crude oil from
Colorado City, Texas, to terminals in Longview and Nederland, Texas.
Additional Preliminary Findings:
The preliminary findings in the Original CAO noted the failure and related information on
Respondent’s West Texas Gulf Pipe Line and details about the defect discovered as a result of
the February 25, 2015 failure. Since that time, the following events have occurred:
1 In the Matter of West Texas Gulf Pipe Line Company, Corrective Action Order (CPF No. 4-2015-5005H) dated
March 12, 2015.



CPF No. 4-2015-5005H
Page 2
• On April 8, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty and Compliance Order (NOPV1) to West Texas Gulf Pipe Line for failure to
report a serious accident that was alleged to have occurred on February 19, 2013.2
• On April 27, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty (NOPV2)3 to West Texas Gulf Pipe Line alleging improper pipeline repair
methods and failing to correct a metal loss condition that was known to exist prior to its
failure related to the accident for which the Original CAO was issued.
• On May 8, 2015, West Texas Gulf’s operator, Sunoco Pipeline, L.P. (SPLP), responded
to the NOPV, submitted an accident report for the reportable accident that occurred on
February 19, 2013, submitted a copy of the internal investigation report and stated that
the proposed civil penalties associated with the Probable Violations had been paid via
wire transfer on May 7, 2015.
• On June 7, 2015, a second leak of the same nature as the leak of February 25, 2015 was
reported to PHMSA by the Respondent at a location approximately seven (7) miles
downstream from the original leak for which the Original CAO was issued.
• On June 19, 2015, a major release of crude oil occurred at the Wortham Facility where
more than 3,000 barrels of crude oil leaked from a failed flanged connection on piping
that was installed in 2013 and associated with the project in which the serious accident
occurred.
• On May 28, 2015 and June 23, 2015, two reportable accidents4 occurred at the Sunoco
Pipeline, L. P. Corsicana facility as part of the Permian Express II construction project
which was managed by the same construction manager, and pipeline operator responsible
for projects upon which the West Texas Gulf February 19, 2013 accident and the June 19,
2015 accidents occurred.
The preliminary findings, additional failures and subsequent investigation into the events on the
West Texas Gulf Pipe Line system indicate that potential hazards associated with the operation
of this system remain. PHMSA has communicated its concerns about this pattern of failures
with Respondent since an accident similar to the 2013 accident subject of NOPV1 occurred on
the Respondent’s system in 2009.5
2 In the Matter of West Texas Gulf Pipe Line Company, Notice of Probable Violation and Proposed Civil Penalty
and Compliance Order (CPF No. 4-2015-5009) dated April 8, 2015.
3 In the Matter of West Texas Gulf Pipe Line Company, Notice of Probable Violation and Proposed Civil Penalty
and Compliance Order (CPF No. 4-2015-5012) dated April 27, 2015.
4 Reference OPID 19718, Sunoco Pipeline, L. P., Accident Reports filed on Form 7000-1, Report Numbers
20150230–20542, and 20150266–20613 for accidents occurring on May 28, 2015 and June 23, 2015, respectively.
5 In the Matter of West Texas Gulf Pipe Line Company, Final Order (CPF No. 4-2010-5010) dated August 1, 2012,
and Decision on Petition for Reconsideration (CPF No. 4-2010-5010) dated December 31, 2012.



CPF No. 4-2015-5005H
Page 3
Finding of Hazardous Condition
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, including amendments, after reasonable notice and the opportunity for a hearing,
requiring the operator of a pipeline determined to pose a hazard to take corrective actions to
protect people and the environment. These may include the suspended or restricted use of a
pipeline facility, physical inspection, testing, repair, replacement, or other action, as appropriate.
The basis for making a determination that a pipeline facility is or would be hazardous, requiring
corrective action, is set forth both in the above-referenced statute and 49 C.F.R. § 190.233, a
copy of which is enclosed.
After evaluating all available information regarding the safety of the West Texas Gulf Pipe Line
System, including the foregoing additional preliminary findings, and considering the nature,
circumstances, and gravity surrounding the pattern of accidents, the hazardous nature of the
product transported, the serious nature of the injury that went unreported, and the ongoing
investigation to determine the root cause of the multiple failures reported on Respondent’s
pipeline system, I find that the continued operation of the West Texas Gulf Pipe Line without
additional corrective measures would be hazardous to life, property, and the environment.
Accordingly, PHMSA hereby issues this Amendment to the CAO requiring the additional
actions specified herein be taken to protect life, property, and the environment. The additional
actions set forth in this Amendment to the CAO are in addition to the actions set forth in the
Original CAO and do not suspend or eliminate the requirements of the Original CAO, unless
otherwise specifically provided herein.
Amendments to Required Corrective Action
Pursuant to 49 U.S.C. § 60112 and 49 C.F.R. §190.233, West Texas Gulf Pipe Line, and its
operator Sunoco Pipeline, L. P. are ordered to comply with this Amendment to the CAO and take
the following additional corrective actions with respect to the West Texas Gulf Pipe Line. The
following item is added to the Corrective Action Order:
7. Before the Director, Southwest Region, OPS, approves the return to normal operating
pressure under Item 2 of the Original CAO, Respondent must complete the following:
A. Reinstate the 20% Operating Pressure Restriction ordered in the Original CAO, and
maintain that pressure restriction until the actions in Item 7B of this Amended CAO have
been completed.
B. For the entire West Texas Gulf Pipe Line System, its operation, and the Operating,
Maintenance and Construction policies and procedures under which it operates, including all
aspects for which the regulations in 49 C.F.R. §195 apply to the pipeline system and its
operator, SPLP must: (1) submit, for prior review and approval of the Director, a
comprehensive written plan, including timelines for specific actions to improve the safety
performance of Respondent’s West Texas Gulf Pipe Line System; and (2) hire an
independent third party pipeline expert in safety management systems to review and assess



CPF No. 4-2015-5005H
Page 4
the written plan, which third party expert must oversee the creation, execution and
implementation of the actions identified in the plan, and must provide bi-monthly monitoring
summaries to PHMSA and Respondent concurrently.
Respondent must address any deficiencies or risks identified in the third party’s
assessment, including completing repairs and implementing corrective actions related to
safety culture and safety management processes. The plan must be sufficiently detailed with
specific tasks, milestones and completion dates. At a minimum, the plan must address:
a. Organizational issues, including creation of a Safety Management System
promoting a safety culture that is equivalent to the elements considered essential
in the American Petroleum Institute (API) Recommended Practice (RP) 1173
including:
i. Management Commitment and Leadership
ii. Risk Management
iii. Operational Controls
iv. Incident Investigation, Evaluation and Lessons Learned
v. Safety Assurance and Continuous Improvement
vi. Competence, Training, Qualification and Development
vii. Emergency Preparedness and Response
viii. Documentation and Record Keeping
ix. Stakeholder Engagement
b. Contractor oversight and inspection of construction activities while performing
construction in existing or operating facilities, whether the facilities are owned or
operated by Respondent or other pipeline operators transporting hazardous
materials and subject to the requirements of 49 C.F.R. §195, and the commitment
to ensure adequate resources are provided to maintain safety during construction
activities. Specific attention shall be given to:
ii. iii. i. Adherence to Respondent’s Operations and Maintenance procedures
required by 49 C.F.R. 195 Subpart F,
Operator Qualification regulations in 49 C.F.R.§ 195 Subpart G, and
Drug and Alcohol Post Accident Testing regulations in 49 C.F.R.§199
c. Work Plans and the requirement for preparation of and adherence to a detailed
Work Plan when performing activities for which an existing Operations and
Maintenance procedure does not exist.
d. Any other risk, task, issue, or item that is necessary to promote and sustain the
safety of its pipeline system.
The actions required by this Amendment to the CAO are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under the Original CAO, and under 49
C.F.R. Parts 190, 194, 195 and 199, as applicable, or any other Order issued to Respondent under
authority of 49 U.S.C. § 60101, et seq., or under any other provision of Federal or State law.



CPF No. 4-2015-5005H
Page 5
After receiving and analyzing additional data in the course of this and the subject related
investigations, PHMSA may identify other corrective actions that need to be taken. In that event,
Respondent will be notified of any additional measures required and further amendment of the
CAO will be considered. To the extent consistent with safety, Respondent will be afforded
notice and an opportunity for a hearing prior to the imposition of any additional corrective
measures.
The terms and conditions of this Amended Corrective Action Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

420155005H_Consent Agreement_10032016_text.pdf

U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of )
West Texas Gulf Pipe Line Company, Respondent. )
_
)
)
)
)
) CPF No. 4-2015-5005H
CONSENT AGREEMENT
On March 12, 2015, under the authority of 49 U.S.C. § 60112, the Associate Administrator for
Pipeline Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a
Corrective Action Order (Original CAO) to West Texas Gulf Pipe Line Company (West Texas
Gulf or Respondent), owned and operated by Sunoco Pipeline, LP (SPLP), to take the necessary
corrective actions to protect the public, property, and the environment from potential hazards
associated with Respondent’s West Texas Gulf Pipeline. PHMSA issued the Original CAO in
response to a failure that occurred on February 25, 2015, on the West Texas Gulf Pipeline System
#1, Unit 8514, at mile post (MP) 257 on the Blum-to-Wortham Segment, which resulted in the
release of approximately 30 barrels of crude oil (Failure).
Since that time, there have been additional accidents on the West Texas Gulf Pipeline that have
caused the expansion of PHMSA’s concerns regarding the safety of the West Texas Gulf System.
The following events have occurred:
• On April 8, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty and Compliance Order 4-2015-5009 (NOPV1) to Respondent for failure to report
a serious accident that occurred on February 19, 2013, at its Wortham, Texas Facility
(2013 Failure). Respondent has complied with the terms of the proposed Compliance
Order and paid the proposed penalty, so PHMSA issued a Final Order and closed the case
on November 3, 2015.
• On April 27, 2015, PHMSA issued a Notice of Probable Violation and Proposed Civil
Penalty 4-2015-5012 (NOPV2) to Respondent for certain violations arising out of the
Failure, alleging improper pipeline repair methods and the failure to correct a metal-loss
condition that was known by Respondent to exist prior to the Failure. Respondent paid a
portion of the proposed penalty in that case and is awaiting the issuance of a Final Order.
• On June 7, 2015, West Texas Gulf experienced a second leak on the Affected Segment
involving external metal loss due to corrosion was reported to PHMSA by the Respondent
at a location approximately seven miles downstream from the original leak and nine and



one-half miles upstream of the Wortham, Texas Facility for which the Original CAO was
issued.
• On June 19, 2015, a major release of crude oil occurred at Respondent’s Wortham Facility,
where an estimated 3,300 barrels of crude oil leaked from a failed flanged connection on
piping that was installed in 2013 and associated with the construction/modification project
in which the February 19, 2013 accident occurred.
• On May 28, 2015 and June 23, 2015, two reportable accidents occurred at the SPLP
Corsicana facility as part of the Permian Express II construction project. This project was
managed by the same West Texas Gulf department responsible for projects upon which the
West Texas Gulf February 19, 2013 accident and the June 19, 2015 accidents occurred.
• On November 10, 2015, a failure of a control valve and release of crude oil occurred
while piping associated with the June 19, 2015 release was being replaced. Five people
were transported to the hospital for treatment of crude oil exposure to the face and eyes as
well as bruises and contusions after a relief valve failed when it was improperly
disconnected while under pressure. The accident was a result of improper isolation and
failure to follow instructions for safely de-energizing the valve before its removal.
• Taken together, the accidents described above raised serious concerns to PHMSA about
the overall safety of the West Texas Gulf Pipeline System, the processes by which West
Texas Gulf makes decisions about safety, how different parts of the company 
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