SUNCOR ENERGY (USA) PIPELINE CO. — Warning Letter

party submissionOfficial PDF520145004W_Operator Response to Notice_06022014.pdf#

520145004W_warning letter_04152014_text.pdf, page 1Official PDFWARNING 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.#

520145004W_warning letter_04152014_text.pdf, page 2Suncor 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. 2#