# SINCLAIR TRANSPORTATION COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 520025010
- **title:** SINCLAIR TRANSPORTATION COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2002-04-30
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.452(b)(6)(ii).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520025010.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520025010.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520025010
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520025010
**body:**

Notice of Amendment involving SINCLAIR TRANSPORTATION COMPANY. PHMSA's enforcement data identifies the cited regulation as 195.452(b)(6)(ii). The case was opened on 2002-04-30 and is reported as closed as of 2005-03-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520025010_order directing amendment_12312002.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520025010/520025010_order%20directing%20amendment_12312002.pdf

520025010_order directing amendment_12312002.pdf

@
U.S.Deporlrnent
of Tronsporlolion
Reseqrchond
Sp€Glol Prognoms
Adminlslrolion
400 Seventh Sl.. S.W
washrnglon. D.C 20590
DEC 3 | 2002
Mr. Kevin Brown
Senior Vice President - Operations
Sinclair Pipeline Company
P.O. Box 30825
Salt Lake City, UT 84130-0825
Re: CPF No. 5-2002-5010
Dear Mr. Brown:
Enclosed is the Order Directing Amendment issued by the Associate Administrator for
Pipeline Safety in the above-referenced case. It makes findings of inadequate procedures and
requires that you amend your integrity management program procedures. When the terms of the
Order are completed, as determined by the Director, Western Region, OPS, this enforcement action
will be closed. Your receipt ofthe Order Directing Amendment constitutes seryice ofthat document
under 49 C.F.R. $ 190.5.
Sincerely,
t/L*
$VY"'dolvn M. Hill
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Mark A. Petersen
Manager, Pipelines and Terminals
Sinclair Oil Corporation
CERTIFIED MAIL - RETURN RECEIPT REOUESTED



o
DEPARTMENT OF TRANSPORTATION
RESEARCH AND SPECTAL PROGRAMS ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON. DC 20590
In the Matter of
Sinclair Pipeline Company,
Respondent.
CPF No. 5-2002-5010
ORDER DIRECTING AMENDMENT
On March I2-l3,2002,pursuant to 49 U.S.C. $ 601 1 7, representatives of the Westem and Southern
Regions, Office of Pipeline Safety (OPS), inspected Sinclair Pipeline Company's (Respondent's)
integrity management program at Respondent's,facility in Lakewood, Colorado,, As a result of the
inspection, the Director, WssternRegion, OPS, issuedto Respondent, by letterdatedApril 30,20A2,
a Notice of Amendment Q.trOA). The NOA alleged inadequacies in.Respondent's integrity
management procedures and proposed to require amendment of these procedures to comply with the
requirements of 49 C.F.R. $ 195.452.
Respondent responded to the NOA by letter dated Jvne24,2002 (Response). Respondent did not
contest the NOA and did not request a hearing, consequently Respondent waived its right to one.
Respondent also submitted amended integrity management procedures with its response letter. The
Western Region reviewed the amended procedures. The revised procedures now contain a Section
206 entitled, "Technical Basis for Buffer Zone." However, Section 206 is summary in nature,
consisting largely of three one-page drawings containing various unsupported assumptions
conceming worst case discharge volumes, spread pool width, and spread pool depth. Respondent
did not explain the basis for these values and did not demonstrate why they could be relied upon to
ensure that all segments are properly identified, particularly segments in the vicinity of topological
gradients, streams and waterways, and drinking water high consequence axeas. Respondent must
provide segment identification procedures which include detailed supporting justifications that
provide a sound technical basis for the assumptions and formulas used in its spill trajectory
modeling.
Accordingly, I find that Respondent's integrity management program procedures are inadequate to
ensure safe operation of its pipeline system. Pursuant to 49 U.S.C. $ 60108(a) and 49 C.F.R.
S 190.237, Respondent is ordered to make the following changes to its integrity management
program procedures:



I
2
1.
Amend its procedures to ensure that pipeline segments that intersect with drinking water
high consequence areas are included in its spill modeling analysis and identified as
segments that could affect a high consequence area.
2.
a
J .
4.
5.
6.
Amend its procedures to provide adequate technical justification for determining the
extent of the buffer zone used to identi$ pipeline segments that could affect high
consequence areas by including a systematic, detailed, and technically sound land flow
analysis incorporating factors, such as topological and hydraulic gradients, that could
stretch the spill pool footprint beyond that associated with uniform distribution.
Amend its procedures to provide adequate technical justification for determining the
extent of the buffer zone used to identiff pipeline segments that could affect high
consequence areas to account for the actual flow characteristics of minor streams and
waterways that can transport releases of commodity to a high consequence area.
Amend its procedures to provide adequate technical justification for determining the
volume of commodity that could be released from a pipeline leak or rupture in
determining the extgnt of the buffer zone used to identiff pipeline segments that could
affect high consequence areas, such that the basis for determining the worst case release
volume is explained and taken into account
Amend its procedures to include an independent field validation and quality assurance
review of the results of the segment identification process to ensure that all pipeline
segments that could affect a high consequence area have been identified.
Submit the amended procedures within 30 days following receipt ofthis Order Directing
Amendment. Submit all procedures and technical justifications demonstrating
compliance with this Order to the Director, Westem Region, Office of Pipeline Safety,
Golden Hills Centre, Suite A-250,12600 West Colfax Avenue, Lakewood, CO 80215-
3736.
The Director, Western Region, OPS, may grant an extension of time to comply with any of the
required items upon a request by the Respondent demonstrating good cause for an extension.
Failure to comply with this Order Directing Amendment may result in the assessment of civil
penalties of up to $25,000 per violation per day, or in the referral of the case for judicial
enforcement. The terms and conditions of this Order are effective upon receipt.
DEC 3 I m02
Date Issued
Associate Admini strator
for Pipeline Safety
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