# ENTERPRISE PRODUCTS OPERATING LLC — Warning Letter

**Citation:** CPF 220115005W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2011-03-18

CLOSED warning letter citing 195.404(a)(2), 195.404(a)(3), 195.589(c).

## Document text

Warning Letter involving ENTERPRISE PRODUCTS OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.404(a)(2),  195.404(a)(3),  195.589(c). The case was opened on 2011-03-18 and is reported as closed as of 2011-03-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220115005W_warning letter_03182011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115005W/220115005W_warning%20letter_03182011.pdf

220115005W_warning letter_03182011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115005W/220115005W_warning%20letter_03182011_text.pdf

220115005W_warning letter_03182011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 18, 2011
Mr. Kevin Bodenhamer
Senior Vice President of Liquid Pipeline Operation
Enterprise Products Operating, LLC
1100 Louisiana Street
Houston, Texas 77002
CPF 2-2011-5005W
Dear Mr. Bodenhamer:
Between February 28 and March 3, 2011, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) inspected Enterprise Products Operating, LLC
(Enterprise) records in Chunchula, Alabama, and your pipeline facilities located in Alabama
and Mississippi, pursuant to Chapter 601 of 49 United States Code.
As a result of the inspection, it appears that Enterprise has committed probable violations of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected
and the probable violations are:
1. §195.404 Maps and records.
(a) Each operator shall maintain current maps and records of its pipeline systems
that include at least the following information:
.... (2) All crossings of public roads, railroads, rivers, buried utilities, and foreign
pipelines.
Enterprise did not have current maps or records of its Chunchula Pipeline System to
show all the foreign pipeline crossings.
Enterprise’s records did not show the Destin Pipeline crossing at Mile Post 38 in
Greene County, Mississippi, or the Tennessee Gas Pipeline crossings at Mile Post 6 in
Petal, Mississippi. During the PHMSA inspection, Enterprise personnel submitted
Encroachment/Foreign Line Crossing reports to Enterprise’s Asset Integrity



Coordinator to update the maps and records for the Destin Pipeline and Tennessee Gas
Pipeline crossings.
2. §195.404 Maps and records.
(a) Each operator shall maintain current maps and records of its pipeline systems
that include at least the following information:
.... (3) The maximum operating pressure of each pipeline.
Enterprise did not have the correct records for the maximum operating pressure
(MOP) of the suction side piping in the Chunchula Pump Station.
Enterprise’s records indicated that the MOP of the Chunchula Pipeline System, to
include the Chunchula Pump Station, was 1,440 psig. Enterprise’s hydrostatic
pressure test records for the pump station, and the ANSI 300 components, do not
support a 1,440 psig MOP per §195.406(a) between the station upstream isolation
valves and the pumps.
During the PHMSA inspection, Enterprise personnel submitted an MOP Data Change
Request to Enterprise’s Asset Integrity Department to review and reestablish the
station MOP at 720 psig between the upstream isolation valves and suction side of the
pumps. Notwithstanding the incorrect records, the pump station piping on the suction
side of the pumps has been protected by the high discharge pressure shutdown switch
at the upstream Hatters Pond Pump Station, which was set at 600 psig
3. §195.589 What corrosion control information do I have to maintain?
.... (c) You must maintain a record of each analysis, check, demonstration,
examination, inspection, investigation, review, survey, and test required by this
subpart in sufficient detail to demonstrate the adequacy of corrosion control
measures or that corrosion requiring control measures does not exist. You must
retain these records for at least 5 years, except that records related to §§195.569,
195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the
pipeline remains in service.
Enterprise did not have records for the inspection of the internal surface of the pipe for
evidence of corrosion when certain pipe sections were removed from Enterprise’s
Chunchula Pipeline System.
Enterprise’s Maintenance Reports for repairs done on the pipeline on December 22,
2010, did not show that the internal pipe surface of the removed pipe was inspected
for evidence of corrosion per §195.579(c). During the PHMSA inspection, Enterprise
personnel inspected the internal surface of the removed pipe for evidence of corrosion
and corrected the Maintenance Reports. The removed pipe was inspected at
Enterprise’s Petal Storage facility where the pipe was stored. It had no signs of
corrosion. The repair work during which the pipe was removed was:
− Dig #1, ASSMT 409 at Mile Post 11.95 in Escambia County, Alabama
− Dig #2, ASSMT 406 at Mile Post 2.45 in Mobile County, Alabama
2



Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of
$1,000,000 for any 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 items identified in this letter. Failure to do so will result in Enterprise 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 2-2011-5005W. 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,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220115005W>
- Source ID: `phmsa-enforcement`
- SHA-256: `3ab2790ffe4d86a13c88b76edb36dbfba92b2248b70a6e7385e21cc9ba037c2c`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T01:11:18.605Z
- Document slug: `phmsa-enforcement-220115005w`

### Source metadata

```json
{
  "cpf": "220115005W",
  "operator": "ENTERPRISE PRODUCTS OPERATING LLC",
  "region": "Southern",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.404(a)(2)",
    "195.404(a)(3)",
    "195.589(c)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
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    },
    {
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      "url": "https://primis.phmsa.dot.gov/enforcement-documents/220115005W/220115005W_warning%20letter_03182011_text.pdf",
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  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "ENTERPRISE PRODUCTS OPERATING LLC"
}
```
