Sunoco 2014 Annual Report Download - page 35

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33
ITEM 3. LEGAL PROCEEDINGS
There are certain legal and administrative proceedings arising prior to the February 2002 initial public offering ("IPO")
pending against our Sunoco-affiliated predecessors and us (as successor to certain liabilities of those predecessors). Although
the ultimate outcome of these proceedings cannot be ascertained at this time, it is reasonably possible that some of them may be
resolved unfavorably. Sunoco has agreed to indemnify us for 100 percent of all losses from environmental liabilities related to
the transferred assets arising prior to, and asserted within 21 years of February 8, 2002. There is no monetary cap on this
indemnification from Sunoco. Sunoco's share of liability for claims asserted thereafter will decrease by 10 percent each year
through the thirtieth year following the February 8, 2002 date. Any remediation liabilities not covered by this indemnity will be
our responsibility. In addition, Sunoco is obligated to indemnify us under certain other agreements executed after the IPO.
Additionally, we have received notices of violations and potential fines under various federal, state and local provisions
relating to the discharge of materials into the environment or protection of the environment. While we believe that even if any
one or more of the environmental proceedings listed below were decided against us, it would not be material to our financial
position, results of operations or cash flows, we are required to report environmental proceedings if we reasonably believe that
such proceedings will result in monetary sanctions in excess of $0.1 million.
In January 2012, the Partnership experienced a release on its products pipeline in Wellington, Ohio. In connection with
this release, the Pipeline Hazardous Material Safety Administration ("PHMSA") issued a Corrective Action Order under which
the Partnership is obligated to follow specific requirements in the investigation of the release and the repair and reactivation of
the pipeline. The Partnership also entered into an Order on Consent with the Environmental Protection Agency ("EPA")
regarding the environmental remediation of the release site. All requirements of the Order on Consent with the EPA have been
fulfilled and the Order has been satisfied and closed. The Partnership has also received a "No Further Action" approval from the
Ohio EPA for all soil and groundwater remediation requirements. The Partnership has not received any proposed penalties
associated with this release and continues to cooperate with both PHMSA and the EPA to complete the investigation of the
incident and repair of the pipeline.
In 2012, the EPA issued a proposed consent agreement related to the releases that occurred at the Partnership's pump
station/tank farm in Barbers Hill, Texas and pump station/tank farm located in Cromwell, Oklahoma in 2010 and 2011,
respectively. These matters were referred to the U.S. Department of Justice ("DOJ") by the EPA. In November 2012, the
Partnership received an initial assessment of $1.4 million associated with these releases. The Partnership is in discussions with
the EPA and the DOJ on this matter and hopes to resolve the issue during 2015. The timing or outcome of this matter cannot be
reasonably determined at this time. However, the Partnership does not expect there to be a material impact to its results of
operations, cash flows or financial position.
In September 2013, the Pennsylvania Department of Environmental Protection ("PADEP") issued a Notice of Violation
and proposed penalties in excess of $0.1 million based on alleged violations of various safety regulations relating to the
November 2008 products release by Sunoco Pipeline in Murrysville, Pennsylvania. The Partnership is currently in discussions
with the PADEP. The timing or outcome of this matter cannot be reasonably determined at this time. However, the Partnership
does not expect there to be a material impact to its results of operations, cash flows or financial position.
ITEM 4. MINE SAFETY DISCLOSURES
Not applicable.