{"operation":"document","citation":"CPF 420165021M","title":"SUNOCO PIPELINE L.P. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-06-02","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.432, 195.573(d), 195.577.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165021m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165021m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165021m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420165021M","body":"Notice of Amendment involving SUNOCO PIPELINE L.P.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.432,  195.573(d),  195.577. The case was opened on 2016-06-02 and is reported as closed as of 2017-02-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420165021M_Closure Letter_02272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165021M/420165021M_Closure%20Letter_02272017.pdf\n\n420165021M_Closure Letter_02272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165021M/420165021M_Closure%20Letter_02272017_text.pdf\n\n420165021M_Notice of Amendment_06022016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165021M/420165021M_Notice%20of%20Amendment_06022016.pdf\n\n420165021M_Notice of Amendment_06022016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165021M/420165021M_Notice%20of%20Amendment_06022016_text.pdf\n\n420165021M_Operator Response to Notice_07112016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165021M/420165021M_Operator%20Response%20to%20Notice_07112016.pdf\n\n420165021M_Closure Letter_02272017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 27, 2017\nMr. David Chalson\nVice President of Operations\nSunoco Pipeline L.P.\n4041 Market Street\nAston, PA 19014\nCPF 4-2016-5021M\nDear Mr. Chalson:\nOn March 2014 to December 2014, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nSunoco Pipeline L.P. procedures for Operations and Maintenance Plan in Sugarland, Texas.\nAs a result of the inspection, Sunoco was issued a Notice of Amendment (NOA) on June 2, 2016,\nwhich proposed amendment of your procedures.\nSunoco submitted its final amended procedures on February 13, 2017. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420165021M_Notice of Amendment_06022016_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 2, 2016\nMr. David Chalson\nVice President of Operations\nSunoco Pipeline L.P.\n4041 Market Street\nAston, PA 19014\nCPF 4-2016-5021M\nDear Mr. Chalson:\nOn March 2014 to December 2014, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nSunoco Pipeline L.P. procedures for Operations and Maintenance, and Integrity Management in\nSugarland, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nSunoco’s plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n\n\n\n§195.432 Inspection of in-service breakout tanks1\n(a) Except for breakout tanks inspected under paragraphs (b) and (c) of this\nsection, each operator shall, at intervals not exceeding 15 months, but at least once\neach calendar year, inspect each in-service breakout tank.\n(b) Each operator must inspect the physical integrity of in-service atmospheric and\nlow-pressure steel aboveground breakout tanks according to API Standard 653\n(incorporated by reference, see § 195.3). However, if structural conditions prevent\naccess to the tank bottom, the bottom integrity may be assessed according to a plan\nincluded in the operations and maintenance manual under § 195.402(c)(3).\n1 Since the time of this inspection, 49 C.F.R. § 195.432 was amended and took effect in March 2015. The current\nregulation is cited below.\n§195.432 Inspection of in-service breakout tanks.\n(a) …\n(b) Each operator must inspect the physical integrity of in-service atmospheric and low-pressure steel above-\nground breakout tanks according to API Std 653 (except section 6.4.3, Alternative Internal Inspection\nInterval) (incorporated by reference, see §195.3). However, if structural conditions prevent access to the\ntank bottom, its integrity may be assessed according to a plan included in the operations and maintenance\nmanual under §195.402(c)(3). The risk-based internal inspection procedures in API Std 653, section 6.4.3\ncannot be used to determine the internal inspection interval.\n(1) Operators who established internal inspection intervals based on risk-based inspection procedures prior\nto March 6, 2015, must re-establish internal inspection intervals based on API Std 653, section 6.4.2\n(incorporated by reference, see §195.3).\n(i) If the internal inspection interval was determined by the prior risk-based inspection procedure using API\nStd 653, section 6.4.3 and the resulting calculation exceeded 20 years, and it has been more than 20 years\nsince an internal inspection was performed, the operator must complete a new internal inspection in\naccordance with §195.432(b)(1) by January 5, 2017.\n(ii) If the internal inspection interval was determined by the prior risk-based inspection procedure using API\nStd 653, section 6.4.3 and the resulting calculation was less than or equal to 20 years, and the time since the\nmost recent internal inspection exceeds the re-established inspection interval in accordance with\n§195.432(b)(1), the operator must complete a new internal inspection by January 5, 2017.\n(iii) If the internal inspection interval was not based upon current engineering and operational information\n(i.e., actual corrosion rate of floor plates, actual remaining thickness of the floor plates, etc.), the operator\nmust complete a new internal inspection by January 5, 2017, and re-establish a new internal inspection\ninterval in accordance with §195.432(b)(1).\n(2) [Reserved]\n(c) Each operator must inspect the physical integrity of in-service steel aboveground breakout tanks built to\nAPI Std 2510 (incorporated by reference, see §195.3) according to section 6 of API Std 510 (incorporated by\nreference, see §195.3).\nSection 195.432 does not allow the use of the procedures set forth in API Standard 653, section 6.4.3, Alternative\nInternal Inspection Interval. Forthcoming inspections of the procedures will be based on the current regulation, cited\nabove.\n2\n\n\n\n(c) Each operator shall inspect the physical integrity of in-service steel aboveground\nbreakout tanks built to API Standard 2510 according to section 6 of API 510.\n(d) The intervals of inspection specified by documents referenced in paragraphs (b)\nand (c) of this section begin on May 3, 1999, or on the operator's last recorded date of\nthe inspection, whichever is earlier.\nSunoco’s DOT 195 Maintenance Manual Subpart F: Operation and Maintenance Section 195.432\nInspection of In-Service Breakout Tanks procedure does not adequately described the time\nintervals for performing out of service internal inspections. Sunoco’s procedure only states the\nout of service inspections shall be determined according to API 653 Section 6.4. Sunoco must\namend their procedure to describe in detail, and specify the time intervals for performing out of\nservice internal inspections and not just state they will follow API 653.\nSunoco’s procedure also does not adequately address §195.432(b) which states if structural\nconditions prevent access to the tank bottom, the bottom integrity may be assessed according to a\nplan included in the operations and maintenance manual under §195.402(c)(3). Sunoco needs to\naddress bottom integrity inspection plan for their tanks that have concrete liners. In the last five\nyears, Sunoco has needed to replace five floors on tanks that had concrete liners due to internal\nand external corrosion on the steel bottoms. This demonstrates tanks with concrete liners are\nsusceptible to internal and external corrosion and need to have internal inspection intervals of 10\nyears.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) (3) see above.\n195.577 What must I do to alleviate interference currents.\n(a) For pipelines exposed to stray currents, you must have a program to identify,\ntest for, and minimize the detrimental effects of such currents.\n(b) You must design and install each impressed current or galvanic anode system to\nminimize any adverse effects on existing adjacent metallic structures.\nSunoco’s 195 Maintenance Manual, Subpart H (Corrosion Control), Section 195.577 (Interference\nCurrents), revised on 10-31-2010 is inadequate that it does not establish a program to identify, test\nfor, and minimize the detrimental effects of stray currents. Sunoco’s 195 Maintenance Manual,\nSubpart H (Corrosion Control), Section 195.577 (Interference Currents), Paragraph SPLP\nRequirement / Process Description (3.b.) states:\n“Unexpected and/or unusual variations in cathodic protection measurements encountered during\nnormal testing will be evaluated to determine whether these test results may be caused by stray\ncurrent interference. SPLP will work through corrosion coordinating committees or by direct\ncontact with area utilities or other pipeline operators to resolve whether interference may be the\n3\n\n\n\ncause of the unexpected and/or unusual test results and to resolve the stray current interference\ncondition, if it exists”.\nAccording to the aforementioned paragraph, Sunoco did not clarify the “Unexpected and/or\nunusual variations in cathodic protection measurements” in their manual. PHMSA notes that there\nmust be a numerical threshold of Unexpected and/or unusual variations in cathodic protection\nmeasurements which triggers Sunoco to determine whether the cathodic protection measurements\nencountered by stray currents or not.\nSunoco must revise its procedure to reflect the numerical value of Unexpected and/or unusual\nvariations in cathodic protection measurements.\n3. 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) (3) see above.\n195.573 What must I do to monitor external corrosion control?\n(c) Breakout tanks. You must inspect each cathodic protection system used to\ncontrol corrosion on the bottom of an aboveground breakout tank to ensure\nthat operation and maintenance of the system are in accordance with API\nRecommended Practice 651. However, this inspection is not required if you\nnote in the corrosion control procedures established under § 195.402(c)(3) why\ncompliance with all or certain operation and maintenance provisions of API\nRecommended Practice 651 is not necessary for the safety of the tank.\nSunoco’s 195 Maintenance Manual, Subpart H Corrosion Control, Section 195.573 Monitoring\nExternal Corrosion Control, is inadequate and lacks detail to inspect each cathodic protection\nsystem used to control corrosion on the bottom of an aboveground breakout tank to ensure that\noperation and maintenance of the system are in accordance with API Recommended Practice 651.\nThe procedure also references the regulation and API 651 but does not give details and guidance\non inspecting and monitoring cathodic protection for breakout tanks.\nSunoco must revise its procedure to give better details and guidance on cathodic protection control\nfor breakout tanks.\n4\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in\nyour amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Sunoco L.P. maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to R. M. Seeley, Director, Southwest Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 4-2016-5021M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5","truncated":false,"body_characters":13931}