WEST TEXAS GULF PIPELINE CO — Corrective Action Order

420155005H_Corrective Action Order_03122015_text.pdf, page 1Official PDFMarch 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.#

420155005H_Corrective Action Order_03122015_text.pdf, page 2U.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#

420155005H_Corrective Action Order_03122015_text.pdf, page 3CPF 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).#

420155005H_Corrective Action Order_03122015_text.pdf, page 4CPF 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).#

420155005H_Corrective Action Order_03122015_text.pdf, page 5CPF 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:#

420155005H_Corrective Action Order_03122015_text.pdf, page 6CPF 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#

420155005H_Corrective Action Order_03122015_text.pdf, page 7CPF 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.#

420155005H_Corrective Action Order_03122015_text.pdf, page 8CPF 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.#

420155005H_Corrective Action Order_03122015_text.pdf, page 9CPF 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, page 1Official PDFSeptember 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#

420155005H_Amended Corrective Action Order_09042015_text.pdf, page 2U.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.#

420155005H_Amended Corrective Action Order_09042015_text.pdf, page 3CPF 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.#

420155005H_Amended Corrective Action Order_09042015_text.pdf, page 4CPF 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#

420155005H_Amended Corrective Action Order_09042015_text.pdf, page 5CPF 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.#

420155005H_Amended Corrective Action Order_09042015_text.pdf, page 6CPF 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, page 1Official PDFU.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#

420155005H_Consent Agreement_10032016_text.pdf, page 2one-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 discuss and learn from past mistakes, and whether there are sufficient measures in place for the company to have an effective safety culture. • On September 4, 2015, PHMSA issued an Amendment to the Original CAO (Amended CAO), with preliminary findings describing the events that had occurred since the Original CAO was issued in February 2015, and ordering West Texas Gulf to prepare a comprehensive written plan to improve the safety performance of the Affected Segment to hire an independent third party to review and oversee implementation of the plan, and other corrective actions. • West Texas Gulf has filed the required monthly reports regarding the actions taken to address the issues in the CAO. The most recent report, dated April 15, 2016, indicates the pipeline has returned to service and is limited to the 80% operating pressure based on approvals provided by PHMSA. The West Texas Gulf Pipe Line System is approximately 580 miles in length and transports crude oil from Colorado City, Texas, to terminals in Longview and Nederland, Texas. Respondent requested a hearing, but PHMSA and Respondent agreed that settlement of this proceeding will avoid further administrative proceedings or litigation of this Notice and that entry into this Consent Agreement is the most appropriate means of resolving issues raised in the Amended CAO and in the public interest. Therefore, pursuant to 49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and agreement of Respondent and the PHMSA (the Parties), the Parties agree as follows:#

420155005H_Consent Agreement_10032016_text.pdf, page 3I. General Provisions 1. Respondent acknowledges that its pipeline system is subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative orders issued thereunder. For purposes of this Consent Agreement, Respondent acknowledges that it received proper notice of PHMSA's action in this proceeding and that the Amended CAO states claims upon which relief may be granted pursuant to 49 U.S.C. 60101, et seq., and the regulations and orders issued thereunder. 2. Respondent agrees to take the actions specified in Section II of this Agreement (Corrective Measures) and to abide by the terms of this Consent Agreement. These actions, including any work plans and schedules, shall automatically be incorporated into this Consent Agreement. This Consent Agreement does not constitute a finding of violation of any Federal law or regulation and may not be used in any civil or administrative proceeding of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this Consent Agreement. 3. After Respondent returns this signed Agreement, the PHMSA's representative will present it to the Associate Administrator for Pipeline Safety recommending that the Associate Administrator adopt the terms of this Agreement and Order. The terms of this Agreement and Order constitute an offer of settlement until accepted by the Associate Administrator. 4. Respondent consents to the issuance of a Consent Agreement and Order, and hereby waives any further procedural requirements with respect to its issuance. Respondent waives all rights to contest the adequacy of notice, or the validity of the Consent Agreement and Order, including all rights to administrative or judicial hearings or appeals. Upon issuance of a Consent Agreement and Order for this matter, Respondent’s Request for Hearing will be deemed withdrawn. The Original CAO will continue in full force and effect according to its terms, and the Amended CAO will be deemed withdrawn upon issuance of a Consent Agreement and Order. 5. This Consent Agreement and Order shall apply to and be binding upon the PHMSA, and upon Respondent, its officers, directors, and employees, and its successors, assigns, or other entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Consent Agreement and Order and any incorporated work plans and schedules to all of Respondent's officers, employees, and agents whose duties might reasonably include compliance with this Consent Agreement and Order. 6. For all transfers of ownership or operating responsibility of Respondent’s pipeline, Respondent shall provide a copy of this Consent Agreement and Order to the prospective transferee at least 30 days prior to such transfer and simultaneously provide written notice of the prospective transfer to the PHMSA Region Director (Director) who issued the Notice. 7. This Consent Agreement and Order constitutes the final, complete and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Consent Agreement. The Parties acknowledge that there are no representations, agreements or#

420155005H_Consent Agreement_10032016_text.pdf, page 4understandings relating to the settlement other than those expressly contained in this Consent Agreement and Order, except that the terms of this Consent Agreement and Order may be construed by reference to the original Corrective Action Order. 8. Nothing in this Consent Agreement and Order affects or relieves Respondent of its responsibility to comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. Nothing in this Consent Agreement and Order alters PHMSA's right of access, entry, inspection, and information gathering or the PHMSA's authority to bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal or State law. 9. This Consent Agreement and Order does not waive or modify any Federal, State, or local laws or regulations that are applicable to Respondent's pipeline systems. This Consent Agreement and Order is not a permit, or a modification of any permit, under any Federal, State, or local laws or regulations. Respondent remains responsible for achieving and maintaining compliance with all applicable Federal, State, and local laws, regulations and permits. 10. This Consent Agreement and Order does not create rights in, or grant any cause of action to, any third party not party to this Consent Agreement and Order. The U.S. Department of Transportation is not liable for any injuries or damages to persons or property arising from acts or omissions of Respondent or its officers, employees, or agents carrying out the work required by this Consent Agreement and Order. Respondent agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents, and representatives from any and all causes of action arising from any acts or omissions of Respondent or its contractors in carrying out any work required by this Consent Agreement and Order. II. Corrective Measures 11. Upon issuance of the Consent Agreement and Order, Respondent agrees to perform the Corrective Measures set forth below. 12. Regarding 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, Respondent must: (1) submit, for prior review and approval of the Director, a comprehensive written plan, including timelines for specific actions to improve the safety record of Respondent’s West Texas Gulf Pipe Line System; and (2) hire an independent third-party pipeline expert in safety management systems (SMS) to review and assess 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. The specific role of the third-party SMS consultant is to review the creation, execution#

420155005H_Consent Agreement_10032016_text.pdf, page 5and implementation of the SMS, by performing a gap analysis, recommending improvements, observing the phases of implementation, providing consultation, and communicating via written reports concurrently to PHMSA and Respondent. 13. Respondent must address any deficiencies or risks identified in the third party’s assessment, including modifying repair procedures and implementing corrective actions related to safety culture and safety management processes. If PHMSA disapproves of Respondent’s rationale for deferment, the agency must provide written notice to Respondent in accordance with Section III below. The plan must be sufficiently detailed with specific tasks, milestones and completion dates. At a minimum, the plan must address: (1) 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; (2) 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: i. ii. iii. 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; (3) Work planning process and requirements to define the appropriate level of preparation, review, and approval to ensure safe performance of activities if the scope of work is not in an existing O&M procedure; (4) Any other task, issue, or item that is necessary to promote and sustain the safety of the West Texas Gulf Pipe Line System. 14. The actions required by this Consent Agreement 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#

420155005H_Consent Agreement_10032016_text.pdf, page 6Federal or State law. 15. Consent Order Documentation Report (CODR). Respondent must create and submit on a quarterly basis, a CODR. The intent is for the CODR to summarize all activities and documentation associated with the Consent Order and to identify any activities or documentation for the period reflected in previous report activities so the status of each item in the Consent Order is reflected in each report. When the Respondent has concluded all of the required items in the Consent Order, it will submit a final CODR to the Director. This will allow the Director to complete a thorough review of all actions taken by the Respondent with regards to the Consent Order prior to approving the closure of the Consent Order. 16. It is requested that Respondent maintain documentation of the costs associated with implementation of this Agreement, and include in each report submitted pursuant to Item 15, 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. 17. The Director may grant an extension of time for compliance with any of the terms of the Consent Order upon a written request, timely submitted, demonstrating good cause for an extension. 18. For all submissions based upon this Consent Agreement that requires the approval of the Director, the Director may (a) approve the submission in whole or in part; (b) impose specific conditions; (c) modify the submission to cure any deficiencies; (d) reject the submission in whole or in part; or (e) any combination of the above. 19. Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator are final. III. Review and Approval Process 20. With respect to any submission under Section II of this Consent Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or in part, the submission, (b) approve the submission on specified conditions, (c) disapprove, in whole or in part, the submission, or (d) any combination of the foregoing. If the Director approves, approves in part, or approves with conditions, Respondent will take all action as approved by the Director, subject to Respondent's right to invoke the dispute resolution procedures in Section IV with respect to any conditions the Director identifies. If the Director disapproves all or any portion of the submission, the Director will provide Respondent with a written notice of the deficiencies. Respondent will correct all deficiencies within the time specified by the Director and resubmit it for approval. IV. Dispute Resolution 21. The Director and Respondent will informally attempt to resolve any disputes arising under this Consent Agreement. If Respondent and the Director are unable to informally resolve the dispute within 15 days, Respondent may request in writing, within 10 days, a written determination resolving the dispute from the Associate Administrator for Pipeline Safety providing#

420155005H_Consent Agreement_10032016_text.pdf, page 7all information that Respondent believes is relevant to the dispute. If the request is submitted as provided herein, the Associate Administrator will issue a final determination in writing. The existence of a dispute and the PHMSA's consideration of matters placed in dispute will not excuse, toll, or suspend any term or timeframe for completion of any work to be performed under this Agreement during the pendency of the dispute resolution process except as agreed by the Director or the Associate Administrator in writing. V. Enforcement 22. This Consent Agreement and Order is subject to all enforcement authorities available to the PHMSA under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190. All work plans and associated schedules set forth or referenced in Section II will be automatically incorporated into this Consent Agreement and are enforceable in the same manner. VI. Recordkeeping and Information Disclosure 23. Unless otherwise required in this Consent Agreement, Respondent agrees to maintain records demonstrating compliance with all requirements of this Consent Agreement for a period of at least five years following completion of all work to be performed. For any reports, plans, or other deliverables required to be submitted to the PHMSA pursuant to this Consent Agreement, Respondent may assert a claim of business confidentiality or other protections applicable to the release of information by the PHMSA, covering part or all of the information required to be submitted to the PHMSA pursuant to this agreement in accordance with 49 C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each page, and include a statement specifying the grounds for each claim of confidentially. The PHMSA determines release of any information submitted pursuant to this Consent Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and/or the PHMSA policies, and other applicable regulations and Executive Orders. VII. Effective Date 24. The “Effective Date” as used herein is the date on which the Consent Order is issued by the Associate Administrator incorporating the terms of this Agreement. Unless specified to the contrary, all deadlines for actions required by this Consent Agreement run from the Effective Date of the Consent Order. VIII. Modification 25. The terms of this Consent Agreement may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both parties. IX. Termination 26. This Consent Agreement terminates upon completion of all terms set forth in Section II (Corrective Measures) as determined by the Director, Southwest Region. Respondent may request written confirmation from the PHMSA when this Consent Agreement is terminated.#

420155005H_Consent Agreement_10032016_text.pdf, page 8To the extent ongoing monitoring is required, PHMSA may terminate this Consent Agreement with respect to all other requirements with the exception of such monitoring. Nothing in this Consent Agreement prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement. X. Ratification 27. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Consent Agreement and to execute and legally bind such party to this document. 28. The Parties hereby agree to all conditions and terms of this Consent Agreement: [SIGNATURES ON NEXT PAGE]#

420155005H_Consent Agreement_10032016_text.pdf, page 9For Respondent: __________________________ NAME ADDRESS WEST TEXAS GULF ______________________ Date For PHMSA: _________________________ Rodrick Seeley Director, Office of Pipeline Safety PHMSA Southwest Region U.S. Department of Transportation _________________________ Date#

420155005H_Consent Order_03242017_text.pdf, page 1Official PDFMarch 24, 2017 Mr. Michael J. Hennigan President and CEO Sunoco Logistics Partners, LP 3807 West Chester Pike Newtown Square, PA 19073 Re: CPF No. 4-2015-5005H Dear Mr. Hennigan: Enclosed please find the Consent Order issued in the above-referenced case, incorporating the terms of the Consent Agreement signed by the Southwest Region Director, PHMSA, and your subsidiary, West Texas Gulf Pipe Line Company, on September 29, 2016. Service of the Consent Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Mr. Rodrick Seeley, Director, Southwest Region, PHMSA Mr. Mike Prince, President, West Texas Gulf Pipe Line Company CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420155005H_Consent Order_03242017_text.pdf, page 2U.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, ) CPF No. 4-2015-5005H ) Respondent. ) ____________________________________) CONSENT ORDER 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), which is 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. The West Texas Gulf Pipe Line System is approximately 580 miles in length and transports crude oil from Colorado City, Texas, to terminals in Longview and Nederland, Texas. Since that time, additional accidents on the West Texas Gulf Pipeline have heightened PHMSA’s concerns regarding the safety of the West Texas Gulf System as a whole. On September 4, 2015, PHMSA issued an Amendment to the Original CAO (Amended CAO), that included preliminary findings describing the events that had occurred since the issuance of the Original CAO and that ordered West Texas Gulf to complete additional remedial actions. On September 14, 2015, SPLP responded to the Amended CAO on behalf of West Texas Gulf, contesting the Amended CAO and requesting a hearing. Since that time, however, PHMSA and Respondent have held discussions and agreed that settlement of this proceeding would serve to avoid further administrative proceedings or litigation regarding the Amended CAO, that entry of ratification of the attached Consent Agreement would be the most appropriate means of resolving the issues raised in the Amended CAO, and that settlement would best serve the public interest. Accordingly, the foregoing Consent Agreement, dated October 3, 2016, is hereby attached hereto and incorporated by reference into this Consent Order. Respondent is ordered to comply with the terms of the Consent Agreement, effective immediately.#

420155005H_Consent Order_03242017_text.pdf, page 3CPF No. 4-2015-5005H Page 2 Pursuant to 49 U.S.C. 60101 et seq. and 49 C.F.R § 190.221, failure to comply with this Consent Order may result in the assessment of civil penalties, or in the referral of the case for judicial enforcement. The terms and conditions of this Consent Order are effective upon service in accordance with 49 C.F.R. § 190.5. March 24, 2017 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420155005H_Closure Letter_02122020_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED February 12, 2020 Greg McIlwain Senior Vice President, Operations West Texas Gulf Pipeline Company 1300 Main Street Houston, Texas 77002 CPF 4-2015-5005H Dear Mr. McIlwain: On March 12, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to West Texas Gulf Pipeline Company (WTG) a Corrective Action Order (CAO). The CAO required WTG develop a restart plan, effect a pressure restriction on the affected segment, develop an integrity verification and remediation plan for the pipeline system, and implement mitigative actions necessary for the safe operation of the pipeline. An amendment to the CAO issued by PHMSA on September 4, 2015 reinstated an operating pressure restriction and directed WTG to complete additional remedial actions. The resulting Consent Order (CO), issued March 24, 2017, included requirements to apply corrective measures to improve the safety record of WTG. WTG has completed all requirements of the CAO and CO. This letter is to inform you that no further action is contemplated with respect to the matters involved in this case, and this case is now closed. Thank you for your cooperation. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#