{"operation":"document","citation":"CPF 42025049NOPV","title":"ENERGY TRANSFER COMPANY — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-10","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.452(f)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025049nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025049nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025049nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025049NOPV","body":"Notice of Probable Violation involving ENERGY TRANSFER COMPANY. PHMSA's enforcement data identifies the cited regulation as 195.452(f)(3). The case was opened on 2025-07-10 and is reported as closed as of 2026-03-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025049NOPV_Final Order_03262026_(24-296979).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025049NOPV/42025049NOPV_Final%20Order_03262026_(24-296979).pdf\n\n42025049NOPV_Final Order_03262026_(24-296979)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025049NOPV/42025049NOPV_Final%20Order_03262026_(24-296979)_text.pdf\n\n42025049NOPV_Operator Response to Notice_09082025_(24-296979).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025049NOPV/42025049NOPV_Operator%20Response%20to%20Notice_09082025_(24-296979).pdf\n\n42025049NOPV_PCO_07102025_(24-296979).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025049NOPV/42025049NOPV_PCO_07102025_(24-296979).pdf\n\n42025049NOPV_PCO_07102025_(24-296979)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025049NOPV/42025049NOPV_PCO_07102025_(24-296979)_text.pdf\n\n42025049NOPV_Final Order_03262026_(24-296979)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMarch 26, 2026\nVIA ELECTRONIC MAIL TO: tom.long@energytransfer.com\nThomas E. Long\nChief Executive Officer\nEnergy Transfer LP\n8111 Westchester Drive\nDallas, Texas 75225\nRe: CPF No. 4-2025-049-NOPV\nDear Mr. Long:\nEnclosed please find the Final Order issued in the above-referenced case. It makes a finding of\nviolation and finds that Energy Transfer Company has completed the actions specified in the\nNotice to comply with the pipeline safety regulations. Therefore, this case is now closed. Service\nof the Final Order by e-mail is effective upon the date of transmission and acknowledgement of\nreceipt as provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA\nTodd Nardozzi, Director – DOT Compliance, Energy Transfer\nTodd Stamm, Senior Vice President, Operations, Energy Transfer\nMatthew Stork, Vice President, Technical Services, Energy Transfer\nSusie Sjulin, Director – DOT Compliance, Energy Transfer\nCONFIRMATION OF RECEIPT REQUESTED\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 )\nEnergy Transfer Company, )\na subsidiary of Energy Transfer, LP, ) CPF No. 4-2025-049-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nFrom March 4 to September 26, 2024, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Energy\nTransfer Company’s (ETC or Respondent) Sunoco Lea to Midland interstate hazardous liquid\npipeline located in New Mexico and Texas.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated July 10, 2025, a Notice of Probable Violation and Proposed\nCompliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding\nthat ETC had violated 49 CFR § 195.452(f)(3) and proposed ordering Respondent to take certain\nmeasures to correct the alleged violation.\nETC responded to the Notice by letter dated September 8, 2025 (Response).1 Respondent\nprovided an explanation regarding the allegations in the Notice and offered additional\ninformation in response to the Notice. Respondent did not request a hearing and therefore has\nwaived its right to one.\nFINDING OF VIOLATION\nThe Notice alleged that Respondent violated 49 CFR Part 195, as follows:\nItem 1: The Notice alleged that Respondent violated 49 CFR § 195.452(f)(3), which states:\n1 ETC requested an extension to respond to the Notice via email on July 10, 2025. This request was granted by the\nDirector via letter dated July 17, 2025, extending ETC’s time to respond to September 8, 2025.\n\n\n\n2\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) …\n(f) What are the elements of an integrity management program? An\nintegrity management program begins with the initial framework. An\noperator must continually change the program to reflect operating\nexperience, conclusions drawn from results of the integrity assessments,\nand other maintenance and surveillance data, and evaluation of\nconsequences of a failure on the high consequence area. An operator must\ninclude, at minimum, each of the following elements in its written integrity\nmanagement program:\n(1) …\n(3) An analysis that integrates all available information about the\nintegrity of the entire pipeline and the consequences of a failure (see\nparagraph (g) of this section);\nThe Notice alleged that Respondent violated 49 CFR § 195.452(f)(3) by failing to include in its\nwritten integrity management program an analysis of its Sunoco Lea to Midland pipeline system\nthat integrates all available information about the integrity of the entire pipeline and the\nconsequences of failure. Specifically, the Notice alleged that ETC failed to incorporate coupon\nand inhibitor data on its Sunoco Lea to Midland pipeline system into its risk model.\nIn its Response, ETC averred that the risk model reviewed by PHMSA in March 2024 “did\nconsider both coupon data and inhibiter program for the Internal Corrosion (IC) Threat.”2\nHowever, ETC noted that because of “data issues both coupon and inhibitor factors used default\nvalues” in the risk model for the Sunoco Lea to Midland pipeline segments.3 ETC stated that\n“[o]ther factors such as ILI feature count, number of leaks, product type, and assessment dates\nwere used for the IC threat.”4\nETC further asserted that it transitioned to a new semi-quantitative risk analysis model in 2024\nthat “does consider if the pipeline has an inhibitor program in the internal corrosion risk score.”5\nCiting that transition, ETC contends that the “data issues with inhibitor data for these pipeline\nsegments have been resolved” as well as the inclusion of the coupon data.6 ETC included with its\nResponse Attachment A, updated risk analysis results, and Attachment B, updated risk model\ninternal corrosion algorithm procedures, to corroborate its statements in its Response.7\nETC does not state in its Response when the transition to the new risk model occurred other than\nto indicate it occurred sometime in 2024. In addition, ETC created and revised Attachments A\n2 Response at Page 1.\n3 Id.\n4 Id.\n5 Response at Page 2.\n6 Id.\n7 Id.\n\n\n\n3\nand B in 2025, a year after the PHMSA inspection took place. ETC also conceded in its\nResponse that the risk model reviewed by PHMSA during the inspection did not factor the\npipeline’s coupon and inhibitor data in the risk model. Rather, the risk model used default values\nfor those data points and relied on other factors to determine the internal corrosion threat to the\nSunoco Lea to Midland pipeline system.\nAccordingly, after considering all of the evidence, I find that Respondent violated 49 CFR\n§ 195.452(f)(3) by failing to include in its written integrity management program an analysis of\nits Sunoco Lea to Midland pipeline system that integrates all available information about the\nintegrity of the entire pipeline including coupon and inhibitor data.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Item 1 in the Notice for the violation of\n49 CFR § 195.452(f)(3). Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. The Director\nindicates that Respondent has taken the following actions specified in the proposed compliance\norder:\n1. With respect to the violation of section 195.452(f)(3) (Item 1), Respondent has\nincorporated coupon and inhibitor data from the Sunoco Lea to Midland pipeline\nsystem into its risk model and provided the risk model analysis results to Southwest\nRegion.\nAccordingly, I find that compliance has been achieved with respect to this violation. Therefore,\nthe compliance terms proposed in the Notice are not included in this Order.\nUnder 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\nAvenue, S.E., East Building, 2nd Floor, Washington, D.C. 20590, with a copy sent to the Office\nof Chief Counsel, PHMSA, at the same address. The written petition must be received no later\nthan 20 days after receipt of the Final Order by Respondent. Any petition submitted must\ncontain a statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The\nterms of the order, including corrective action, remain in effect unless the Associate\nAdministrator, upon request, grants a stay. The terms and conditions of this Final Order are\neffective upon service in accordance with 49 CFR § 190.5.\n___________________________________ __________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":9641}