# SINCLAIR TRANSPORTATION COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 42024055NOA
- **title:** SINCLAIR TRANSPORTATION COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-12-03
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.402(c)(3), 195.417(a), 195.419(a), 195.420(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024055noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024055noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024055noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024055NOA
**body:**

Notice of Amendment involving SINCLAIR TRANSPORTATION COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.417(a),  195.419(a),  195.420(a). The case was opened on 2024-12-03 and is reported as closed as of 2025-11-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024055NOA_Closure Letter_11252025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024055NOA/42024055NOA_Closure%20Letter_11252025_(23-266712).pdf

42024055NOA_Closure Letter_11252025_(23-266712)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024055NOA/42024055NOA_Closure%20Letter_11252025_(23-266712)_text.pdf

42024055NOA_Notice of Amendment_12032024_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024055NOA/42024055NOA_Notice%20of%20Amendment_12032024_(23-266712).pdf

42024055NOA_Notice of Amendment_12032024_(23-266712)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024055NOA/42024055NOA_Notice%20of%20Amendment_12032024_(23-266712)_text.pdf

42024055NOA_Operator Response to Notice_12052024_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024055NOA/42024055NOA_Operator%20Response%20to%20Notice_12052024_(23-266712).pdf

42024055NOA_Notice of Amendment_12032024_(23-266712)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: steve.ledbetter@hfsinclair.com
December 3, 2024
Steven Ledbetter
Executive Vice President, Commercial
HF Sinclair Corporation
2828 N. Harwood St, Suite 1300
Dallas, TX 75201
CPF 4-2024-055-NOA
Dear Mr. Ledbetter:
From February 27 to May 11, 2023, of the onsite inspection, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States
Code (U.S.C.) inspected Sinclair Transportation Company, LLC’s1 (Sinclair) procedures for its
hazardous liquid pipeline facilities in Sinclair, Wyoming.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Sinclair’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) . . . .
(2) . . . .
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
§ 195.417 Notification of potential rupture.
(a) As used in this part, a notification of potential rupture means
the notification to, or observation by, an operator (e.g., by or to its
controller(s) in a control room, field personnel, nearby pipeline or
1 Sinclair Transportation Company, LLC, is a subsidiary of HF Sinclair Corporation.



utility personnel, the public, local responders, or public authorities) of
one or more of the below indicia of a potential unintentional or
uncontrolled release of a large volume of hazardous liquids from a
pipeline:
(1) An unanticipated or unexplained pressure loss outside of the
pipeline's normal operating pressures, as defined in the operator's
written procedures. The operator must establish in its written
procedures that an unanticipated or unplanned pressure loss is outside
of the pipeline's normal operating pressures when there is a pressure
loss greater than 10 percent occurring within a time interval of 15
minutes or less, unless the operator has documented in its written
procedures the operational need for a greater pressure-change
threshold due to pipeline flow dynamics (including changes in
operating pressure, flow rate, or volume), that are caused by
fluctuations in product demand, receipts, or deliveries;
(2) An unanticipated or unexplained flow rate change, pressure
change, equipment function, or other pipeline instrumentation
indication at the upstream or downstream station that may be
representative of an event meeting paragraph (a)(1) of this section; or
(3) Any unanticipated or unexplained rapid release of a large
volume of hazardous liquid, a fire, or an explosion, in the immediate
vicinity of the pipeline.
Sinclair’s written procedures for conducting operations and maintenance activities were
inadequate to provide for safe operation of a pipeline facility in accordance with § 195.402(c)(3).
Specifically, Sinclair’s Operations and Maintenance Manual, revised July 21, 2021, failed to
contain provisions for operator personnel to identify a notification of potential rupture in
accordance with § 195.417.
Sinclair must revise its written procedures to include provisions for operator personnel to identify
a potential rupture and instructions on notification of a potential rupture in accordance with §
195.417(a).
2. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) . . . .
(2) . . . .
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.



§ 195.419 Valve capabilities.
(a) Scope. The requirements in this section apply to rupture-
mitigation valves (RMV), as defined in § 195.2, or alternative
equivalent technology, installed pursuant to §§ 195.258 and 195.418. (b)
Rupture identification and valve shut-off time.
Sinclair’s written procedures for conducting operations and maintenance activities were
inadequate to provide for safe operation of a pipeline facility in accordance with § 195.402(c)(3).
Specifically, Sinclair’s Operations and Maintenance Manual, revised July 21, 2021, failed to
include the provisions of § 195.419(a)-(h).
Therefore, Sinclair Transportation company must amend its written procedures to include the
provisions of § 195.419(a)-(h).
3. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(c) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following
to provide safety during maintenance and normal operations:
(1) . . . .
(2) . . . .
(3) Operating, maintaining, and repairing the pipeline system in
accordance with each of the requirements of this subpart and subpart
H of this part.
§ 195.420 Valve maintenance.
(a) . . . .
(f) Each operator must implement remedial measures as follows to
correct any valve installed on an onshore pipeline in accordance with §
195.258(c), or an RMV or alternative equivalent technology installed in
accordance with § 195.418, that is indicated to be inoperable or unable
to maintain effective shut-off:
(1) Repair or replace the valve as soon as practicable but no later
than 12 months after finding that the valve is inoperable or unable to
maintain shut-off. An operator may request an extension of the
compliance deadline requirements of this section if it can demonstrate
to PHMSA, in accordance with the notification procedures in § 195.18,
that repairing or replacing a valve within 12 months would be
economically, technically, or operationally infeasible; and
(2) Designate an alternative compliant valve within 7 calendar days
of the finding while repairs are being made and document an interim
response plan to maintain safety. Alternative compliant valves are not
required to comply with valve spacing requirements of this part.



Sinclair’s written procedures for conducting operations and maintenance activities were
inadequate to provide for safe operation of a pipeline facility in accordance with § 195.402(c)(3).
Specifically, Sinclair’s Operations and Maintenance Manual, revised July 21, 2021, failed to
include procedures for repairing or replacing a valve as soon as practicable but no later than 12
months after finding that the valve is inoperable or unable to maintain shut-off, and designate an
alternative compliant valve within 7 calendar days of the finding while repairs are being made and
document an interim response plan to maintain safety in accordance with § 195.420(f)(1) and (2),
respectively.
Therefore, Sinclair must amend its written procedures to include procedures for the remediation
of valves in accordance with the requirements of § 195.420(f).
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
Proceedings.
Please refer to this document and note the response options. 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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice
and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice
without further notice to you and to issue an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 90 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Sinclair Transportation Company maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director,
Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 4-2024-055-NOA and, for each document you submit,
please provide a copy in electronic format whenever possible.



Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Jessica Franklin, Compliance Auditor, Lead, - Pipeline Regulatory,
Jessica.Franklin@HFSinclair.com
Bridgette Taylor, Manager, Pipeline Regulatory - Regulatory Compliance,
bridgette.taylor@hfsinclair.com

42024055NOA_Closure Letter_11252025_(23-266712)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: steve.ledbetter@hfsinclair.com
November 25, 2025
Steven Ledbetter
Executive Vice President, Commercial
HF Sinclair Corporation
2828 N. Harwood St, Suite 1300
Dallas, TX 75201
CPF 4-2024-055-NOA
Dear Mr. Ledbetter:
From February 27, 2023 to May 11, 2023, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)
inspected Sinclair Transportation Company, LLC’s1 (Sinclair) procedures for its hazardous liquid
pipeline facilities in Sinclair, Wyoming.
HF Sinclair Corporation submitted its amended procedures on September 8, 2025. PHMSA staff
reviewed these procedures, and it appears that the inadequacies outlined in this Notice of
Amendment have been corrected.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank
you for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Jessica Franklin, Compliance Auditor, Lead, - Pipeline Regulatory, HF Sinclair
Corporation, Jessica.Franklin@HFSinclair.com
Bridgette Taylor, Manager, Pipeline Regulatory - Regulatory Compliance, HF Sinclair
Corporation, bridgette.taylor@hfsinclair.com
Charles Curl, Director, Pipeline Excellence & Compliance | Midstream, HF Sinclair
Corporation, Charles.Curl@hfsinclair.com
1 Sinclair Transportation Company, LLC, is a subsidiary of HF Sinclair Corporation.
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