# SUNCOR ENERGY (USA) PIPELINE CO. — Warning Letter

- **operation:** document
- **citation:** CPF 520145004W
- **title:** SUNCOR ENERGY (USA) PIPELINE CO. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-04-15
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.404(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145004w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145004w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145004w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520145004W
**body:**

Warning Letter involving SUNCOR ENERGY (USA) PIPELINE CO.. PHMSA's enforcement data identifies the cited regulation as 195.404(c). The case was opened on 2014-04-15 and is reported as closed as of 2014-04-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520145004W_Operator Response to Notice_06022014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145004W/520145004W_Operator%20Response%20to%20Notice_06022014.pdf

520145004W_warning letter_04152014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145004W/520145004W_warning%20letter_04152014.pdf

520145004W_warning letter_04152014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145004W/520145004W_warning%20letter_04152014_text.pdf

520145004W_warning letter_04152014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 15, 2014
Ms. Christina Henderson
Suncor Energy (USA) Pipeline Co.
1715 Fleischli Parkway
Cheyenne, WY 80221
CPF 5-2014-5004W
Dear Ms. Henderson:
On August 1, 2013, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Rocky Mountain Pipeline System in Wyoming and Colorado.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation is:
1. §195.404 (c)(3) Maps and Records
(c) Each operator shall maintain the following records for the periods specified;
(1) The date, location, and description of each repair made to pipe shall be
maintained for the useful life of the pipe.
(2) The date, location, and description of each repair made to parts of the pipeline
other than pipe shall be maintained for at least 1 year.
(3) A record of each inspection and test required by this subpart shall be
maintained for at least 2 years or until the next inspection or test is performed,
whichever is longer.



Suncor Energy (USA) Pipeline Co. (Suncor) failed to maintain proper records of the inspection
two mainline valves at the required 7½ month interval. A block valve at mile post (MP) 34.22
had a signed inspection form dated September 18, 2012, but the form was not complete. Also,
the inspection record of a discharge valve at MP 22.3 was not dated and there was not any valve
specific inspection information provided. As a result, Suncor was not able to show that these
valves were properly inspected as required.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item(s) identified in this letter.
Failure to do so will result in Suncor Energy (USA) being subject to additional enforcement
action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2014-5004W. 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).
Sincerely,
Chris Hoidal
Director, Western
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 T. Larson (#142677)
Mr. Randall Lowry, Suncor Energy (USA) Pipeline Co.
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