{"operation":"document","citation":"CPF 420165030H","title":"SUNOCO PIPELINE L.P. — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2016-09-14","effective_on":null,"summary":"OPEN corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165030h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165030h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165030h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420165030H","body":"Corrective Action Order involving SUNOCO PIPELINE L.P.. The dataset does not identify a cited regulation for this case. The case was opened on 2016-09-14 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420165030H_Corrective Action Order_09142016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165030H/420165030H_Corrective%20Action%20Order_09142016.pdf\n\n420165030H_Corrective Action Order_09142016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165030H/420165030H_Corrective%20Action%20Order_09142016_text.pdf\n\n420165030H_Corrective Action Order_09142016_text.pdf\n\nSeptember 14, 2016\nMr. Michael J. Hennigan\nPresident and Chief Executive Officer\nSunoco Logistics Partners L.P.F\n1818 Market Street, Suite 1500\nPhiladelphia, Pennsylvania 19103\nRe: CPF No. 4-2016-5030H\nDear Mr. Hennigan:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires Sunoco\nPipeline Company, LP, to take certain corrective actions with respect to the Permian Express II\nPipeline that failed on September 10, 2016, near Sweetwater, Texas. Service is being made by\ncertified mail and facsimile. Service of the Corrective Action Order by electronic transmission is\ndeemed complete upon transmission and acknowledgement of receipt, or as otherwise provided\nunder 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion\nof service.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Acting Deputy Associate Administrator for Field Operations, OPS\nMr. Rodrick Seeley, Regional Director, Southwest Region, OPS\nVIA CERTIFIED MAIL AND FAX\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nSunoco Logistics Partners, LP, ) CPF No. 4-2016-5030H\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C. § 60112,\nto require Sunoco Logistics Partners, LP (Sunoco or Respondent), to take the necessary\ncorrective action to protect the public, property, and environment from potential hazards\nassociated with the recent failure on Sunoco’s Permian Express II crude oil pipeline.1\nOn September 10, 2016, a reportable accident occurred on the Permian Express II pipeline,\nresulting in the release of approximately 800 barrels of crude oil (the Failure). The Permian\nExpress II Pipeline is a 24-inch diameter crude oil pipeline that runs from Colorado City, Texas\nto Corsicana, Texas, a total of 279 miles (Permian Express II). The cause of the Failure has not\nyet been determined. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of\nthe accident. The preliminary findings of the ongoing investigation are as follows.\n1 Sunoco is a master limited partnership that owns and operates a broad portfolio of crude oil, natural gas liquids,\nand refined products pipeline, terminalling and acquisition assets. Sunoco operates approximately 5,900 miles of\ncrude oil pipelines, approximately 900 miles of natural gas pipelines and approximately 14 million barrels of refined\nproducts storage capacity. See http://www.sunocologistics.com/Customers/Business-Lines/252/ (current as of\n9/12/2016).\n\n\n\nPreliminary Findings:\n The Permian Express II Pipeline is a 24-inch diameter crude oil pipeline that runs from\nColorado City, Texas to Corsicana, Texas, a total of 279 miles (Affected Segment). The\nFailure occurred near milepost 30.2, approximately 1.8 miles southeast of Sweetwater, Texas\n(Failure Site).\n The Affected Segment was manufactured in 2014, is 24-inches in nominal diameter, Grade\nX-65, and has .406 inch wall thickness. The pipe is coated in Fusion bonded epoxy coating\n(FBE), has an Electric Resistance Welded (ERW) seam, and was manufactured by Stupp\nBrothers. The Permian Express II pipeline was constructed in 2014-2015, and transports\nWest Texas Intermediate crude oil from west to east, ending at the Corsicana station. The\nFailure occurred at mile post 30.2 in rural Nolan County, Texas. The area where the leak\noccurred is a low spot and product is draining from the pipeline (gravity) for the 12.2 mile\nisolated section. Sunoco closed the block valve at milepost 21.8 west of Sweetwater, as well\nas the block valve at milepost 34, near Lake Sweetwater.\n The maximum operating pressure (MOP) of the Permian Express II pipeline is 1480 psig, as\nestablished by hydrostatic test in 2015. At the time of the Failure, the actual operating\npressure of the pipeline was 1060 psig.\n Beginning August 30, 2016, the Sunoco Control Center identified meter imbalances on the\nControl Center Over/Short Report and began investigating the imbalances. The results of the\ninvestigation did not indicate a release occurred until September 10, 2016, the time of the last\nstatic pressure test and land patrol. On September 10, 2016, at 5:15 p.m. (CST), Sunoco’s\nfield personnel confirmed a failure on the affected segment, and the release of an estimated\n800 barrels of crude oil. The failure happened in a remote location. There were no reported\ninjuries, fatalities, or ignition of the product. Additionally, there were no affected water ways\nor other environmental concerns reported. The Failure was reported to the National Response\nCenter (NRC Report No. 981503) on September 10, 2016, at approximately 7:15 PM CST.\n The initial indication of a possible leak occurred on August 30, 2016 at approximately 10:00\nPM CST. At that time, the discharge pressure from the Colorado City pump station was\n1127 psig, with the estimated pressure at the leak site of 1060 psig. While field personnel\nwere responding to the site on September 10, 2016, the pipeline control center isolated the\nsuspected leak area by closing the valve at milepost 21.8 downstream of Colorado City, as\nwell as the Eastland mainline valve at milepost 34, near Lake Sweetwater.\n The estimated volume of product released was initially reported as 800 barrels based on a\n120 by 70 feet area. The revised area was considered at a 70 by 20 foot area. The on-site\npersonnel continued the on-ground assessment of the extent of the release. The Oil Spill\nResponse Organization (OSRO) was contacted by the operator on September 10, 2016.\n There was no federal or local emergency response. The Railroad Commission of Texas was\nonsite for a limited time on September 11, 2016.\n\n\n\n The cause of the Failure is unknown at this time, and an investigation is ongoing. Excavation\nof the site is limited to product removal due to safety and environmental concerns.\n The Permian Express II line began operation in June 2015, and there have been no significant\nprevious failures on this pipeline. During a PHMSA construction inspection, however,\nPHMSA identified issues regarding the welding of the pipe, and there is an open NOPV,\nissued by the Southwest Region, related to this construction project (CPF No. 4-2016-5011).\nWhile a visual examination of the pipe has not been completed, the initial observation\nappears to show the leak site is in the vicinity of a girth weld.\n The crude oil released visually appears to be contained within a 70 by 20 area. The operator\nhas vacuum trucks available to remove product as soon as it is drained from the pipe, and is\nmonitoring the Affected Segment. While the Failure is not in a high consequence area\n(HCA), the area is considered a “could affect” area with regard to the Drinking Water\nUnusually Sensitive Areas (USAs)2 criteria. Continued operation of the pipeline poses\npotential risks to municipal drinking water intakes along the pipeline route. The route is\nrelatively rural, but other populated areas could be affected along the pipeline route, and\ncontinued operation of the pipeline poses a risk to the environment. The Permian Express II\nline runs 279.5 total miles, 93.2 miles of which are in an HCA.\n While metallurgical testing of the failed pipe has not yet been completed, the Permian\nExpress II pipeline will need additional integrity verification to ensure continued safe\noperation of the pipeline.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, having considered the uncertainties as to the cause of the failure; the\nlocation of the Failure; the proximity of the pipeline to populated areas, public water intake\n2 Drinking Water USAs are used by pipeline operators in formulating their Integrity Management plans, and are part\nof PHMSA’s National Pipeline Mapping System. (See https://www npms.phmsa.dot.gov/USADWData.aspx).\n\n\n\nsystems, or other high consequence areas; the young age of the pipeline and the history of known\nproblems or failures on this pipeline, including during construction of the line, I find that a\nfailure to issue this Order expeditiously to require immediate corrective action would result in\nthe likelihood of serious harm to life, property, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southwest Region,\nPHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person\nin Southwest Region office or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nThe “Affected Segment” means approximately 279.5 miles of the Permian Express II pipeline\nfrom the Colorado City Pump Station to the Corsicana Delivery Station.\nThe “Isolated Segment” means approximately 12.2 mile segment from milepost (MP) 21.8 west\nof Sweetwater, Texas to MP 34 near Lake Sweetwater.\nPursuant to 49 U.S.C. § 60112, I hereby order Sunoco to immediately take the following\ncorrective actions for the Affected Segment and Isolated Segment:\n1. Operating Restriction. Respondent must not operate the Isolated Segment until\nauthorized in writing to do so by the Director pursuant to Item 4.\n2. Operating Pressure Restriction. Respondent must maintain a twenty percent (20%)\npressure reduction in the actual operating pressure of the Affected Segment such that the\noperating pressure on this segment will not exceed eighty percent (80%) of the actual operating\npressure in effect immediately prior to the Failure.\na. This pressure restriction must remain in effect until the Respondent obtains written\napproval from the Director to increase the pressure or return the pipeline to its pre-failure\noperating pressure.\nb. This pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\n\n\n\nadjusted accordingly.\n3. Restart Plan. Prior to resuming operation of the Isolated Segment, the Respondent must\ndevelop and submit a written Restart Plan to the Director for approval.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan, but the Isolated Segment cannot resume operation until the Restart Plan is approved\nin its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nc. d. e. f. g. h. The Restart Plan must provide for adequate patrolling of the Affected and Isolated\nSegments during the restart process and must include incremental pressure increases\nduring start up, with each increment to be held for at least one hour.\nThe Restart Plan must include sufficient surveillance of the pipeline during each pressure\nincrement to ensure that no leaks are present when operation of the line resumes.\nThe Restart Plan must specify a day-light restart and include advance communications\nwith local emergency response officials.\nThe Restart Plan must provide for a review of the Isolated and Affected Segments for\nconditions similar to those of the Failure, including a review of construction, operating\nand maintenance (O&M) and integrity management records, such as in-line inspection\n(ILI) results, hydrostatic tests, root cause failure analysis of prior failures, aerial and\nground patrols, corrosion, cathodic protection, excavations and pipe replacements. The\noperator must address any findings that require remedial measures to be implemented\nprior to restart.\nThe Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications are\nincorporated into Sunoco’s operations and maintenance procedures manual.\nThe Restart Plan must provide for hydrostatic pressure testing of the Affected Segment.\n4. Return to Service. After the Director approves the Restart Plan, Respondent may return\nthe Isolated Segment to service, but the operating pressure must not exceed eighty percent (80%)\nof the actual operating pressure in effect immediately prior to the Failure, in accordance with\nItem 2 above.\n5. Removal of Pressure Restriction. The Director may allow the removal or modification of\nthe pressure restrictions upon a written request from Respondent demonstrating that restoring the\npipeline to its pre-failure operating pressure is justified based on a reliable engineering analysis\nshowing that the pressure increase is safe considering all known defects, anomalies, and\noperating parameters of the pipeline. The Director may also consider a demonstration that\ntemporary mitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director’s determination will\nbe based on the cause of the Failure and evidence of the analyses and measures taken, discussed\nabove.\n\n\n\na. Appeals to determinations of the Director in this regard will be decided by the Associate\nAdministrator for Pipeline Safety.\n6. Mechanical and Metallurgical Testing. Within 45 days of receipt of this Order, Sunoco\nmust complete mechanical and metallurgical testing and failure analysis of the failed pipe,\nincluding an analysis of soil samples and any foreign materials. Testing and analysis\nrequirements are as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the failure site.\nb. c. d. Within 10 days of receipt of this Order, develop and submit the testing protocol and the\nproposed testing laboratory to the Director for prior approval.\nPrior to beginning the mechanical and metallurgical testing, provide the Director with the\nscheduled date, time, and location of the testing to allow for an OPS representative to\nwitness the testing.\nEnsure the testing laboratory distributes all reports whether draft or final in their entirety\nto the Director at the same time they are made available to Respondent.\n7. Root Cause Failure Analysis. Within 90 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director. The\nRCFA must be supplemented/facilitated by an independent third-party acceptable to the Director\nand must document the decision making process and all factors contributing to the failure. The\nfinal report must include findings and lessons learned. The RCFA must also include a discussion\nof whether the findings and lessons learned are applicable to other locations within Sunoco’s\npipeline system.\n8. Remedial Work Plan. Within 45 days following receipt of the final report from the\nmetallurgical testing laboratory, Respondent must submit a Remedial Work Plan (RWP) to the\nDirector for approval. The Director may approve the RWP incrementally without approving the\nentire RWP. Once approved by the Director, the RWP will be incorporated by reference in this\nOrder.\na. b. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures Respondent will use to verify the integrity of the Affected Segment. It must\naddress all known or suspected factors and causes of the Failure. Respondent should\nconsider both the risk of another failure and the consequence of another failure to develop\na prioritized schedule for RWP related work along the Affected Segment.\nThe RWP must include a procedure or process to:\ni. Gather all data necessary to review the failure history (in service and pressure test\nfailures) of the Affected Segment and to prepare a written summary containing all the\navailable information such as the locations, dates, and causes of leaks and failures.\nii. Integrate the results of the metallurgical testing, root cause failure analysis, and other\ncorrective actions required by this Order with all relevant pre-existing operational and\n\n\n\nc. d. e. f. iii. iv. assessment data for the Affected Segment. Pre-existing operational data includes, but\nis not limited to, construction, operations, maintenance, testing, repairs, prior\nmetallurgical analyses, and any third party consultation information. Pre-existing\nassessment data includes, but is not limited to, in-line inspection (ILI) tool runs,\nhydrostatic pressure testing, direct assessments, close interval surveys, and\nDCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the Failure are likely to exist\nelsewhere on the Affected Segment.\nConduct additional field tests, inspections, assessments, and/or evaluations to\ndetermine whether, and to what extent, the conditions associated with the Failure, and\nother failures from the failure history (see (8)(b)(ii) above), or any other integrity\nthreats are present elsewhere on the Affected Segment.\n3 At a minimum, this process\nmust consider all failure causes and specify the use of one or more of the following:\n1. Inline inspection (ILI) tools that are technically appropriate for assessing the\npipeline system based on the cause of the Failure and that can reliably detect and\nidentify anomalies,\n2. Hydrostatic pressure testing,\n3. Close-interval surveys,\n4. Cathodic protection surveys, to include interference surveys in coordination with\nother utilities (e.g. underground utilities, overhead power lines, etc.) in the area,\n5. Coating surveys,\n6. Stress corrosion cracking surveys,\n7. Selective seam corrosion surveys; and,\n8. Other tests, inspections, assessments, and evaluations appropriate for the failure\ncauses.\nDescribe the inspection and repair criteria Respondent will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity threats.\nInclude a description of how any defects will be graded and a schedule for repairs or\nreplacement.\nBased on the known history and condition of the Affected Segment, describe the methods\nRespondent will use to repair, replace, or take other corrective measures to remediate the\nconditions associated with the Failure, and to address other known integrity threats along\nthe Affected Segment.\nImplement continuing long-term periodic testing and integrity verification measures to\nensure the ongoing safe operation of the Affected Segment considering the results of the\nanalyses, inspections, evaluations, and corrective measures undertaken pursuant to the\nOrder.\nInclude a proposed schedule for completion of the RWP.\n3 Respondent may use the results of previous tests, inspections, assessments, and evaluations if approved by the\nDirector, provided the results of the tests, inspections, assessments, and evaluations are analyzed with regard to the\nfactors known or suspected to have caused the September 10, 2016 failure.\n\n\n\ng. h. i. j. Respondent must revise the RWP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of\nactions undertaken pursuant to this Order, and/or to incorporate modifications required by\nthe Director.\nSubmit any plan revisions to the Director for prior approval.\nThe Director may approve plan revisions incrementally.\nSunoco must implement the RWP as it is approved by the Director, including any\nrevisions to the plan.\n9. CAO Documentation Report. Sunoco must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Sunoco has completed all the items in this Order, it will\nsubmit the final CDR in its entirety to the Director. This will allow the Director to complete a\nthorough review of all actions taken by Sunoco with regards to this Order prior to approving the\nclosure of this Order. The intent is for the CDR to summarize all activities and documentation\nassociated with this Order in one document.\na. b. The Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nc. The CDR must include but not be limited to:\ni. Table of Contents;\nii. iii. iv. Summary of the Failure and the response activities;\nSummary of pipe data/properties and all prior assessments of the Affected Segment;\nSummary of all tests, inspections, assessments, evaluations, and analysis required by\nthe Order;\nv. vi. vii. Summary of the mechanical and metallurgical testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by Sunoco to implement the RWP, the results of\nthose actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to incorporate\nthe results of actions undertaken pursuant to this Order and whenever necessary to\nincorporate new information obtained during the failure investigation and remedial\nactivities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions Sunoco will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and Appendices (if\nrequired).\n\n\n\n10. Reporting. Submit monthly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress of the\nrepairs or other remedial actions being undertaken. The first quarterly report is due on\nDecember 31, 2016. The Director may change the interval for the submission of these reports.\n11. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure, including\nrepairs, replacements and other modifications; and (3) environmental remediation, if applicable.\n12. Approvals. With respect to each submission requiring the approval of the Director, the\nDirector may: (a) approve the submission in whole or in part; (b) approve the submission on\nspecified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove the\nsubmission in whole or in part and direct Respondent to modify the submission; or (e) any\ncombination of the above. In the event of approval, approval upon conditions, or modification\nby the Director, Respondent shall proceed to take all action required by the submission, as\napproved or modified by the Director. If the Director disapproves all or any portion of a\nsubmission, Respondent must correct all deficiencies within the time specified by the Director\nand resubmit it for approval.\n13. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted and demonstrating good\ncause for an extension.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any\nother order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or under any\nother provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 4-2016-5030H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\n\n\n\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n______________________________ _____________________________________\nAlan K. Mayberry Date Issued\nActing Associate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":27484}