# SINCLAIR TRANSPORTATION COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 42025021NOPV
- **title:** SINCLAIR TRANSPORTATION COMPANY — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2025-01-08
- **effective on:** Not available
- **summary:** OPEN notice of probable violation citing 195.310(a), 195.310(b), 195.430, 195.452(b)(5).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42025021nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42025021nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42025021nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42025021NOPV
**body:**

Notice of Probable Violation involving SINCLAIR TRANSPORTATION COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.310(a),  195.310(b),  195.430,  195.452(b)(5). The case was opened on 2025-01-08 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42025021NOPV_Consent Agreement and Order_03062026_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Consent%20Agreement%20and%20Order_03062026_(23-266712).pdf

42025021NOPV_Consent Agreement and Order_03062026_(23-266712)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Consent%20Agreement%20and%20Order_03062026_(23-266712)_text.pdf

42025021NOPV_Final Order_09262025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Final%20Order_09262025_(23-266712).pdf

42025021NOPV_Final Order_09262025_(23-266712)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Final%20Order_09262025_(23-266712)_text.pdf

42025021NOPV_Operator Petition for Reconsideration (Part 1)_10162025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Operator%20Petition%20for%20Reconsideration%20(Part%201)_10162025_(23-266712).pdf

42025021NOPV_Operator Petition for Reconsideration (Part 2)_10162025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Operator%20Petition%20for%20Reconsideration%20(Part%202)_10162025_(23-266712).pdf

42025021NOPV_Operator Response to Notice (REVISED) and Request for Informal Discussion_06092025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Operator%20Response%20to%20Notice%20(REVISED)%20and%20Request%20for%20Informal%20Discussion_06092025_(23-266712).pdf

42025021NOPV_Operator Response to Notice and Request for Time Extension_04012025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Operator%20Response%20to%20Notice%20and%20Request%20for%20Time%20Extension_04012025_(23-266712).pdf

42025021NOPV_Operator Response to Notice_02142025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_Operator%20Response%20to%20Notice_02142025_(23-266712).pdf

42025021NOPV_PCO_01082025_(23-266712).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_PCO_01082025_(23-266712).pdf

42025021NOPV_PCO_01082025_(23-266712)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025021NOPV/42025021NOPV_PCO_01082025_(23-266712)_text.pdf

42025021NOPV_Final Order_09262025_(23-266712)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
September 26, 2025
VIA ELECTRONIC MAIL TO: steve.ledbetter@hfsinclair.com
Steven Ledbetter
Executive Vice President, Commercial
HF Sinclair Corporation
2828 N. Harwood Street
Suite 1300
Dallas, TX 75201
Re: CPF No. 4-2025-021-NOPV
Dear Mr. Ledbetter:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and specifies actions that need to be taken to comply with the pipeline safety
regulations. When the terms of the compliance order are completed, as determined by the
Director, Southwest Region, this enforcement action will be closed. Service of the Final Order
by e-mail is effective upon the date of transmission and acknowledgement of receipt as provided
under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Bryan Jeffrey Lethcoe, Director, Southwest Region, Office of Pipeline Safety
Charles Curl, Director Pipeline Excellence and Compliance, HF Sinclair Corporation,
charles.curl@hfsinclair.com



Dwight Brown, Pipeline Regulator Manager, HF Sinclair Corporation,
dwight.brown@hfsinclair.com
CONFIRMATION OF RECEIPT REQUESTED
2



3
U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
HF Sinclair Corporation, ) CPF No. 4-2025-021-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
On January 8, 2025, pursuant to 49 CFR § 190.207, the Director, Southwest Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice or NOPV) to HF Sinclair
Corporation (HF Sinclair or Respondent). The Notice proposed finding that Respondent had
violated the pipeline safety regulations in 49 CFR Part 195. The Notice also proposed certain
measures to correct the violations.
HF Sinclair responded to the Notice on February 14, 2025, one week after the 30-day response
deadline stated in the Notice. In this response, Respondent did not contest the allegations of
violation or corrective measures and stated that it would comply with the Proposed Compliance
Order. Subsequently, on April 1, 2025, fifty-three days after the 30-day response deadline, HF
Sinclair submitted a second response, wherein it disputed all the NOPV items and requested
informal discussion with Southwest Region. Respondent provided a follow-up response on June
9, 2025, one hundred and twenty-two days after the 30-day response deadline, wherein it
provided additional information and reiterated its request for informal discussion.
Pursuant to 49 CFR § 190.208(d), failure to respond within 30 days of receipt of a NOPV
constitutes a waiver of the right to contest the allegations in the Notice and authorizes the
Associate Administrator, without further notice to the respondent, to find the facts as alleged in
the NOPV and to issue a final order. If a respondent states that they are not contesting a Notice
with a Proposed Compliance Order, the Associate Administrator is authorized to make a finding
of violation and to issue a final order. See 49 CFR 190.208(b)(1). Here, Respondent did not
respond within 30 days of receipt of the NOPV. Thus, HF Sinclair waived its right to contest the
allegations and this waiver authorized finding the facts as alleged in the Notice and issuance of a
final order. Respondent’s subsequent submissions were untimely and will not be considered.
Based upon a review of all of the evidence, pursuant to section 190.213, I find Respondent
violated the pipeline safety regulations listed below, as more fully described in the enclosed
Notice, which is incorporated by reference:



4
49 CFR § 195.310(b) (Item 1) ─ Respondent failed to maintain pressure test
records with the required information.
49 CFR § 195.430 (Item 2) ─ Respondent failed to maintain adequate firefighting
equipment at each pump station and breakout tank area.
49 CFR § 195.452(b)(5) (Item 3) ─ Respondent failed to implement and follow
its integrity management program.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
Compliance Actions
Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the
actions proposed in the enclosed Notice to correct the violations. The Director may grant an
extension of time to comply with any of the required items upon a written request timely
submitted by the Respondent and demonstrating good cause for an extension. Upon completion
of the ordered actions, Respondent may request that the Director close the case. Failure to
comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223
or in referral to the Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this order are effective upon service in accordance with 49 CFR
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
8701 S. Gessner, Suite 630
Houston TX 77074
NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: steve.ledbetter@hfsinclair.com
January 8, 2025
Steven Ledbetter
Executive Vice President, Commercial
HF Sinclair Corporation
2828 N. Harwood St, Suite 1300
Dallas, TX 75201
CPF 4-2025-021-NOPV
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 the pipeline facilities and records of Sinclair Transportation Company,
LLC1 (Sinclair).
As a result of the inspection, it is alleged that Sinclair has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 195.310 Records.
(a) A record must be made of each pressure test required by this
subpart, and the record of the latest test must be retained as long as the
facility tested is in use.
(b) The record required by paragraph (a) of this section must
include:
(1) The pressure recording charts;
(2) Test instrument calibration data;
1 Sinclair Transportation Company, LLC, is a subsidiary of HF Sinclair Corporation.



2
(3) The name of the operator, the name of the person responsible
for making the test, and the name of the test company used, if any;
(4) The date and time of the test;
(5) The minimum test pressure;
(6) The test medium;
(7) A description of the facility tested and the test apparatus;
(8) An explanation of any pressure discontinuities, including test
failures, that appear on the pressure recording charts;
(9) Where elevation differences in the section under test exceed 100
feet (30 meters), a profile of the pipeline that shows the elevation and
test sites over the entire length of the test section; and
(10) Temperature of the test medium or pipe during the test period.
Sinclair failed to maintain pressure test records with the required information in accordance with
§ 195.310(b)(1)-(10). Specifically, for the 10-inch Casper Station to Poison Spider Rd. segment,
Sinclair provided the hydrotest chart, which only included the segment name, minimum test
pressure, and date/time of the test.
2. § 195.430 Firefighting equipment.
Each operator shall maintain adequate firefighting equipment at
each pump station and breakout tank area. The equipment must be-
(a) In proper operating condition at all times;
(b) Plainly marked so that its identity as firefighting equipment is
clear; and,
(c) Located so that it is easily accessible during a fire.
Sinclair failed to maintain adequate firefighting equipment at each pump station and breakout tank
area in accordance with § 195.430. Specifically, Sinclair failed to maintain adequate firefighting
equipment at Tanks 1325 and 1326 at Bairoil Pump Station.
3. § 195.452 Pipeline integrity management in high consequence areas.
(a) . . . .
(b) What program and practices must operators use to manage
pipeline integrity? Each operator of a pipeline covered by this section
must:
(1) . . . .
(5) Implement and follow the program.
Sinclair failed to implement and follow its integrity management program in accordance with §
195.452(b)(5). Specifically, Sinclair failed to perform spill modeling for Cheyenne Station in
accordance with its procedure, Sinclair Transportation Company – Pipeline Integrity Management
Program, IM-100 Volume Release & HCA Impact Procedure, section 103.1 (Rev. Jan. 24, 2022).
Section 103.1 states that Sinclair will perform spill modeling on facilities with breakout tanks.
Cheyenne Station has three breakout tanks, but Sinclair failed to perform the requisite spill
modeling.



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Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related
series of violations. For violation occurring on or after January 6, 2023 and before December 28,
2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists,
up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or
after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142
per violation per day the violation persists, up to a maximum of $2,391,412 for a related series of
violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the
maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a
maximum of $2,251,334 for a related series of violations. For violation occurring on or after
January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per
violation per day the violation persists, up to a maximum of $2,225,034 for a related series of
violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the
maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a
maximum of $2,186,465 for a related series of violations. For violation occurring on or after
November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per
violation per day, with a maximum penalty not to exceed $2,132,679.
We have reviewed the circumstances and supporting documents involved in this case, and have
decided not to propose a civil penalty assessment at this time.
Proposed Compliance Order
With respect to Items 1, 2, and 3 pursuant to 49 U.S.C. § 60118(b), the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Sinclair Transportation
Company. Please refer to the Proposed Compliance Order, which is enclosed and made a part of
this Notice.
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. All
material you submit in response to this enforcement action may be 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 respond as described in the enclosed
Response Options. 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 a Final Order. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region Director
may extend the period for responding upon a written request timely submitted demonstrating good
cause for an extension.



4
In your correspondence on this matter, please refer to CPF 4-2024-021-NOPV 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: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings
cc: Charles Curl, Director Pipeline Excellence and Compliance, charles.curl@hfsinclair.com
Dwight Brown, Pipeline Regulator Manager, dwight.brown@hfsinclair.com



5
PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Sinclair Transportation Company, LLC (Sinclair),
a Compliance Order incorporating the following remedial requirements to ensure the compliance
of Sinclair with the pipeline safety regulations:
A. In regard to Item 1 of the Notice pertaining to Sinclair’s failure to maintain pressure
test records with the required information in accordance with § 195.310(b)(1)-(10),
Sinclair must complete a pressure test for Casper Station to Poison Spider Rd
segment and provide pressure test records that includes the information required by
§ 195.310(b)(1)-(10) to the Director, Southwest Region, PHMSA within 90 days
of receipt of the Final Order.
B. In regard to Item 2 of the Notice pertaining to Sinclair’s failure to maintain adequate
firefighting equipment at each pump station and breakout tank area in accordance
with § 195.430, Sinclair must install a fire protection system on Tanks 1325 and
1326 and provide records of the installed system to the Director, Southwest Region,
PHMSA within 90 days of receipt of the Final Order.
C. In regard to Item 3 of the Notice pertaining to Sinclair’s failure to implement and
follow its integrity management program in accordance with § 195.452(b)(5),
Sinclair must perform overland spread spill modeling for Cheyenne Station and
provide records of the modeling to the Director, Southwest Region, PHMSA within
90 days of receipt of the Final Order.
D. It is requested (not mandated) that Sinclair Transportation Company maintain
documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to Bryan Lethcoe, Director, Southwest
Region, Pipeline and Hazardous Materials Safety Administration. It is requested
that these costs be reported in two categories: 1) total cost associated with
preparation/revision of plans, procedures, studies and analyses, and 2) total cost
associated with replacements, additions and other changes to pipeline
infrastructure.

42025021NOPV_Consent Agreement and Order_03062026_(23-266712)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
March 6, 2026
VIA ELECTRONIC MAIL TO: steve.ledbetter@hfsinclair.com
Steven Ledbetter
Executive Vice President, Commercial
HF Sinclair Corporation
2828 N. Harwood Street
Suite 1300
Dallas, TX 75201
CPF No. 4-2025-021-NOPV
Dear Mr. Ledbetter:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and HF Sinclair
Corporation, which was executed on March 3, 2026. Service of the Consent Order and Consent
Agreement by electronic mail is deemed effective upon the date of transmission and
acknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: Charles Curl, Director Pipeline Excellence and Compliance, HF Sinclair Corporation,
Charles.curl@hfsinclair.com
Dwight Brown, Pipeline Regulatory Manager, HF Sinclair Corporation,
Dwight.brown@hfsinclair.com
Richard Alonso, Counsel, HF Sinclair Corporation, rich.alonso@hfsinclair.com
James Curry, outside counsel for HF Sinclair Corporation, jcurry@babstcalland.com
Lee Banse, outside counsel for HF Sinclair Corporation, lbanse@babstcalland.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
HF Sinclair Corporation, ) CPF No. 4-2025-021-NOPV
)
)
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated January 8, 2025, pursuant to 49 CFR § 190.207, the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of
Probable Violation and Proposed Compliance Order (Notice) to HF Sinclair Corporation (HF
Sinclair or Respondent).
HF Sinclair responded to the Notice by letter dated February 14, 2025 (Response). Respondent
did not contest the alleged violations or the proposed compliance order. On April 1, 2025,
Respondent submitted a second response, in which it contested Items 1-3 and the proposed
compliance order, requested an additional 90 days to respond to the Notice, and requested to
meet with PHMSA regarding the findings. On June 9, 2025, Respondent submitted a third
response, providing additional reasons contesting the items described in the Notice. On
September 26, 2025, the Associate Administrator issued to Respondent a Final Order including
the violations and proposed compliance order alleged in the Notice, finding that Respondent had
waived its right to contest the allegation. On October 16, 2025, Respondent filed a petition for
reconsideration of the Final Order. HF Sinclair also requested to meet informally with PHMSA
to discuss the matters raised in its petition. Respondent and PHMSA (the Parties) subsequently
met on November 21, 2025. As a result of those discussions, the Parties have agreed to a
Consent Agreement by which PHMSA affirms the findings of violations for two of the Items
alleged in the Notice, withdraws one of the findings of violation from the Final Order, and
Respondent agrees to complete certain compliance actions.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order issued pursuant to section 190.219. HF Sinclair is hereby ordered to comply
with the terms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101,
et seq., failure to comply with this Consent Order may result in the assessment of civil penalties
as set forth in 49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney General
for appropriate relief in a district court of the United States.



The terms and conditions of this Consent Order are effective upon service in accordance with
49 CFR § 190.5.
______________________ ______________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



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U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
HF Sinclair Corporation, ) CPF No. 4-2025-021-NOPV
)
)
)
Respondent. )
____________________________________)
CONSENT AGREEMENT
From February 27 through May 11, 2023, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of Title 49, United States Code (U.S.C.), conducted an on-site pipeline safety inspection of
the facilities and records of HF Sinclair Corporation (HF Sinclair or Respondent) in Wyoming.
The inspection covered 540 miles of pipeline carrying crude oil products between Sinclair
Refinery, Casper Refinery, Guernsey Tank Farm, and Cheyenne Station.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated January 8, 2025, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding
that HF Sinclair committed three violations of 49 CFR Part 195 (Items 1 – 3), and proposed
ordering Respondent to take certain measures to correct the alleged violations.
HF Sinclair responded to the Notice by letter dated February 14, 2025 (Response). Respondent
did not contest the alleged violations or the proposed compliance order. On April 1, 2025,
Respondent submitted a second response, in which it contested Items 1-3 and the proposed
compliance order, requested an additional 90 days to respond to the Notice, and requested to
meet with the Director regarding the Notice. On June 9, 2025, Respondent submitted a third
response, providing additional reasons contesting the items described in the Notice. On
September 26, 2025, the Associate Administrator issued to Respondent a Final Order including
the violations and proposed compliance order alleged in the Notice, finding that Respondent had
waived its right to contest the allegation. On October 16, 2025, Respondent filed a petition for
reconsideration of the Final Order.
The Director and Respondent (the Parties) subsequently met to discuss the issues raised in the
petition for reconsideration. As a result of those discussions and as explained in more detail
below, the Parties have agreed to a Consent Agreement by which PHMSA affirms the findings of
violations for two of the Items alleged in the Notice, withdraws one of the findings of violation



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from the Final Order, and Respondent agrees to complete certain compliance actions.
Having agreed that settlement of this proceeding will avoid further administrative proceedings or
litigation and will serve the public interest by promoting safety and protection of the
environment, pursuant to 49 U.S.C. § 60101, et seq. and 49 CFR Part 190, and upon consent and
agreement, the Parties hereby agree as follows:
I. General Provisions
1. Respondent acknowledges that as the operator of the pipeline facilities subject to
the Notice and Final Order, Respondent and its referenced pipeline facilities are 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
(Agreement), Respondent acknowledges that it received proper notice of PHMSA’s action in this
proceeding and that the Notice and Final Order state claims upon which relief may be granted
pursuant to 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder.
2. After Respondent returns this signed Agreement to PHMSA, the Agency’s
representative will present it to the Associate Administrator for Pipeline Safety, recommending
that the Associate Administrator adopt the terms of this Agreement by issuing an administrative
order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement
constitute an offer of settlement until accepted by the Associate Administrator. Once accepted,
the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement.
3. Respondent consents to the issuance of the Consent 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 Order or this Agreement, including
all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution
provisions set forth herein. Respondent agrees to withdraw its petition for reconsideration
regarding the Final Order.
4. This Agreement shall apply to and be binding upon PHMSA and 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 Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and agents
whose duties might reasonably include compliance with this Agreement.
5. This Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this Agreement.
The Parties acknowledge that there are no representations, agreements or understandings relating
to settlement other than those expressly contained in this Agreement, except that the terms of this
Agreement may be construed by reference to the Notice and Final Order.
6. Nothing in this Agreement 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 Agreement alters



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PHMSA's right of access, entry, inspection, and information gathering or 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.
7. For all transfers of ownership or operating responsibility of Respondent’s pipeline
system referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice of the
transfer to the Director no later than 60 days after the transfer occurs.
8. This Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent’s pipeline systems. This Agreement 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.
9. This Agreement does not create rights in, or grant any cause of action to, any third
party not party to this Agreement. 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 Agreement. 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 Agreement.
10. Except as set forth herein, this Agreement does not constitute a finding of
violation of any other federal law or regulation and may not be used in any civil proceeding of
any kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any
law, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this
Agreement or in future PHMSA enforcement actions.
II. Findings of Violation:
11. Item 2 - 49 CFR § 195.430: The Final Order found that HF Sinclair failed to
maintain adequate firefighting equipment at each pump station and breakout tank area.
Specifically, the Final Order found that HF Sinclair failed to maintain adequate firefighting
equipment at Tanks 1325 and 1326 at Bairoil Pump Station. HF Sinclair does not contest the
finding of violation in the Final Order. As such, PHMSA finds a violation of 49 CFR § 195.430.
12. Item 3 - 49 CFR § 195.452(b)(5): The Final Order found that HF Sinclair failed to
implement and follow its integrity management program. Specifically, the Final Order found that
HF Sinclair failed to perform spill modeling for three out-of-service breakout tanks at the
Cheyenne Station in accordance with its procedure. HF Sinclair does not contest the finding of
violation in the Final Order. As such, PHMSA finds a violation of 49 CFR § 195.452(b)(5).
13. Items 2 and 3 will be considered by PHMSA as prior offenses in any future PHMSA
enforcement action taken against Respondent.



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III. Item Withdrawn:
14. Item 1 - CFR § 195.310(b)(1)-(10): With respect to Item 1 of the Final Order, the
Parties agree that this Item should be withdrawn following review of additional documentation
provided by Respondent regarding its compliance with the applicable regulation. Because this
Item is withdrawn, it will not constitute a finding of violation for any purpose, but Respondent
agrees to take the corrective actions in paragraph 16. The finding of violation for Item 1 is
withdrawn.
IV. Compliance Order:
15. In paragraphs 16, 17, 18 of this Consent Agreement, the term Sinclair Assets shall
be defined as the hazardous liquids facilities covered under the notice of divestiture filed by the
Sinclair Transportation Company with the National Registry of Operators on April 4, 2022 that
provided notice of the transfer of pipeline facilities to Holly Energy Partners-Operating, L.P.
16. Item 1: The Final Order included certain compliance order actions related to Item
1. Following informal consultation, the Parties agreed to the following modified actions to be
taken by Respondent. As such, Respondent agrees to undertake the following corrective
measures:
a. Within 60 days of issuance of the Consent Order, HF Sinclair must conduct a
review of its classifications of the Sinclair Assets and ensure that each system is correctly
classified as intrastate or interstate in accordance with 49 CFR Part 195 Appendix A.
Within 60 days of issuance of the Consent Order, HF Sinclair must submit any updates
related to the intrastate or interstate classification of the relevant facilities to the National
Pipeline Mapping System (NPMS). HF Sinclair must notify the Director when the review
is complete, and provide an electronic map (in GIS format) showing interstate and
intrastate pipeline status.
17. Item 2: The Final Order included certain compliance order actions to address the
non-compliance found under Item 2. Following informal consultation, the Parties agreed to the
following modified actions to be taken by Respondent. As such, Respondent agrees to undertake
the following corrective measures:
a. Within 60 days of issuance of the Consent Order, HF Sinclair will conduct a
refresher training of its existing procedures for operators for remote facilities in the
Sinclair Assets that do not have fixed firewater systems and locations where one of the
fire response strategies may be a controlled burn-out. HF Sinclair must provide records to
the Director of the refresher training.
b. Within 240 days of issuance of the Consent Order, HF Sinclair will conduct a
tabletop drill to train operators on the execution of its fire response plan for remote
facilities in the Sinclair Assets that do not have fixed firewater systems and locations
where one of the fire response strategies may be a controlled burn-out. HF Sinclair will
invite local first responders to participate in the tabletop drill and provide notification to



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PHMSA, at least 60 days before the expected date of the drill, to allow for PHMSA
personnel to attend and observe the drill.
c. Within 60 days of completion of the tabletop drill, HF Sinclair will provide the
Director updated fire response procedures and training materials for facilities that do not
have fixed firewater systems and locations where one of the fire response strategies may
be a controlled burn-out. HF Sinclair will provide notification to local first responders to
permit them to participate in future drills.
18. Item 3: The Final Order included certain compliance order actions to address the
non-compliance found under Item 3. Following informal consultation, the Parties agreed to the
following modified actions to be taken by Respondent. As such, Respondent agrees to undertake
the following corrective measures:
a. Within 60 days of the issuance of the Consent Order, HF Sinclair must provide the
Director records confirming the integration into its integrity management program of each
segment on the Sinclair Assets for which IM integration is required per 49 CFR Part 195.
b. Within 60 days of the issuance of the Consent Order, HF Sinclair shall submit to
the Director draft revisions to its integrity management plan requiring verification that out-
of-service pipelines and breakout tanks are confirmed in compliance with all applicable
requirements of its integrity management plan prior to return to service.
c. Within 60 days of receiving any feedback or proposed revisions from the Director,
HF Sinclair will finalize and submit to the Director the updated integrity management plan
sections related to out-of-service pipelines and breakout tanks.
V. Enforcement:
19. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil penalties
under 49 U.S.C. § 60122, of up to $272,926 per violation for each day the violation continues and
referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that
Respondent is not complying with the terms of this Agreement in accordance with the
determinations made by the Director, or in accordance with decisions of the Associate
Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil
penalty amounts are adjusted annually for inflation. See 49 CFR § 190.223. All work plans and
associated schedules set forth or referenced in Section IV (Compliance Order) are automatically
incorporated into this Agreement and are enforceable in the same manner.
VI. Review and Approval Process:
20. With respect to any submission under Section IV (Compliance Order) of this
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, reasonable 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



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actions as approved by the Director, subject to Respondent’s right to invoke the dispute
resolution procedures with respect to any conditions the Director identifies. If the Director
disapproves all or any portion of the submission, the Director will provide Respondent a written
notice of the deficiencies. Respondent will correct all deficiencies within the time specified by
the Director and resubmit it for approval.
VII. Dispute Resolution:
21. The Director and Respondent will informally attempt to resolve any disputes
arising under this Agreement, including any decision of the Director under the terms of Sections
IV (Compliance Order) and VI (Review and Approval Process). If Respondent and the Director
are unable to informally resolve the dispute within 15 calendar days after the dispute is first
raised, in writing, to the Director, Respondent may submit a written request for a determination
resolving the dispute from the Associate Administrator. Such request must be made in writing
and provided to the Director, counsel for the Southwest Region, and to the Associate
Administrator, no later than 10 calendar days from the 15-day deadline for informal resolution
referenced in this paragraph. Along with its request, Respondent must provide the Associate
Administrator with all information Respondent believes is relevant to the dispute. Decisions of
the Associate Administrator under this paragraph will constitute final agency action. The
existence of a dispute and 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.
VIII. Effective Date:
22. The term “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.
IX. Recordkeeping and Information Disclosure:
23. Unless otherwise required in this Agreement, Respondent agrees to maintain
records demonstrating compliance with all requirements of this Agreement for a period of at
least five (5) years following completion of all work to be performed, unless a longer period of
time is required pursuant to 49 
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