Energy Transfer 2012 Annual Report Download - page 193

F - 48
The table below reflects the amounts of accrued liabilities recorded in our consolidated balance sheets related to environmental
matters that are considered to be probable and reasonably estimable. Except for matters discussed above, we do not have any
material environmental matters assessed as reasonably possible that would require disclosure in our consolidated financial
statements.
December 31,
2012 2011
Current $ 46 $ 1
Non-current 165 13
Total environmental liabilities $ 211 $ 14
During the three months ended December 31, 2012, Sunoco had $12 million of expenditures related to environmental cleanup
programs.
The U.S. Environmental Protection Agency’s (the “EPA”) Spill Prevention, Control and Countermeasures program regulations
were recently modified and impose additional requirements on many of our facilities. We expect to expend resources on tank
integrity testing and any associated corrective actions as well as potential upgrades to containment structures to comply with
the new rules. Costs associated with tank integrity testing and resulting corrective actions cannot be reasonably estimated at
this time, but we believe such costs will not have a material adverse effect on our financial position, results of operations or
cash flows.
On August 20, 2010, the EPA published new regulations under the federal Clean Air Act (“CAA”) to control emissions of
hazardous air pollutants from existing stationary reciprocal internal combustion engines. The rule will require us to undertake
certain expenditures and activities, likely including purchasing and installing emissions control equipment. In response to an
industry group legal challenge to portions of the rule in the U.S. Court of Appeals for the D.C. Circuit and a Petition for
Administrative Reconsideration to the EPA, on March 9, 2011, the EPA issued a new proposed rule and direct final rule
effective on May 9, 2011 to clarify compliance requirements related to operation and maintenance procedures for continuous
parametric monitoring systems. If no further changes to the standard are made as a result of comments to the proposed rule,
we would not expect that the cost to comply with the rule’s requirements will have a material adverse effect on our financial
condition or results of operations. Compliance with the final rule is required by October 2013.
On June 29, 2011, the EPA finalized a rule under the CAA that revised the new source performance standards for manufacturers,
owners and operators of new, modified and reconstructed stationary internal combustion engines. The rule became effective
on August 29, 2011. The rule modifications may require us to undertake significant expenditures, including expenditures for
purchasing, installing, monitoring and maintaining emissions control equipment, if we replace equipment or expand existing
facilities in the future. At this point, we are not able to predict the cost to comply with the rule’s requirements, because the
rule applies only to changes we might make in the future.
Our pipeline operations are subject to regulation by the DOT under the PHMSA, pursuant to which the PHMSA has established
requirements relating to the design, installation, testing, construction, operation, replacement and management of pipeline
facilities. Moreover, the PHMSA, through the Office of Pipeline Safety, has promulgated a rule requiring pipeline operators
to develop integrity management programs to comprehensively evaluate their pipelines, and take measures to protect pipeline
segments located in what the rule refers to as “high consequence areas.” Activities under these integrity management programs
involve the performance of internal pipeline inspections, pressure testing or other effective means to assess the integrity of
these regulated pipeline segments, and the regulations require prompt action to address integrity issues raised by the assessment
and analysis. For the years ended December 31, 2012, 2011 and 2010, $7 million, $18 million and $13 million, respectively,
of capital costs and $17 million, $15 million and $15 million, respectively, of operating and maintenance costs have been
incurred for pipeline integrity testing. Integrity testing and assessment of all of these assets will continue, and the potential
exists that results of such testing and assessment could cause ETP to incur even greater capital and operating expenditures
for repairs or upgrades deemed necessary to ensure the continued safe and reliable operation of its pipelines; however, no
estimate can be made at this time of the likely range of such expenditures.
Our operations are also subject to the requirements of the federal Occupational Safety and Health Act (“OSHA”), and
comparable state laws that regulate the protection of the health and safety of employees. In addition, OSHA’s hazardous
communication standard requires that information be maintained about hazardous materials used or produced in our operations
and that this information be provided to employees, state and local government authorities and citizens. We believe that our
operations are in substantial compliance with the OSHA requirements, including general industry standards, record keeping
requirements, and monitoring of occupational exposure to regulated substances.
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