# TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Corrective Action Order

**Citation:** CPF 220191002H  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2019-08-08

CLOSED corrective action order.

## Document text

Corrective Action Order involving TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP). The dataset does not identify a cited regulation for this case. The case was opened on 2019-08-08 and is reported as closed as of 2023-09-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220191002H_Amended Corrective Action Order_04282020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Amended%20Corrective%20Action%20Order_04282020.pdf

220191002H_Amended Corrective Action Order_04282020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Amended%20Corrective%20Action%20Order_04282020_text.pdf

220191002H_Closure Letter_09062023_(19-166438S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Closure%20Letter_09062023_(19-166438S).pdf

220191002H_Closure Letter_09062023_(19-166438S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Closure%20Letter_09062023_(19-166438S)_text.pdf

220191002H_Corrective Action Order_08082019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Corrective%20Action%20Order_08082019.pdf

220191002H_Corrective Action Order_08082019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Corrective%20Action%20Order_08082019_text.pdf

220191002H_Second Amended Corrective Action Order_06012020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Second%20Amended%20Corrective%20Action%20Order_06012020.pdf

220191002H_Second Amended Corrective Action Order_06012020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191002H/220191002H_Second%20Amended%20Corrective%20Action%20Order_06012020_text.pdf

220191002H_Corrective Action Order_08082019_text.pdf

August 8, 2019
CORRECTIVE ACTION ORDER
ISSUED WITHOUT PRIOR NOTICE
VIA CERTIFIED MAIL AND FAX TO: 403-231-3920
Mr. William T. Yardley
Executive VP and President
Gas Transmission and Midstream
Enbridge Inc.
1100 Louisiana Street, Suite 300
Houston, Texas 77002
Re: CPF No. 2-2019-1002H
Dear Mr. Yardley:
Enclosed is a Corrective Action Order issued in the above-referenced case to your subsidiary,
Texas Eastern Transmission, LP, to take certain corrective actions with respect to Line 15, which
failed on August 1, 2019, near Danville Kentucky, and the adjacent Lines 10 and 25. Service is
being made by certified mail and facsimile. Service of the Corrective Action Order by electronic
transmission is deemed complete upon transmission and acknowledgement of receipt, or as
otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are
effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
or Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA
Mr. Rick Kivela, Manager, Operational Compliance, Enbridge Inc.



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Texas Eastern Transmission, LP, ) CPF No. 2-2019-1002H
a subsidiary of Enbridge Inc., )
)
)
)
Respondent. )
____________________________________)
CORRECTIVE ACTION ORDER
Purpose and Background:
This Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112,
to require Texas Eastern Transmission, LP (TETLP or Respondent), to take the necessary
corrective action to protect the public, property, and the environment from potential hazards
associated with the recent gas transmission pipeline failure on TETLP’s 30-inch Line 15 near
Danville, Kentucky (Failure).
On August 1, 2019, an incident occurred on Line 15, resulting in the release of approximately 66
million cubic feet of natural gas, which ignited and resulted in the death of one person and the
hospitalization of six others. The resulting fire also destroyed multiple structures and burned
vegetation over approximately 30 acres of land. Pursuant to 49 U.S.C. § 60117, the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated
an investigation of the accident. The National Transportation Safety Board (NTSB) is now
leading the investigation. The preliminary findings of PHMSA’s ongoing investigation are as
follows.
Preliminary Findings:
 TETLP is a wholly-owned subsidiary of Spectra Energy Partners, LP, which is in turn a
wholly-owned subsidiary of Enbridge Inc. (Enbridge), which is based in Calgary,
Alberta, Canada.1 TETLP operates an approximately 9,100-mile pipeline system,
transporting natural gas from the northeastern United States to the Gulf Coast Region.
1 Enbridge Inc. website, available at
https://www.enbridge.com/~/media/Enb/Documents/Investor%20Relations/Texas%20Eastern%20Transmission/TE
TLP%20Q1%202019%20Financial%20Statements%20-%20Final.pdf?la=en (last accessed August 6, 2019).



CPF No. 2-2019-1002H
Page 2
 TETLP’s system transports natural gas to and through Texas, Louisiana, the Gulf of
Mexico, Mississippi, Arkansas, Missouri, Tennessee, Illinois, Indiana, Kentucky, Ohio,
Pennsylvania, New Jersey, and New York.
 The failed pipeline (Line 15 or Affected Segment) is a component of the above-reference
TETLP system. It is a 775-mile long, 30-inch diameter, bi-directional pipeline that
transports natural gas between Kosciusko, Mississippi and Uniontown, Pennsylvania.
Line 15 is one of three parallel TETLP pipelines running in a common corridor near the
site of the Failure. The other two TETLP pipelines are the 30-inch Line 10 and the
30/36-inch Line 25. At the Failure Site, Line 15 is the middle of the three pipelines. The
Failure occurred near MP 423.4, approximately 6 miles south of Danville, Kentucky
(Failure Site), on the Danville to Tompkinsville portion of the Affected Segment.
 Line 15 was constructed beginning in 1942. The portion of Line 15 at the Failure Site
consists of 0.375-inch wall thickness, American Petroleum Institute X-52 grade pipe,
manufactured by A.O. Smith using flash welding, and is coated with coal tar enamel.
The line is cathodically protected with impressed current.
 Line 15 is a bi-directional pipeline. The maximum allowable operating pressure (MAOP)
of Line 15 is dependent on flow direction. When flowing south-to-north, the MAOP is
1000 psig, established as 76.92 percent of the specified minimum yield strength (SMYS)
of Line 15. When flowing north-to-south, the MAOP is 936 psig, established as 72
percent of the SMYS. When first constructed, Line 15 flowed south-to-north. In 2014,
TETLP reversed the flow to north-to-south. At the time of the Failure, Line 15 was
flowing north-to-south and was operating at 925 psig.
 It is estimated that approximately 66 million cubic feet of natural gas was released by the
Failure.
 The Failure occurred at approximately 1:24 a.m. EDT. At approximately 1:25 am,
Enbridge’s Gas Control in Houston, Texas, received a rate of change alarm on Line 15 on
the south side of Danville Compressor Station and during the ensuing minutes, received
reports from the public of a fire in the area south of Danville Compressor Station. A
Danville Compressor Station operator also received a rate of change alarm and observed
the rupture fire from the window of the compressor station control room. During the
ensuing minutes, other Enbridge employees confirmed the reported fire, indicating the
failure of Line 15.
 TETLP’s Danville Compressor Station personnel closed the Line 15 discharge valve
located north of the Failure Site. TETLP field personnel responded by closing the Line
15 Main Line Block Valve located at Valve Site #4 (MP 408.48), located south of the
Failure Site. Following confirmation of the Failure, Enbridge further isolated a portion
(Isolated Segment) of the Affected Segment by closing Valve 15-382 at MP 408.48 and
Valve 15-393 at the Danville Compressor Station near MP 427.5. Enbridge also shut
down and shut in Lines 10 and 25, which are blocked in between the Danville
Compressor Station and the Tompkinsville Compressor Station.



CPF No. 2-2019-1002H
Page 3
 The Failure resulted in the ejection of an approximately 30-foot long section of Line 15,
which landed approximately 460 feet from the Failure Site. Additionally, the Failure
resulted in a 50-foot long, 35-foot wide, 13-foot deep crater at the Failure Site. Gas
released from the Failure ignited, causing a fire that resulted in the death of one person,
the hospitalization of six people, and the destruction of several nearby homes and other
structures. Railroad tracks operated by Norfolk Southern Corporation (NSC) were also
damaged by the fire. NSC temporarily suspended rail service through the area. The fire
also scorched or burned approximately 30 acres of land, resulting in numerous burned
trees and grass.
 Fire fighters from the Lincoln County were the first responders to arrive at the Failure
Site. Other local fire departments responded to this event and evacuated approximately
75 people from the nearby Indian Camp subdivision. Casey County emergency medical
services transported one injured person to Ephraim McDowell emergency medical center
and Boyle County emergency medical services transported 2 injured persons to the same
emergency medical center. Other injured persons were self-transported to medical
centers.
 The Affected Segment contains an as-yet-to-be-determined amount of A.O. Smith-
manufactured pipe of similar vintage and type to the pipe involved in the Failure. At this
time, the actual cause of the Failure has not been determined. The origin of the Failure
has been identified and the specimen pipe is under control of the NTSB. NTSB and
PHMSA investigators are collecting information related to potential causal factors and
circumstances that may have led to the Failure. The NTSB will conduct a metallurgical
investigation to determine the exact cause.
 Lines 10 and 25 run on either side of Line 15 in the immediate vicinity of the Failure
Site. At this time, the possibility of damage to Lines 10 and 25 from the concussive force
of the Failure or of thermal damage from the resulting fire cannot be ruled out.
 On November 2, 2003, Line 15 failed at MP 501.72 near Morehead, Kentucky, between
the Danville Compressor Station and the Owingsville Compressor Station to the north of
the Danville Compressor Station. The 2003 failure also occurred on A.O. Smith-
manufactured pipe, and resulted from interactions between hard spots and mid-wall
lamination, and in PHMSA’s predecessor agency issuing a Corrective Action Order to
TETLP’s predecessor entity on November 6, 2003, in CPF 2-2003-1018H.
 TETLP reported that it performed an in-line inspection (ILI) to detect hard spots on Line
15 in 2011. The company also reported that it ran an ILI with a magnetic flux leakage
tool in 2018 and an ILI with a dent and inertial measurement unit tool in 2019. The 2018
tool data indicated a small dent with metal loss that did not require action under federal
pipeline safety regulations or TETLP’s procedures. The results of the 2019 ILIs have not
yet been provided to PHMSA.



CPF No. 2-2019-1002H
Page 4
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous and requiring corrective action, is
set forth both in the above-referenced statute and 49 C.F.R. § 190.233.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
Affected Segment and the two other adjacent TETLP pipelines, Line 10 and Line 25, without
corrective measures is or would be hazardous to life, property, or the environment. The adjacent
lines could potentially have been affected by the Failure and that, accordingly, should not be
restarted without further investigation. At this time, the risk of concussive force or thermal
damage to the adjacent lines cannot be ruled out. In addition, having considered the
uncertainties of the cause of the Failure, the pressure at which gas is transported, the vintage and
type of pipe, the risk of fire to the environment and populated areas in the vicinity of the
Affected Segment, and the potential damage to the two adjacent TETLP pipelines, I find that a
failure to issue this Order expeditiously to require immediate corrective action would result in
the likelihood of serious harm to life, property, or the environment.
Accordingly, this Order mandating immediate corrective action is issued without prior notice and
opportunity for a hearing. The terms and conditions of this Order are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may contest its issuance and obtain
expedited review either by answering in writing or requesting a hearing under 49 C.F.R.
§ 190.211, to be held as soon as practicable under the terms of such regulation, by notifying the
Associate Administrator for Pipeline Safety in writing, with a copy to the Director, Eastern
Region, PHMSA (Region Director). If Respondent requests a hearing, it will be held
telephonically or in-person in Atlanta, Georgia, or Washington, D.C, unless a different location
is expressly agreed-to in writing by the Director.
After receiving and analyzing additional data in the course of this investigation, PHMSA
may identify other corrective measures that need to be taken on the Affected Segment or
other pipelines in the TETLP system. In that event, PHMSA will notify Respondent of any
additional measures that are required and an amended Order will be issued, if necessary. To the
extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.



CPF No. 2-2019-1002H
Page 5
Required Corrective Actions:
Definitions:
Affected Segment means the approximately 775-mile long, 30-inch diameter Line
15 that transports natural gas between Kosciusko, Mississippi and Uniontown,
Pennsylvania.
Isolated Segment means the approximately 19 miles of the Affected Segment
between the Danville Compressor Station at MP 427.5 and Valve 15-382 at MP
408.48. It is the portion of the Affected Segment that was shut-in after the Failure
on August 1, 2019, by closing main-line valves upstream and downstream of the
Failure Site and that remains shut-in as of the date of this Order.
Director means the Director, Southern Region, Office of Pipeline Safety,
PHMSA.
Pursuant to 49 U.S.C. § 60112, I hereby order Texas Eastern Transmission, LP to immediately
take the following corrective actions for the Affected Segment, Line 10, and Line 25:
1. Shutdown of Isolated Section. Texas Eastern Transmission, LP (TETLP) must not
operate the Isolated Segment or Lines 10 and 25 until authorized to do so by the Director
2. Operating Pressure Restriction. With respect to the remainder of the Affected Segment
not shut down under Item 1, above, TETLP must reduce and maintain a twenty percent
(20%) pressure reduction in the actual operating pressure along the entire length of the
Affected Segment such that the operating pressure along the Affected Segment will not
exceed eighty percent (80%) of the actual operating pressure in effect immediately prior
to the Failure.
(A)This pressure restriction is to remain in effect until the Director provides written
approval for TETLP to either increase the pressure or return the pipeline to its
pre-Failure operating pressure.
(B) By August 21, 2019, TETLP must provide the Director the actual operating
pressures of each compressor station and each main line pressure regulating
station on the Affected Segment at the time of Failure and the reduced pressure
restriction set-points at these same locations.
(C) This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-pressure
devices to be adjusted accordingly.
(D)When determining the pressure restriction set-points, TETLP must take into
account any ILI features or anomalies present in the Affected Segment to provide
for continued safe operation while further corrective actions are completed.



3. CPF No. 2-2019-1002H
Page 6
(E) TETLP must review the pressure restriction monthly by analyzing the operating
pressure data. TETLP must take into account any ILI features or anomalies
present in the Affected Segment and immediately reduce the operating pressure to
maintain the safe operations of the Affected Segment, if warranted by the monthly
review. TETLP must submit the results of the monthly review to the Director.
The results must include, at a minimum, the current discharge set-points
(including any additional pressure reductions), and any pressure exceedance at
discharge set-points.
Restart Plan. Prior to resuming operation of the Isolated Segment, TETLP must develop
and submit a written Restart Plan to the Director for prior approval.
(A)The Director may approve the Restart Plan incrementally without approving the
entire plan but the Isolated Segment cannot resume operation until the Restart
Plan has been approved in its entirety.
(B) Once approved by the Director, the Restart Plan will be incorporated by reference
into this Order.
(C) The Restart Plan must provide for adequate patrolling of the Isolated Segment
during the restart process and must include incremental pressure increases during
start up, with each increment to be held for at least two hours.
(D)The Restart Plan must include sufficient surveillance of the pipeline during each
pressure-increase increment to ensure that no leaks are present when operation of
the line resumes.
(E) The Restart Plan must specify a day-light restart and include advance
communications with local emergency response officials.
(F) The Restart Plan must provide for a review of the Isolated Segment for conditions
similar to those surrounding the Failure including a review of construction,
operating and maintenance (O&M) and integrity management records such as ILI
results, hydrostatic tests, root cause failure analysis of prior failures, aerial and
ground patrols, corrosion, cathodic protection, excavations and pipe replacements.
TETLP must address any findings that require remedial measures to be
implemented prior to restart.
(G)The Restart Plan must also include documentation of the completion of all
mandated actions, and a management of change plan to ensure that all procedural
modifications are incorporated into TETLP’s operations and maintenance
procedures manual.
(H)Procedures for the exposure, testing, and repair of Line 15 must include:
i. Exposure of Line 15 extending for at least two girth welds on either side
of the Failure Site to examine for corrosion, coating condition, concussive
damage, and thermally-impacted areas. If damage to the exposed pipe is
discovered, TETLP must expose additional pipe until at least 10 feet of



CPF No. 2-2019-1002H
Page 7
undamaged pipe is exposed and examined. TETLP must perform safe
operating-pressure calculations and remediation for any anomalies or
threat found, using permanent repair methods and design factors based
upon 49 C.F.R. §§ 192.713 and 192.111 and using ASME/ANSI B31G or
R STRENG methods. TETLP must repair or replace pipe or coating, as
necessary. Upon completion of pipe replacement and repairs, TETLP
must provide proper backfill and protection from stones and rocks,
pursuant to procedures developed under this Order;
ii. Establishment of adequate cathodic protection for the area where the
Failure occurred. TETLP must replace any damaged rectifier(s) and must
re-establish the electrical test station at the railroad crossing. Once
backfill and land settling have occurred, TETLP must ensure pipe-to-soil
readings are within applicable criteria; and
iii. Development of additional requirements for remediation and the eventual
restart for Line 15 as the investigation yields more information about the
cause of the Failure and the condition of the Affected Segment.
(I) Procedures for the exposure, examination, remediation, and restart of Lines 10
and 25 must include:
i. Development of assessment, remediation, and restart plans that are aligned
with the criteria show immediately below;
ii. Exposure of Lines 10 and 25, extending for at least two girth welds in both
directions from the Failure location. TETLP must examine the girth welds
and pipeline coating materials for damage caused by thermal and
concussive forces. TETLP must continue a broader exposure of each line
if associated damage is discovered, until 10 feet of undamaged pipe is
reached and verified. Any needed repairs are to be guided by established
Enbridge procedures and safe operating-pressure calculations and the
remediation for any pits or other forms of anomalies found, using
engineering permanent repair methods and design factors based upon 49
C.F.R. §§ 192.713 and 192.111 and using ASME/ANSI B31O or R-
STRENG methods. TETLP must repair or replace pipe or coating, as
necessary. Upon completion of pipe replacement and repairs, and provide
proper backfill and protection from stones and rocks, all pursuant to
Enbridge's established procedures;
iii. Restarts for each individual line in pressure-increase increments, at 25%,
50%, and 80%, with each increment held for at least one hour after
pressure stabilization. After reaching 80% pressure, Respondent must
obtain specific individual written approval from the Director to increase
pressure to pre-Failure normal pressure. Respondent must obtain separate
approval for each pipe (Lines 10 and 25) before increasing pressure to the
final normal operating pressure; and



4. 5. 6. 7. 8. CPF No. 2-2019-1002H
Page 8
iv. A ground-level, instrumented leak survey on Lines 10 and 25, for a
distance of two miles in both directions from the Failure Site. TETLP
must investigate any elevated readings and make all appropriate repairs.
Return to Service. After the Director approves the Restart Plan, TETLP may return the
Isolated Segment to service but the operating pressure must not exceed 80% of the actual
operating pressure in effect immediately prior to the Failure, in accordance with Item 2
above.
Removal or Modification of Pressure Restriction. The pressure restriction required by
the above Items may be removed or modified, as follows:
(A)The Director may allow the removal or modification of the pressure restriction
upon a written request from TETLP demonstrating that restoring the pipeline to
its pre-Failure operating pressure is justified based on a reliable engineering
analysis showing that the pressure increase is safe considering all known defects,
anomalies, and operating parameters of the pipeline.
(B) The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from TETLP demonstrating that temporary
mitigative and preventive measures are being implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director's
determination will be based on the Failure cause and provision of evidence that
preventive and mitigative actions taken by TETLP provide for the safe operation
of the Affected Segment during the temporary removal or modification of the
pressure restriction. Appeals to determinations of the Director in this regard will
be decided by the Associate Administrator for Pipeline Safety.
Instrumented Leakage Survey. Within 180 days of receipt of this Order, TETLP must
perform an aerial or ground instrumented leakage survey of the Affected Segment.
TETLP must investigate all leak indications and remedy all leaks discovered. TETLP
must submit documentation of this survey to the Director within 45 days of the
completion of the leak survey.
Records Verification. As recommended in PHMSA Advisory Bulletin 2012-06, verify
the records for the Affected Segment to confirm the maximum allowable operating
pressure (MAOP). The Affected Segment is bi-directional with two different MAOPs.
TETLP must confirm the MAOPs for both flow directions. TETLP must submit
documentation of this records verification to the Director within 45 days of receipt of this
Order.
Review of Prior ILI Results. Within 30 days of receipt of this Order, conduct a review
of the previous ILI results of the Affected Segment. TETLP must re-evaluate all ILI
results from the past 20 calendar years, include a review of the ILI vendors' raw data and
analysis. TETLP must determine whether any features were present in the failed pipe
joint and/or any other pipe removed. Also, TETLP must determine if any features are
present elsewhere on the Affected Segment. TETLP must submit documentation of this
ILI review to the Director within 45 days of receipt of this Order as follows:



CPF No. 2-2019-1002H
Page 9
(A)List all ILI tool runs, tool types, and the calendar years of the tool runs.
(B) List, describe (type, size, wall loss, etc.), and identify the specific location of all
ILI features present in the failed joint and/or other pipe removed.
(C) Explain the process used to review the ILI results and the results of the
reevaluation.
9. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing, including
failure analysis will be performed by the NTSB in accordance with NTSB procedures and
protocols. In the event the NTSB does not perform these functions, TETLP will be
responsible for completing all testing and analysis. If the NTSB does not perform the
analysis, TETLP must submit to the Director for prior approval a plan to complete the
testing and analysis.
10. Root Cause Failure Analysis. The NTSB will perform a root cause failure analysis
(RCFA) to determine the cause of the Failure. TETLP must incorporate the findings the
NTSB RCFA into its integrity management plan and operations and maintenance manual.
If the NTSB does not perform these tasks, TETLP must submit to the Director for prior
approval a plan to complete an RCFA.
11. Emergency Response Plan and Training Review. TETLP must review and assess the
effectiveness of its emergency response plan and operational actions with regards to the
Failure. TETLP must include in the review and assessment the on-scene response and
support, coordination, and communication with emergency responders and public
officials. Also, TETLP must include a review and assessment of the effectiveness of its
emergency training program. TETLP must amend its emergency response plan and
emergency training, if necessary, to reflect the results of this review. The documentation
of this Emergency Response Plan and Training Review must be included in the CAO
Documentation Report (see Item 14 for description of the CAO Documentation Report).
12. Public Awareness Program Review. TETLP must review and assess the effectiveness of
its Public Awareness Program with regards to the Failure. TETLP must amend its Public
Awareness Program, if necessary, to reflect the results of this review. The documentation
of this Public Awareness Program Review must be provided to the Director.
13. Remedial Work Plan (RWP).
(A)Within 90 days following receipt of this Order, TETLP must submit a Remedial
Work Plan (RWP) to the Director for approval.
(B) The Director may approve the RWP incrementally without approving the entire
RWP.
(C) Once approved by the Director, the RWP will be incorporated by reference into
this Order.
(D)The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures TETLP will use to verify the integrity of the Affected



CPF No. 2-2019-1002H
Page 10
Segment. The RWP must address all known or suspected factors and causes of
the Failure. TETLP should consider both the risks and consequences of another
failure arising from the same root cause as the August 1, 2019 Failure to develop
a prioritized schedule for RWP related work along the Affected Segment.
(E) The RWP must include a procedure or process to:
i. Identify pipe in the Affected Segment with characteristics similar to the
contributing factors identified for the Failure.
ii. Gather all data necessary to review the failure history (in service and
pressure test failures) of the Affected Segment and to prepare a written
report containing all the available information such as the locations, dates,
and causes of leaks and failures.
iii. Integrate the results and conclusions of the NTSB’s metallurgical testing
and RCFA, and other corrective actions required by this Order with all
relevant pre-existing operational and assessment data for the Affected
Segment. Pre-existing operational data includes, but is not limited to,
construction, operations, maintenance, testing, repairs, prior metallurgical
analyses, and any third-party consultation information. Pre-existing
assessment data includes, but is not limited to, ILI tool runs, hydrostatic
pressure testing, direct assessments, close interval surveys, and
DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to the Failure are
likely to exist elsewhere on the Affected Segment.
v. Conduct additional field tests, inspections, assessments, and/or evaluations
to determine whether, and to what extent, the conditions associated with
the Failure, and other failures from the failure history (see Item 13(E)(ii),
above) or any other integrity threats are present elsewhere on the Affected
Segment. At a minimum, this process must consider all failure causes and
specify the use of one or more of the following:
a. Inline inspection (ILI) tools that are technically appropriate for
assessing the pipeline system based on the cause of Failure, and
that can reliably detect and identify anomalies,
b. Hydrostatic pressure testing,
c. Close-interval surveys,
d. Cathodic protection surveys, to include interference surveys in
coordination with other utilities (e.g. underground utilities,
overhead power lines, etc.) in the area,
e. Coating surveys,



CPF No. 2-2019-1002H
Page 11
f. Stress corrosion cracking surveys,
g. Selective seam corrosion surveys; and,
h. Other tests, inspections, assessments, and evaluations appropriate
for the failure causes.
Note: TETLP may use the results of previous tests, inspections,
assessments, and evaluations if approved by the Director, provided
the results of the tests, inspections, assessments, and evaluations
are analyzed with regard to the factors known or suspected to have
caused the Failure.
vi. Describe the inspection and repair criteria TETLP will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other
identified integrity threats. Include a description of how any defects will
be graded and a schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Segment,
describe the methods TETLP will use to repair, replace, or take other
corrective measures to remediate the conditions associated with the
pipeline Failure, and to address other known integrity threats along the
Affected Segment. The repair, replacement, or other corrective measures
must meet the criteria specified in Item 13(E)(iv), above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Segment
considering the results of the analyses, inspections, evaluations, and
corrective measures undertaken pursuant to the Order.
ix. Implement specific actions TETLP will take on its entire pipeline system
as a result of the lessons learned from work on this Order. Incorporate
lessons learned on TETLP’s entire pipeline system. TETLP will report
lessons learned in the CAO Documentation Report (see Item 14 for
description of the CAO Documentation Report).
(F) TETLP must include a proposed schedule for completion of the RWP.
(G)TETLP must revise the RWP as necessary to incorporate new information
obtained during the NTSB and PHMSA’s failure investigation and remedial
activities taken under this Order, to incorporate the results of actions undertaken
pursuant to this Order, and/or to incorporate modifications required by the
Director.
i. TETLP must submit any plan revisions to the Director for prior approval.
ii. The Director may approve plan revisions incrementally.



CPF No. 2-2019-1002H
Page 12
iii. Any and all revisions to the RWP after it has been approved and
incorporated by reference into this Order will be fully described and
documented in the CAO Documentation Report (CDR).
(H)Implement the RWP as it is approved by the Director, including any revisions to
the plan.
14. CAO Documentation Report (CDR). TETLP must create and revise, as necessary, a
CAO Documentation Report (CDR). When TETLP has concluded all the items in this
Order it will submit the final CDR in its entirety to the Director. This will allow the
Director to complete a thorough review of all actions taken by TETLP with regards to
this Order prior to approving the closure of this Order. The intent is for the CDR to
summarize all activities and documentation associated with this Order in one document.
(A)The Director may approve the CDR incrementally without approving the entire
CDR.
(B) Once approved by the Director, the CDR will be incorporated by reference into
this Order.
(C) The CDR must include but not be limited to:
i. Table of Contents;
ii. Summary of the pipeline Failure, and the response activities;
iii. Summary of pipe data/properties and all prior assessments of the Affected
Segment;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis
required by the Order;
v. Summary of the Mechanical and Metallurgical Testing as required by the
Order;
vi. Documentation of all actions taken by TETLP to implement the RWP, the
results of those actions, and the inspection and repair criteria used;
vii. Documentation of any revisions to the RWP including those necessary to
incorporate the results of actions undertaken pursuant to this Order and
whenever necessary to incorporate new information obtained during the
failure investigation and remedial activities;
viii. Lessons learned while completing this Order;
ix. A description of specific actions TETLP will take on its entire pipeline
system as a result of the lessons learned from work on this Order; and
x. Appendices (if required).



CPF No. 2-2019-1002H
Page 13
Other Requirements:
1. Reporting. Submit monthly reports to the Region Director that: (1) include all available
data and results of the testing and evaluations required by this Order; and (2) describe the
progress of the repairs or other remedial actions being undertaken. The first monthly
report for the period August 1 through August 31 is due on September 15, 2019. The
Region Director may change the interval for the submission of these reports.
2. Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Order. Include in each
monthly report the to-date total costs associated with: (1) preparation and revision of
procedures, studies and analyses; (2) physical changes to pipeline infrastructure,
including repairs, replacements and other modifications; and (3) environmental
remediation, if applicable.
3. Approvals. With respect to each submission requiring the approval of the Region
Director, the Region Director may: (a) approve the submission in whole or in part; (b)
approve the submission on specified conditions; (c) modify the submission to cure any
deficiencies; (d) disapprove the submission in whole or in part and direct Respondent to
modify the submission; or (e) any combination of the above. In the event of approval,
approval upon conditions, or modification by the Region Director, Respondent shall
proceed to take all action required by the submission, as approved or modified by the
Region Director. If the Region Director disapproves all or any portion of a submission,
Respondent must correct all deficiencies within the time specified by the Region Director
and resubmit it for approval.
4. Extensions of Time. The Region Director may grant an extension of time for compliance
with any of the terms of this Order upon a written request timely submitted and
demonstrating good cause for an extension.
5. 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).
In your correspondence on this matter, please refer to “CPF No.2-2019-1002H” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Order are in addition to and do not waive any requirements that apply to
Respondent's pipeline system under 49 C.F.R. Parts 190 through 199, under any other order
issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of
Federal or State law.
Respondent may appeal any decision of the Region Director to the Associate Administrator for
Pipeline Safety. Decisions of the Associate Administrator shall be final.



CPF No. 2-2019-1002H
Page 14
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.
§ 60120.
The terms and conditions of this Corrective Action Order are effective upon service in
accordance with 49 C.F.R. § 190.5.
August 8, 2019
__________________________________ __________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

220191002H_Closure Letter_09062023_(19-166438S)_text.pdf

VIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com;
Nathan.Atanu@enbridge.com; Thomas.Wooden@enbridge.com;
andy.drake@enbridge.com; Sherif.Hassanien@enbridge.com
September 6, 2023
Texas Eastern Transmission, LP
Cynthia Hansen, President
915 North Eldridge Parkway
Houston, Texas 77079
RE: CPF 2-2019-1002H
Dear Ms. Hansen:
On August 8, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Texas Eastern Transmission, LP a Corrective Action Order in the above-referenced case. This
Order included a requirement to take corrective actions on your pipeline. Based on our review of
the documentation you provided, it has been determined that you have complied with the terms of
this Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
James A. Urisko
Director, Office of Pipeline Safety
PHMSA, Southern Region

220191002H_Second Amended Corrective Action Order_06012020_text.pdf

SECOND AMENDED CORRECTIVE ACTION ORDER
ISSUED WITHOUT PRIOR NOTICE
VIA ELECTRONIC MAIL TO: william.yardley@enbridge.com
William T. Yardley
Executive Vice President and President
Gas Transmission and Midstream
Enbridge, Inc.
5400 Westheimer Court
Houston, Texas 77056
Re: CPF No. 2-2019-1002H
Dear Mr. Yardley:
Enclosed is a Second Amended Corrective Action Order issued in the above-referenced case to
your subsidiary, Texas Eastern Transmission, LP. It requires certain corrective actions that need
to be taken with respect to Lines 10, 15 and 25 for failures on August 1, 2019, near Danville,
Kentucky, and May 4, 2020, near Hillsboro, Kentucky. Service of the Second Amended
Corrective Action Order by electronic mail is deemed complete upon transmission and
acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and
conditions of this Second Amended Order are effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA
Ms. Mary McDaniel, Director Southwest Region, Office of Pipeline Safety, PHMSA
Mr. Rick Kivela, Manager, Operational Compliance, Enbridge, rick.kivela@enbridge.com
Ms. Catherine Little, Counsel, Troutman Sanders, LLP, catherine.little@troutman.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Texas Eastern Transmission, LP, ) CPF No. 2-2019-1002H
a subsidiary of Enbridge, Inc., )
)
)
)
Respondent. )
____________________________________)
SECOND AMENDED CORRECTIVE ACTION ORDER
Purpose and Background:
This Second Amended Corrective Action Order (Second Amended Order) is being issued under
the authority of 49 U.S.C. § 60112, to require Texas Eastern Transmission, LP (TETLP or
Respondent), to take necessary corrective actions to protect the public, property, and the
environment from potential hazards associated with the gas transmission pipeline failures on
TETLP’s 30-inch Line 15 near Danville, Kentucky (Failure 1) and its 30-inch Line 10 near
Hillsboro, Kentucky (Failure 2).
Failure 1: On August 1, 2019, an incident occurred on Line 15, resulting in the release of
approximately 66 million cubic feet of natural gas (MMCF), which ignited and resulted in the
death of one person and the hospitalization of six others. The resulting fire also destroyed
multiple structures and burned vegetation over approximately 30 acres of land. Pursuant to 49
U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office
of Pipeline Safety (OPS), initiated an investigation of the accident. The National Transportation
Safety Board (NTSB) is now leading the investigation.
On August 8, 2019, PHMSA issued a Corrective Action Order to TETLP requiring it to take
certain corrective actions with respect to Line 15 and the adjacent Lines 10 and 25. On April 28,
2020, PHMSA issued an Amended Corrective Action Order (Amended Order) requiring certain
corrective actions with respect to Line 15.
Failure 2: On May 4, 2020, an incident occurred on Line 10, resulting in the release of
approximately 52 MMCF of natural gas which ignited. Reports and media video identified large
fireballs in the area of the failure, a heavily wooded, rural location with one road into the site.
Pursuant to 49 U.S.C. § 60117, the PHMSA, OPS, initiated an investigation of the incident.
NTSB has also initiated an investigation into this failure.



CPF No. 2-2019-1002H
Page 2
The purpose of these amendments is to update the terms of the Amended Corrective Action
Order to address the May 4, 2020 failure.
The second amended preliminary findings of PHMSA’s ongoing investigation are as follows:
Second Amended Preliminary Findings:
 TETLP is a wholly-owned subsidiary of Spectra Energy Partners, LP, which is, in turn, a
wholly-owned subsidiary of Enbridge, Inc. (Enbridge), which is based in Calgary,
Alberta, Canada.1 TETLP operates an approximately 9,100-mile pipeline system,
transporting natural gas from the northeastern United States to the Gulf Coast Region.
 TETLP’s system transports natural gas to and through Texas, Louisiana, the Gulf of
Mexico, Mississippi, Arkansas, Missouri, Tennessee, Illinois, Indiana, Kentucky, Ohio,
Pennsylvania, New Jersey, and New York.
Failure 1: August 1, 2019 near Danville, Kentucky
 The failed pipeline (Line 15) is a component of the above-referenced TETLP system. It
is a 775-mile long, 30-inch diameter, bi-directional pipeline that transports natural gas
between Kosciusko, Mississippi and Union Township, Pennsylvania. Line 15 is one of
three parallel TETLP pipelines running in a common corridor near the site of Failure 1.
The other two TETLP pipelines are the 30-inch Line 10 and the 30/36-inch Line 25. At
the Failure 1 Site, Line 15 is the middle of the three pipelines. Failure 1 occurred near
Mile Post (MP) 423.4, approximately 4.5 miles south of Danville, Kentucky, on the
Danville to Tompkinsville portion of the Line 15 (Failure 1 Site).
 Line 15 was constructed beginning in 1957. The portion of Line 15 at the Failure 1 Site
consists of 0.375-inch wall thickness, American Petroleum Institute X-52 grade pipe,
manufactured by A.O. Smith using flash welding, and is coated with coal tar enamel.
The line is cathodically protected with impressed current.
 Line 15 originally flowed south-to-north, with a maximum allowable operating pressure
(MAOP) of 1000 psig, established as 76.92 percent of the specified minimum yield
strength (SMYS). In 2014, TETLP reversed the flow to north-to-south, and the MAOP
was reestablished as 936 psig, or 72 percent of the SMYS, commensurate with
49 C.F.R. § 192.105. At the time of Failure 1, Line 15 was flowing north-to-south and
was operating at 925 psig.
 It is estimated that approximately 66 million cubic feet of natural gas was released as a
result of Failure 1.
 Failure 1 occurred at approximately 1:24 a.m. EDT. At approximately 1:25 am,
Enbridge’s Gas Control in Houston, Texas, received a rate of change alarm on Line 15 on
the south side of Danville Compressor Station and during the ensuing minutes, received
1 Enbridge, Inc., website, available at
https://www.enbridge.com/~/media/Enb/Documents/Investor%20Relations/Texas%20Eastern%20Transmission/TE
TLP%20Q1%202019%20Financial%20Statements%20-%20Final.pdf?la=en (last accessed April 22, 2020).



CPF No. 2-2019-1002H
Page 3
reports from the public of a fire in the area south of Danville Compressor Station. A
Danville Compressor Station operator also received a rate of change alarm and observed
the rupture fire from the window of the compressor station control room. During the
ensuing minutes, other Enbridge employees confirmed the reported fire, indicating the
failure of Line 15.
 TETLP’s Danville Compressor Station personnel closed the Line 15 discharge valve
located north of the Failure 1 Site. TETLP field personnel responded by closing the Line
15 Main Line Block Valve located at Valve Site #4 (MP 408.48), located south of the
Failure 1 Site. Following confirmation of Failure 1, Enbridge further isolated a portion of
Line 15 by closing Valve 15-382 at MP 408.48 and Valve 15-393 at the Danville
Compressor Station near MP 427.5. Enbridge also shut down and shut in Lines 10 and
25, which were blocked in between the Danville Compressor Station and the
Tompkinsville Compressor Station.
 Failure 1 resulted in the ejection of an approximately 30-foot long section of Line 15,
which landed approximately 481 feet from the Failure 1 Site. Additionally, Failure 1
resulted in a 43-foot long, 30-foot wide, 10-foot deep crater at the Failure 1 Site. Gas
released from Failure 1 ignited, causing a fire that resulted in the death of one person, the
hospitalization of six people, and the destruction of several nearby homes and other
structures. Railroad tracks operated by Norfolk Southern Corporation (NSC) were also
damaged by the fire. NSC temporarily suspended rail service through the area. The fire
also scorched or burned approximately 30 acres of land, resulting in numerous burned
trees and grass.
 Fire fighters from the Lincoln County were the first responders to arrive at the Failure 1
Site. Other local fire departments responded to this event and evacuated approximately
75 people from the nearby Indian Camp subdivision. Casey County emergency medical
services transported one injured person to Ephraim McDowell emergency medical center
and Boyle County emergency medical services transported two injured persons to the
same emergency medical center. Other injured persons were self-transported to medical
centers.
 Line 15 contains approximately 353 miles of A.O. Smith-manufactured pipe of similar
vintage and type to the pipe involved in Failure 1. The origin of Failure 1 was identified
and the specimen pipe is under control of the NTSB. NTSB and PHMSA investigators
collected information related to potential causal factors and circumstances that may have
led to Failure 1. The NTSB will conduct a metallurgical investigation to determine the
exact cause.
 Lines 10 and 25 run on either side of Line 15 in the immediate vicinity of the Failure 1
Site. Lines 10 and 25 were evaluated and determined to have suffered no damage from
the concussive force or thermal damage resulting from Failure 1.
 Following TETLP’s analysis, PHMSA approved a return to MAOP for Lines 10 and 25
on August 30, 2019, and August 23, 2019, respectively.



CPF No. 2-2019-1002H
Page 4
 On November 2, 2003, Line 15 failed at MP 501.72 near Morehead, Kentucky, between
the Danville Compressor Station and the Owingsville Compressor Station to the north of
the Danville Compressor Station. The 2003 failure also occurred on A.O.
Smith-manufactured pipe, and resulted from interactions between hard spots and mid-
wall lamination, and in PHMSA’s predecessor agency issuing a Corrective Action Order
to TETLP’s predecessor entity on November 6, 2003, in CPF No. 2-2003-1018H.
 TETLP reported that it performed an in-line inspection (ILI) to detect hard spots on
Line 15 in 2011. The company also reported that it ran an ILI with a magnetic flux
leakage tool in 2018 and an ILI with a dent and inertial measurement unit tool in 2019.
The 2018 tool data indicated a small dent with metal loss that did not require action under
federal pipeline safety regulations or TETLP’s procedures.
 The 2011 hard spot in-line inspection of Line 15 resulted in no evidence of hard spot
indications. A 2019 post-incident review of the same hard spot in-line inspection data
revealed ten hard spots located in the failed pipe joint. Further analysis revealed the
location of the Line 15 failure origin coincided with the locations of two newly
discovered hard spot indications.
Failure 2: May 4, 2020 near Hillsboro, Kentucky
 The failed pipeline (Line 10) is a component of the above-referenced TETLP system. On
the afternoon of May 4, 2020, the TETLP controllers observed a pressure drop from 654
psig to 0 psig. Upon investigation, the operator’s personnel discovered a rupture on Line
10. The rupture resulted in the release of 51,676 MCF (52 MMCF) of natural gas which
ignited. Reports and media video identified large fireballs in the area of failure, a heavily
wooded, rural location with one road into the site. The failure resulted in a crater of an
estimated 20 feet in diameter with residual gas burning as of 10 p.m. on May 4, 2020
(Failure 2 Site).
 Immediately following the pressure drop, TETLP personnel isolated Line 10 at 5:05 PM,
and subsequently isolated and depressurized Line 15 and Line 25. Suspecting a rupture,
crews were deployed to investigate the site. An aerial patrol was conducted to fly over the
site of the failure to confirm any nearby structures and impacted area.
 The site is located approximately 1.75 miles west of HWY 32 and 3.18 miles north east
of Hillsboro, Kentucky, the coordinates (lat/long) are 38.302493, -83.601636.
 Line 10 is a bi-directional flow, approximately 774.76 miles in length, 30-inch diameter,
pipeline that transports natural gas between Kosciusko, Mississippi and North Union
Township, Pennsylvania. The line’s original MAOP was established at 1139 psig. At the
time of Failure 2, Line 10 was operating at 954 psig. It shares a common corridor along
with Lines 15 and 25.
 Line 25 is a bi-directional flow, approximately 775.18 miles in length, 30/36-inch
diameter pipeline that runs from Kosciusko, Mississippi and North Union Township,
Pennsylvania.



CPF No. 2-2019-1002H
Page 5
 Line 10 was constructed beginning in 1952. The portion of Line 10 at the Failure 2 Site
consists of 0.375-inch wall thickness, API X-52 grade pipe, and is coated with coal tar
enamel. The line is cathodically protected with impressed current.
 The failed pipe is currently shut in and Lines 15 and 25 were depressurized and isolated.
Line 25 returned to service at a reduced pressure on May 26, 2020.
 The preliminary failure cause appears to be due to land movement, and seems to originate
on a girth weld in a right of way (ROW) containing a slip shelf, cracks, natural springs
and trees with S shape trunks.
 Line 10 traverses similar land conditions along the length of the pipeline. The potential
environmental impacts include damage to trees and grass due to failure fire. Lines 10,
15, and 25 traverse through several states and within close proximity to houses and other
structures involving human occupancy. The issue of land-movement is potentially
systemwide as evidenced by inertial measurement unit testing already completed by the
operator. The ROW for Lines 10, 15, and 25 contains many hills/slopes from north of
Nashville through Kentucky and into Southwestern Ohio. Northern Kentucky and
Southeastern Ohio have shown to be the worst areas for slippage.
 On January 21, 2019, Line 10 also failed in Noble County, Ohio. The line was operating
in a north to south flow at the time of the failure. A DNV lab report indicated the failure
of the girth weld “was a result of ductile overload from a longitudinal tensile or bending
force that exceeded the load carrying capacity of the weld.” The DNV report went on to
conclude that the “ductile overload” was the result of unintended land movement.
Further, DNV’s analysis revealed two incomplete penetration flaws on the fracture
surface.
 Following the January 21, 2019 failure in Ohio, TETLP established a program using ILI
tools with inertial mapping capability to assess Lines 10, 15, and 25 for additional areas
subject to strain from unintended land movement. Initial results from these assessments
indicated potential areas of strain due to unintended land movement along Lines 10 and
15 in the vicinity of Failure 2, and no indications of strain along Line 25 in the same area.
The referenced area was scheduled for remediation, along with several other areas along
the common ROW.
 TETLP submitted a Safety Related Condition (SRC) Report on March 25, 2020, for Line
25 due to land movement causing a deflection of 7 feet along a length of about 10 feet of
the pipeline. The SRC location is 220 miles northeast on the ROW at MP 721.35 to MP
722.90. Line 25 was isolated and the pressure reduced to zero psig. Per the SRC, the
referenced land movement along Line 25 stemmed from a land wall mining operation in
the corridor. TETLP temporarily moved the pipeline above ground and eventually plans
to re-bury the line as a permanent repair. Line 25 lies in a corridor adjacent to Lines 10
and 15.
 On July 29, 2019, Line 10 also failed at MP 658.85 due to material failure of pipe or weld
near Beverly, Ohio. Per the submitted incident report, sub-causes are identified as a dent



CPF No. 2-2019-1002H
Page 6
and crack caused by the pipe being laid on a sharp rock during its original construction.
The failure resulted in a release of 45 MMCF of natural gas. There were no injuries or
fatalities. A total of $514,406 in operator property damage was reported, with no impacts
private or public property.
Determination of Necessity for Second Amended Corrective Action Order and Right to
Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous and requiring corrective action, is
set forth both in the above-referenced statute and 49 C.F.R. § 190.233.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
Affected Segment without corrective measures is or would be hazardous to life, property, or the
environment. In addition, having considered the uncertainties of the cause of the Failure 1, the
pressure at which gas is transported, the vintage and type of pipe, the risk of fire to the
environment and populated areas in the vicinity of the Affected Segment, as well as the apparent
cause of Failure 2 related to land-movement, prior occurrences of failures due to land-movement,
and the similarity of land conditions, I find that a failure to issue this Order expeditiously to
require immediate corrective action would result in the likelihood of serious harm to life,
property, or the environment.
Accordingly, this Second Amended Order mandating immediate corrective action is issued
without prior notice and opportunity for a hearing. The terms and conditions of this Second
Amended Order are effective upon receipt.
Within 10 days of receipt of this Second Amended Order, Respondent may contest its issuance
and obtain expedited review either by answering in writing or requesting a hearing under
49 C.F.R. § 190.211, to be held as soon as practicable under the terms of such regulation, by
notifying the Associate Administrator for Pipeline Safety in writing, with a copy to the Director,
Southern Region, PHMSA (Director). If Respondent requests a hearing, it will be held
telephonically or in-person, if practicable, in Atlanta, Georgia or Washington, D.C, unless a
different location is expressly agreed-to in writing by the Director.
After receiving and analyzing additional data in the course of this investigation, PHMSA
may identify other corrective measures that need to be taken on the Affected Segment or
other pipelines in the TETLP system. In that event, PHMSA will notify Respondent of any
additional measures that are required and a further Amended Order will be issued, if necessary.



CPF No. 2-2019-1002H
Page 7
To the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
Definitions:
Affected Segment means the three parallel bi-directional pipelines operated by
TETLP located within the common ROW that transports natural gas from
Kosciusko, Mississippi to Union Township, Pennsylvania. Line 10 is
approximately 775 miles in length, 30-inch diameter pipeline; Line 15 is
approximately 775 miles in length, 30-inch diameter pipeline; and Line 25 is
approximately 775 miles in length, 30/36-inch diameter pipeline.
Failure 1 Isolated Segment means the approximately 19 miles of the Affected
Segment between the Danville Compressor Station at MP 427.5 and Valve 15-382
at MP 408.48. It is the portion of the Affected Segment that was shut-in after the
Failure on August 1, 2019, by closing main-line valves upstream and downstream
of the Failure Site and that remains shut-in as of August 8, 2019.
Failure 2 Isolated Segment means the approximately 14.7 miles of the Affected
Segment between the Owingsville Compressor Station at upstream valve (10-367,
MP 516.82) and the downstream valve (10-353, MP 502.11) of Line 10. Line 15
was isolated from upstream valve (15-522, MP 517.32) to downstream valve (15-
513, MP 502.62). Line 25 was isolated from upstream valve (25-725, MP 517.32)
to downstream valve (25-656, MP 502.62). It is the portion of the Affected
Segment that was shut-in after Failure 2 on May 4, 2020, by closing main-line
valves upstream and downstream of the Failure 2 Site and that remains shut-in as
of May 30, 2020 for Lines 10 and 15. The Identified segment for each pipeline in
the incident corridor are the following; Line 10 (KY-2 & 6702), Line 15 (KY-1 &
2802), and Line 25 (KY-2 & 6702).
Director means the Director, Southern Region, Office of Pipeline Safety,
PHMSA.
Pursuant to 49 U.S.C. § 60112, I hereby order TETLP to immediately take the following
corrective actions for the Affected Segment:
Failure 1 Corrective Actions:
1. Shutdown of Failure 1 Isolated Segment. The Director approved TETLP’s Restart Plan
on March 20, 2020. TETLP restarted the Failure 1 Isolated Segment on March 25, 2020.
The operating pressure for the Failure 1 Isolated Segment must not exceed eighty percent
(80%) of the actual operating pressure in effect immediately prior to Failure 1, in
accordance with Item 2 below.
2. Operating Pressure Restriction. With respect to the remainder of the Affected Segment
not shut down under Item 1, above, TETLP must reduce and maintain a twenty percent



3. CPF No. 2-2019-1002H
Page 8
(20%) pressure reduction in the actual operating pressure along the entire length of the
Affected Segment such that the operating pressure along the Affected Segment will not
exceed eighty percent (80%) of the actual operating pressure in effect immediately prior
to Failure 1.
(A) This pressure restriction is to remain in effect until the Director provides written
approval for TETLP to either increase the pressure or return the pipeline to its
pre-Failure operating pressure. A copy of the TETLP Restart Plan was provided
to the Southern Region. After the region’s review, approval of the Restart Plan
was given to TETLP to return the pipeline to the pre-Failure operating pressure on
March 20, 2020.
(B) This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-pressure
devices to be adjusted accordingly.
(C) When determining the pressure restriction set-points, TETLP must take into
account any ILI features or anomalies present in the Affected Segment to provide
for continued safe operation while further corrective actions are completed.
(D) TETLP must review the pressure restriction monthly by analyzing the operating
pressure data. TETLP must take into account any ILI features or anomalies
present in the Affected Segment and immediately reduce the operating pressure to
maintain the safe operations of the Affected Segment, if warranted by the monthly
review. TETLP must submit the results of the monthly review to the Director.
The results must include, at a minimum, the current discharge set-points
(including any additional pressure reductions), and any pressure exceedance at
discharge set-points.
Removal or Modification of Pressure Restriction. The pressure restriction required by
the above Items may be removed or modified, as follows:
(A) The Director may allow the removal or modification of the pressure restriction
upon a written request from TETLP demonstrating that restoring the pipeline to
its pre-Failure operating pressure is justified based on a reliable engineering
analysis showing that the pressure increase is safe considering all known defects,
anomalies, and operating parameters of the pipeline.
(B) The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from TETLP demonstrating that temporary
mitigative and preventive measures are being implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director’s
determination will be based on the Failure cause and provision of evidence that
preventive and mitigative actions taken by TETLP provide for the safe operation
of the Affected Segment during the temporary removal or modification of the
pressure restriction. Appeals to determinations of the Director in this regard will
be decided by the Associate Administrator for Pipeline Safety.



CPF No. 2-2019-1002H
Page 9
4. Instrumented Leakage Survey. TETLP completed an aerial or ground instrumented
leakage survey of the Affected Segment on November 20, 2019. A re-survey was
completed during the restart of Line 15 on March 24, 2020.
5. Records Verification. TETLP submitted documentation confirming the MAOP for Line
15 on October 30, 2019.
6. Review of Prior ILI Results. Within 30 days of receipt of the Amended Corrective
Action Order, conduct a review of the previous ILI results of the Affected Segment.
TETLP must re-evaluate all ILI results from the past 20 calendar years, include a review
of the ILI vendors’ raw data and analysis. TETLP must determine whether any features
were present in the failed pipe joint and/or any other pipe removed. Also, TETLP must
determine if any features are present elsewhere on the Affected Segment. TETLP must
submit documentation of this ILI review to the Director within 45 days of receipt of the
Amended Corrective Action Order as follows:
(A) List all ILI tool runs, tool types, and the calendar years of the tool runs.
(B) List, describe (type, size, wall loss, etc.), and identify the specific location of all
ILI features present in the failed joint and/or other pipe removed.
(C) Explain the process used to review the ILI results and the results of the
reevaluation.
TETLP has begun this re-evaluation and has been submitting monthly reports to the
Director, along with additional data. The latest report was received on May 13, 2020.
7. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing, including
failure analysis will be performed by the NTSB in accordance with NTSB procedures and
protocols. In the event the NTSB does not perform these functions, TETLP will be
responsible for completing all testing and analysis. If the NTSB does not perform the
analysis, TETLP must submit to the Director for prior approval a plan to complete the
testing and analysis.
8. Root Cause Failure Analysis. The NTSB will perform a root cause failure analysis
(RCFA) to determine the cause of the Failure. TETLP must incorporate the findings the
NTSB RCFA into its integrity management plan and operations and maintenance manual.
If the NTSB does not perform these tasks, TETLP must submit to the Director for prior
approval a plan to complete an RCFA.
9. Emergency Response Plan and Training Review. TETLP must review and assess the
effectiveness of its emergency response plan and operational actions with regards to
Failure 1. TETLP must include in the review and assessment the on-scene response and
support, coordination, and communication with emergency responders and public
officials. Also, TETLP must include a review and assessment of the effectiveness of its
emergency training program. TETLP must amend its emergency response plan and
emergency training, if necessary, to reflect the results of this review. The documentation
of this Emergency Response Plan and Training Review must be included in the CAO
Documentation Report (see Item 12 for description of the CAO Documentation Report).



CPF No. 2-2019-1002H
Page 10
10. Public Awareness Program Review. TETLP must review and assess the effectiveness of
its Public Awareness Program with regards to Failure 1. TETLP must amend its Public
Awareness Program, if necessary, to reflect the results of this review. The documentation
of this Public Awareness Program Review must be provided to the Director.
11. Remedial Work Plan (RWP).
(A) TETLP must submit a Remedial Work Plan (RWP) to the Director for approval
by August 2, 2020.
(B) The Director may approve the RWP incrementally without approving the entire
RWP.
(C) Once approved by the Director, the RWP will be incorporated by reference into
the Amended Order.
(D) The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures TETLP will use to verify the integrity of the Affected
Segment. The RWP must address all known or suspected factors and causes of
Failure 1. TETLP should consider both the risks and consequences of another
failure arising from the same root cause as Failure 1 to develop a prioritized
schedule for RWP related work along the Affected Segment.
(E) The RWP must include a procedure or process to:
i. Identify pipe in the Affected Segment with characteristics similar to the
contributing factors identified for Failure 1.
ii. Gather all data necessary to review the failure history (in service and
pressure test failures) of the Affected Segment and to prepare a written
report containing all the available information such as the locations, dates,
and causes of leaks and failures.
iii. Integrate the results and conclusions of the NTSB’s metallurgical testing
as well as those of the final RCFA, and other corrective actions required
by the Amended Order with all relevant pre-existing operational and
assessment data for the Affected Segment. Pre-existing operational data
includes, but is not limited to, construction, operations, maintenance,
testing, repairs, prior metallurgical analyses, and any third-party
consultation information. Pre-existing assessment data includes, but is not
limited to, ILI tool runs, hydrostatic pressure testing, direct assessments,
close interval surveys, and DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to Failure 1 are likely
to exist elsewhere on the Affected Segment.
v. Conduct additional field tests, inspections, assessments, and/or evaluations
to determine whether, and to what extent, the conditions associated with
the Failure, and other failures from the failure history (see Item 11(E)(ii),



CPF No. 2-2019-1002H
Page 11
above) or any other integrity threats are present elsewhere on the Affected
Segment. At a minimum, this process must consider all failure causes and
specify the use of one or more of the following:
a. Inline inspection (ILI) tools that are technically appropriate for
assessing the pipeline system based on the cause of Failure 1, and
that can reliably detect and identify anomalies;
b. Hydrostatic pressure testing;
c. Close-interval surveys;
d. Cathodic protection surveys, to include interference surveys in
coordination with other utilities (e.g., underground utilities,
overhead power lines, etc.) in the area;
e. Coating surveys;
f. Stress corrosion cracking surveys;
g. Selective seam corrosion surveys; and
h. Other tests, inspections, assessments, and evaluations appropriate
for the failure causes.
Note: TETLP may use the results of previous tests, inspections,
assessments, and evaluations if approved by the Director, provided
the results of the tests, inspections, assessments, and evaluations
are analyzed with regard to the factors known or suspected to have
caused Failure 1.
vi. Describe the inspection and repair criteria TETLP will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other
identified integrity threats. Include a description of how any defects will
be graded and a schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Segment,
describe the methods TETLP will use to repair, replace, or take other
corrective measures to remediate the conditions associated with Failure 1,
and to address other known integrity threats along the Affected Segment.
The repair, replacement, or other corrective measures must meet the
criteria specified in Item 11(E)(iv), above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Segment
considering the results of the analyses, inspections, evaluations, and
corrective measures undertaken pursuant to the Amended Order.



CPF No. 2-2019-1002H
Page 12
ix. Implement specific actions TETLP will take on its entire pipeline system
as a result of the lessons learned from work on the Amended Order.
Incorporate lessons learned on TETLP’s entire pipeline system. TETLP
will report lessons learned in the CAO Documentation Report (see Item 12
for description of the CAO Documentation Report).
(F) TETLP must include a proposed schedule for completion of the RWP.
(G) TETLP must revise the RWP as necessary to incorporate new information
obtained during the NTSB and PHMSA’s failure investigation and remedial
activities taken under the Amended Order, to incorporate the results of actions
undertaken pursuant to the Amended Order, and/or to incorporate modifications
required by the Director.
i. TETLP must submit any plan revisions to the Director for prior approval.
ii. The Director may approve plan revisions incrementally.
iii. Any and all revisions to the RWP after it has been approved and
incorporated by reference into the Amended Order will be fully described
and documented in the CAO Documentation Report (CDR).
(H) Implement the RWP as it is approved by the Director, including any revisions to
the plan.
12. CAO Documentation Report (CDR). TETLP must create and revise, as necessary, a
CDR. When TETLP has concluded all the items in the Amended Order it will submit the
final CDR in its entirety to the Director. This will allow the Director to complete a
thorough review of all actions taken by TETLP with regards to the Amended Order prior
to approving the closure of the Amended Order. The intent is for the CDR to summarize
all activities and documentation associated with the Amended Order in one document.
(A) The Director may approve the CDR incrementally without approving the entire
CDR.
(B) Once approved by the Director, the CDR will be incorporated by reference into
the Amended Order.
(C) The CDR must include but not be limited to:
i. Table of Contents;
ii. Summary of the pipeline Failure, and the response activities;
iii. Summary of pipe data/properties and all prior assessments of the Affected
Segment;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis
required by the Amended Order;



CPF No. 2-2019-1002H
Page 13
v. Summary of the Mechanical and Metallurgical Testing as required by the
Amended Order;
vi. Documentation of all actions taken by TETLP to implement the RWP, the
results of those actions, and the inspection and repair criteria used;
vii. Documentation of any revisions to the RWP including those necessary to
incorporate the results of actions undertaken pursuant to the Amended
Order and whenever necessary to incorporate new information obtained
during the failure investigation and remedial activities;
viii. Lessons learned while completing the Amended Order;
ix. A description of specific actions TETLP will take on its entire pipeline
system as a result of the lessons learned from work on the Amended
Order; and
x. Appendices (if required).
Failure 2 Corrective Actions:
13. Shutdown of Isolated Section. TETLP must not operate the Failure 2 Isolated Segment
of Lines 10 or 15 until authorized to do so by the Director.
14. Operating Pressure Restriction. With respect to the remainder of the Affected Segment
not shut down under Item 13, above, TETLP must reduce and maintain a twenty percent
(20%) pressure reduction in the actual operating pressure along the entire length of the
Affected Segment such that the operating pressure along the Affected Segment will not
exceed eighty percent (80%) of the actual operating pressure in effect immediately prior
to Failure 1 and Failure 2.
(A) This pressure restriction is to remain in effect until the Director provides written
approval for TETLP to either increase the pressure or return the pipeline to its
pre-Failure operating pressure.
(B) By June 1, 2020, TETLP must provide the Director the actual operating pressures
of each compressor station and each main line pressure regulating station on the
Affected Segment at the time of Failure 2 and the reduced pressure restriction set-
points at these same locations.
(C) This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-pressure
devices to be adjusted accordingly.
(D) When determining the pressure restriction set-points, TETLP must take into
account any ILI features or anomalies present in the Affected Segment to provide
for continued safe operation while further corrective actions are completed.



CPF No. 2-2019-1002H
Page 14
(E) TETLP must review the pressure restriction monthly by analyzing the operating
pressure data. TETLP must take into account any ILI features or anomalies
present in the Affected Segment and immediately reduce the operating pressure to
maintain the safe operations of the Affected Segment, if warranted by the monthly
review. TETLP must submit the results of the monthly review to the Director.
The results must include, at a minimum, the current discharge set-points
(including any additional pressure reductions), and any pressure exceedance at
discharge set-points.
15. Restart Plan. Prior to resuming operation of any part of the Failure 2 Isolated Segment,
TETLP must develop and submit a written Restart Plan to the Director.
(A) The Director may approve the Restart Plan incrementally without approving the
entire plan but the Failure 2 Isolated Segment cannot resume operation until the
Restart Plan has been approved in its entirety.
(B) Once approved by the Director, the Restart Plan will be incorporated by reference
into this Second Amended Order.
(C) The Restart Plan must provide for adequate patrolling of the Failure 2 Isolated
Segment during the restart process and must include incremental pressure
increases during start up, with each increment to be held for at least two hours.
(D) The Restart Plan must include sufficient surveillance of the pipeline during each
pressure-increase increment to ensure that no leaks are present when operation of
the line resumes.
(E) The Restart Plan must specify a day-light restart and include advance
communications with local emergency response officials.
(F) The Restart Plan must provide for a review of the Failure 2 Isolated Segment for
conditions similar to those surrounding the Failure including a review of
construction, operating and maintenance (O&M) and integrity management
records such as ILI results, hydrostatic tests, root cause failure analysis of prior
failures, aerial and ground patrols, corrosion, cathodic protection, excavations and
pipe replacements. TETLP must address any findings that require remedial
measures to be implemented prior to restart.
(G) The Restart Plan must also include documentation of the completion of all
mandated actions, and a management of change plan to ensure that all procedural
modifications are incorporated into TETLP’s operations and maintenance
procedures manual.
(H) Procedures for the exposure, testing, and repair of Line 10 must include:
i. Exposure of Line 10 extending for at least two girth welds on either side
of the Failure 2 Site to examine for corrosion, coating condition,
concussive damage, and thermally-impacted areas. If damage to the
exposed pipe is discovered, TETLP must expose additional pipe until at



CPF No. 2-2019-1002H
Page 15
least 10 feet of undamaged pipe is exposed and examined. TETLP must
perform safe operating-pressure calculations and remediation for any
anomalies or threat found, using permanent repair methods and design
factors based upon 49 C.F.R. §§ 192.713 and 192.111 and using
ASME/ANSI B31G or R STRENG methods. TETLP must repair or
replace pipe or coating, as necessary. Upon completion of pipe
replacement and repairs, TETLP must provide proper backfill and
protection from stones and rocks, pursuant to procedures developed under
this Second Amended Order;
ii. Establishment of adequate cathodic protection for the area where Failure 2
occurred. TETLP must replace any damaged rectifier(s) and must re-
establish the electrical test station at the railroad crossing. Once backfill
and land settling have occurred, TETLP must ensure pipe-to-soil readings
are within applicable criteria; and
iii. Development of additional requirements for remediation and the eventual
restart for Line 10 as the investigation yields more information about the
cause of Failure 2 and the condition of the Affected Segment.
(I) Procedures for the exposure, examination, remediation, and restart of Lines 10 and
15 must include:
i. Development of assessment, remediation, and restart plans that are aligned
with the criteria shown immediately below;
ii. Exposure of Lines 15 extending for at least two girth welds in both
directions from the Failure 2 location. TETLP must examine the girth
welds and pipeline coating materials for damage caused by thermal and
concussive forces. TETLP must continue a broader exposure of each line
if associated damage is discovered, until 10 feet of undamaged pipe is
reached and verified. Any needed repairs are to be guided by established
Enbridge procedures and safe operating-pressure calculations and the
remediation for any pits or other forms of anomalies found, using
engineering permanent repair methods and design factors based upon
49 C.F.R. §§ 192.713 and 192.111 and using ASME/ANSI B310 or R-
STRENG methods. TETLP must repair or replace pipe or coating, as
necessary. Upon completion of pipe replacement and repairs, and provide
proper backfill and protection from stones and rocks, all pursuant to
Enbridge's established procedures;
iii. Restarts for each individual line in pressure-increase increments, at
twenty-five percent (25%), fifty percent (50%), and eighty percent (80%),
with each increment held for at least one hour after pressure stabilization.
After reaching eighty percent (80%) pressure, Respondent must obtain
specific individual written approval from the Director to increase pressure
to pre-Failure normal pressure. Respondent must obtain separate approval



CPF No. 2-2019-1002H
Page 16
for Line 15 before increasing pressure to the final normal operating
pressure; and
iv. A ground-level, instrumented leak survey on Lines 15 for the entire
Isolated Segment. TETLP must investigate any elevated readings and
make all appropriate repairs.
16. Return to Service. TETLP may return the Failure 2 Isolated Segment to service, but the
operating pressure must not exceed 80 percent (80%) of the actual operating pressure in
effect immediately prior to Failure 2, in accordance with Item 14 above.
17. Removal or Modification of Pressure Restriction. The pressure restriction required by
the above Items may be removed or modified, as follows:
(A) The Director may allow the removal or modification of the pressure restriction
upon a written request from TETLP demonstrating that restoring each pipeline
within the Affected Segment to its pre-Failure operating pressure is justified
based on a reliable engineering analysis showing that the pressure increase is safe
considering all known defects, anomalies, and operating parameters of the
pipeline.
(B) The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from TETLP demonstrating that temporary
mitigative and preventive measures are being implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director’s
determination will be based on the Failures’ causes and provisions of evidence
that preventive and mitigative actions taken by TETLP provide for the safe
operation of the Affected Segment during the temporary removal or modification
of the pressure restriction. Appeals to determinations of the Director in this
regard will be decided by the Associate Administrator for Pipeline Safety.
18. Instrumented Leakage Survey. Within 180 days of receipt of this Second Amended
Order, TETLP must perform an aerial or ground instrumented leakage survey of the
Affected Segment. TETLP must investigate all leak indications and remedy all leaks
discovered. TETLP must submit documentation of this survey to the Director within 45
days of the completion of the leak survey.
19. Records Verification. As recommended in PHMSA Advisory Bulletin 2012-06, verify
the records for the Affected Segment to confirm the MAOPs for Lines 10, 15, and 25.
TETLP must submit documentation of this records verification to the Director within 45
days of receipt of this Second Amended Order.
20. Review of Prior ILI Results. Within 30 days of receipt of this Second Amended Order,
conduct a review of the previous ILI results of the Affected Segment. TETLP must re-
evaluate all ILI results from the past 20 calendar years, include a review of the ILI
vendors’ raw data and analysis. TETLP must determine whether any features were
present in the failed pipe joint and/or any other pipe removed. Also, TETLP must
determine if any features are present elsewhere on the Affected Segment. TETLP must



CPF No. 2-2019-1002H
Page 17
submit documentation of this ILI review to the Director within 45 days of receipt of this
Second Amended Order as follows:
(A) List all ILI tool runs, tool types, and the calendar years of the tool runs.
(B) List, describe (type, size, wall loss, etc.), and identify the specific location of all
ILI features present in the failed joint and/or other pipe removed.
(C) Explain the process used to review the ILI results and the results of the
reevaluation.
TETLP has begun this re-evaluation and has been submitting monthly reports to the
Director, along with additional data. The latest report for the Original CAO was received
on April 14, 2020.
21. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing, including
failure analysis will be performed by DNV-GL in accordance with NTSB and PHMSA
procedures and protocols. DNV-GL was selected as the laboratory and accepted by both
PHMSA and NTSB. TETLP is required to notify DNV-GL to submit all reports
regarding tests/finding simultaneously with PHMSA at the time of its completion.
22. Root Cause Failure Analysis. The RCFA is to be conducted by a third party selected by
TETLP and approved by PHMSA to determine the cause of the Failure. TETLP must
submit to the Director for prior approval a plan to complete an RCFA. TETLP must
incorporate the findings the RCFA into its integrity management plan and operations and
maintenance manual. TETLP must incorporate the findings the RCFA into its integrity
management plan and operations and maintenance manual.
23. Emergency Response Plan and Training Review. TETLP must review and assess the
effectiveness of its emergency response plan and operational actions with regards to the
Failures. TETLP must include in the review and assessment the on-scene response and
support, coordination, and communication with emergency responders and public
officials. Also, TETLP must include a review and assessment of the effectiveness of its
emergency training program. TETLP must amend its emergency response plan and
emergency training, if necessary, to reflect the results of this review. The documentation
of this Emergency Response Plan and Training Review must be included in the CAO
Documentation Report (see Item 26 for description of the CAO Documentation Report).
24. Public Awareness Program Review. TETLP must review and assess the effectiveness of
its Public Awareness Program with regards to the Failures. TETLP must amend its
Public Awareness Program, if necessary, to reflect the results of this review. The
documentation of this Public Awareness Program Review must be provided to the
Director.
25. Remedial Work Plan (RWP).
(A) Within 90 days following receipt of the RCFA, TETLP must submit a RWP to
the Director for approval.



CPF No. 2-2019-1002H
Page 18
(B) The Director may approve the RWP incrementally without approving the entire
RWP.
(C) Once approved by the Director, the RWP will be incorporated by reference into
this Second Amended Order.
(D) The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures TETLP will use to verify the integrity of the Affected
Segment. The RWP must address all known or suspected factors and causes of
the failures on January 21, 2019, August 1, 2019, and May 4, 2020. TETLP
should consider both the risks and consequences of another failure arising from
the same root cause as these Failures to develop a prioritized schedule for RWP
related work along the Affected Segment.
i. Inertial Measurement Unit and High-Resolution Deformation Tool runs
looking for bending/buckling and movement areas;
ii. Walk the pipeline with Geotech engineers; and
iii. Aerial photo review.
(E) The RWP must include a procedure or process to:
i. Identify pipe in the Affected Segment with characteristics similar to the
contributing factors identified for the Failures.
ii. Gather all data necessary to review the failure history (in service and
pressure test failures) of the Affected Segment and to prepare a written
report containing all the available information such as the locations, dates,
and causes of leaks and failures.
iii. Integrate the results and conclusions of the NTSB’s metallurgical testing
for Failure 1 and the DNV-GL metallurgical testing for Failure 2 as well
as those of the final RCFA, and other corrective actions required by this
Second Amended Order with all relevant pre-existing operational and
assessment data for the Affected Segment. Pre-existing operational data
includes, but is not limited to, construction, operations, maintenance,
testing, repairs, prior metallurgical analyses, and any third-party
consultation information. Pre-existing assessment data includes, but is not
limited to, ILI tool runs, hydrostatic pressure testing, direct assessments,
close interval surveys, and DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to the Failures are
likely to exist elsewhere on the Affected Segment.
v. Conduct additional field tests, inspections, assessments, and/or evaluations
to determine whether, and to what extent, the conditions associated with
the Failures, and other failures from the failure history (see Item 25(E)(ii),
above) or any other integrity threats are present elsewhere on the Affected



CPF No. 2-2019-1002H
Page 19
Segment. At a minimum, this process must consider all failure causes and
specify the use of one or more of the following:
a. ILI tools that are technically appropriate for assessing the pipeline
system based on the cause of the Failures, and that can reliably
detect and identify anomalies;
b. Hydrostatic pressure testing;
c. Close-interval surveys;
d. Cathodic protection surveys, to include interference surveys in
coordination with other utilities (e.g. underground utilities,
overhead power lines, etc.) in the area;
e. Coating surveys;
f. Stress corrosion cracking surveys;
g. Selective seam corrosion surveys; and
h. Other tests, inspections, assessments, and evaluations appropriate
for the failure causes.
Note: TETLP may use the results of previous tests, inspections,
assessments, and evaluations if approved by the Director, provided
the results of the tests, inspections, assessments, and evaluations
are analyzed with regard to the factors known or suspected to have
caused the Failures.
vi. Describe the inspection and repair criteria TETLP will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other
identified integrity threats. Include a description of how any defects will
be graded and a schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Segment,
describe the methods TETLP will use to repair, replace, or take other
corrective measures to remediate the conditions associated with the
Failures, and to address other known integrity threats along the Affected
Segment. The repair, replacement, or other corrective measures must
meet the criteria specified in Item 25(E)(iv), above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Segment
considering the results of the analyses, inspections, evaluations, and
corrective measures undertaken pursuant to the Second Amended Order.
ix. Implement specific actions TETLP will take on its entire pipeline system
as a result of the lessons learned from work on this Second Amended



CPF No. 2-2019-1002H
Page 20
Order. Incorporate lessons learned on TETLP’s entire pipeline system.
TETLP will report lessons learned in the CDR (see Item 26 for description
of the CDR).
(F) TETLP must include a proposed schedule for completion of the RWP.
(G) TETLP must revise the RWP as necessary to incorporate new information
obtained during the NTSB and PHMSA’s failure investigation and remedial
activities taken under this Second Amended Order, to incorporate the results of
actions undertaken pursuant to this Second Amended Order, and/or to incorporate
modifications required by the Director.
i. TETLP must submit any plan revisions to the Director for prior approval.
ii. The Director may approve plan revisions incrementally.
iii. Any and all revisions to the RWP after it has been approved and
incorporated by reference into this Second Amended Order will be fully
described and documented in the CDR.
(H) Implement the RWP as it is approved by the Director, including any revisions to
the plan.
26. CAO Documentation Report (CDR). TETLP must create and revise, as necessary, a
CDR. When TETLP has concluded all the items in this Second Amended Order it will
submit the final CDR in its entirety to the Director. This will allow the Director to
complete a thorough review of all actions taken by TETLP with regards to this Second
Amended Order prior to approving the closure of this Second Amended Order. The
intent is for the CDR to summarize all activities and documentation associated with this
Second Amended Order in one document.
(A) The Director may approve the CDR incrementally without approving the entire
CDR.
(B) Once approved by the Director, the CDR will be incorporated by reference into
this Second Amended Order.
(C) The CDR must include but not be limited to:
i. Table of Contents;
ii. Summary of the pipeline Failures, and the response activities;
iii. Summary of pipe data/properties and all prior assessments of the Affected
Segment;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis
required by the Second Amended Order;



v. vi. vii. viii. CPF No. 2-2019-1002H
Page 21
Summary of the Mechanical and Metallurgical Testing as required by the
Second Amended Order;
Documentation of all actions taken by TETLP to implement the RWP, the
results of those actions, and the inspection and repair criteria used;
Documentation of any revisions to the RWP including those necessary to
incorporate the results of actions undertaken pursuant to this Second
Amended Order and whenever necessary to incorporate new information
obtained during the failure investigation and remedial activities;
Lessons learned while completing this Second Amended Order;
ix. A description of specific actions TETLP will take on its entire pipeline
system as a result of the lessons learned from work on this Second
Amended Order; and
x. Appendices (if required).
Other Requirements:
26. Reporting. Submit monthly reports to the Director that: (1) include all available data and
results of the testing and evaluations required by this Second Amended Order; and (2)
describe the progress of the repairs or other remedial actions being undertaken. The
Director may change the interval for the submission of these reports.
27. Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Second Amended
Order. Include in each monthly report the to-date total costs associated with: (1)
preparation and revision of procedures, studies and analyses; (2) physical changes to
pipeline infrastructure, including repairs, replacements and other modifications; and (3)
environmental remediation, if applicable.
28. Approvals. With respect to each submission requiring the approval of the Director, the
Director may: (a) approve the submission in whole or in part; (b) approve the submission
on specified conditions; (c) modify the submission to cure any deficiencies; (d)
disapprove the submission in whole or in part and direct Respondent to modify the
submission; or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission, as approved or modified by the Director. If the Director
disapproves all or any portion of a submission, Respondent must correct all deficiencies
within the time specified by the Director and resubmit it for approval.
29. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of this Second Amended Order upon a written request timely submitted
and demonstrating good cause for an extension.



CPF No. 2-2019-1002H
Page 22
30. 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).
In your correspondence on this matter, please refer to “CPF No. 2-2019-1002H” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Second Amended Order are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199,
under any other order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under
any other provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Second Amended Order may result in the assessment of civil
penalties and in referral to the Attorney General for appropriate relief in United States District
Court pursuant to 49 U.S.C. § 60120.
The terms and conditions of this Second Amended Order are effective upon service in
accordance with 49 C.F.R. § 190.5.
June 1, 2020
__________________________________ ________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

220191002H_Amended Corrective Action Order_04282020_text.pdf

AMENDED CORRECTIVE ACTION ORDER
ISSUED WITHOUT PRIOR NOTICE
VIA ELECTRONIC MAIL TO: william.yardley@enbridge.com
Mr. William T. Yardley
Executive Vice President and President
Gas Transmission and Midstream
Enbridge, Inc.
5400 Westheimer Court
Houston, Texas 77056
Re: CPF No. 2-2019-1002H
Dear Mr. Yardley:
Enclosed is an Amended Corrective Action Order issued in the above-referenced case to your
subsidiary, Texas Eastern Transmission, LP. It requires certain corrective actions that need to be
taken with respect to Line 15, which failed on August 1, 2019, near Danville, Kentucky. Service
of the Amended Corrective Action Order by electronic mail is deemed complete upon
transmission and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.
The terms and conditions of this Amended Order are effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA
Mr. Rick Kivela, Manager, Operational Compliance, Enbridge, rick.kivela@enbridge.com
Ms. Catherine Little, Counsel, Troutman Sanders, LLP, catherine.little@troutman.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Texas Eastern Transmission, LP, ) CPF No. 2-2019-1002H
a subsidiary of Enbridge, Inc., )
)
)
)
Respondent. )
____________________________________)
AMENDED CORRECTIVE ACTION ORDER
Purpose and Background:
This Amended Corrective Action Order (Amended Order) is being issued under the authority of
49 U.S.C. § 60112, to require Texas Eastern Transmission, LP (TETLP or Respondent), to take
the necessary corrective action to protect the public, property, and the environment from
potential hazards associated with the recent gas transmission pipeline failure on TETLP’s 30-
inch Line 15 near Danville, Kentucky (Failure).
On August 1, 2019, an incident occurred on Line 15, resulting in the release of approximately 66
million cubic feet of natural gas, which ignited and resulted in the death of one person and the
hospitalization of six others. The resulting fire also destroyed multiple structures and burned
vegetation over approximately 30 acres of land. Pursuant to 49 U.S.C. § 60117, the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated
an investigation of the accident. The National Transportation Safety Board (NTSB) is now
leading the investigation.
On August 8, 2019, PHMSA issued a Corrective Action Order to TETLP requiring it to take
certain corrective actions with respect to Line 15 and the adjacent Lines 10 and 25.
The purpose of these amendments is to update the terms of the Order to address actions taken by
TETLP in response to the August 8 Corrective Action Order.
The amended preliminary findings of PHMSA’s ongoing investigation are as follows:
Amended Preliminary Findings:
 TETLP is a wholly-owned subsidiary of Spectra Energy Partners, LP, which is, in turn, a
wholly-owned subsidiary of Enbridge, Inc. (Enbridge), which is based in Calgary,



CPF No. 2-2019-1002H
Page 2
Alberta, Canada.1 TETLP operates an approximately 9,100-mile pipeline system,
transporting natural gas from the northeastern United States to the Gulf Coast Region.
 TETLP’s system transports natural gas to and through Texas, Louisiana, the Gulf of
Mexico, Mississippi, Arkansas, Missouri, Tennessee, Illinois, Indiana, Kentucky, Ohio,
Pennsylvania, New Jersey, and New York.
 The failed pipeline (Line 15 or Affected Segment) is a component of the above-
referenced TETLP system. It is a 775-mile long, 30-inch diameter, bi-directional
pipeline that transports natural gas between Kosciusko, Mississippi and Uniontown,
Pennsylvania. Line 15 is one of three parallel TETLP pipelines running in a common
corridor near the site of the Failure. The other two TETLP pipelines are the 30-inch Line
10 and the 30/36-inch Line 25. At the Failure Site, Line 15 is the middle of the three
pipelines. The Failure occurred near MP 423.4, approximately 4.5 miles south of
Danville, Kentucky (Failure Site), on the Danville to Tompkinsville portion of the
Affected Segment.
 Line 15 was constructed beginning in 1957. The portion of Line 15 at the Failure Site
consists of 0.375-inch wall thickness, American Petroleum Institute X-52 grade pipe,
manufactured by A.O. Smith using flash welding, and is coated with coal tar enamel.
The line is cathodically protected with impressed current.
 Line 15 is a bi-directional pipeline. The line originally flowed south-to-north, with an
MAOP of 1000 psig, established as 76.92 percent of the specified minimum yield
strength (SMYS) of Line 15. In 2014, TETLP reversed the flow to north-to-south, and
the MAOP was reestablished as 936 psig, or 72 percent of the SMYS, commensurate
with 49 C.F.R. § 192.105. At the time of the Failure, Line 15 was flowing north-to-
south and was operating at 925 psig.
 It is estimated that approximately 66 million cubic feet of natural gas was released by the
Failure.
 The Failure occurred at approximately 1:24 a.m. EDT. At approximately 1:25 am,
Enbridge’s Gas Control in Houston, Texas, received a rate of change alarm on Line 15 on
the south side of Danville Compressor Station and during the ensuing minutes, received
reports from the public of a fire in the area south of Danville Compressor Station. A
Danville Compressor Station operator also received a rate of change alarm and observed
the rupture fire from the window of the compressor station control room. During the
ensuing minutes, other Enbridge employees confirmed the reported fire, indicating the
failure of Line 15.
 TETLP’s Danville Compressor Station personnel closed the Line 15 discharge valve
located north of the Failure Site. TETLP field personnel responded by closing the Line
15 Main Line Block Valve located at Valve Site #4 (MP 408.48), located south of the
1 Enbridge, Inc. website, available at
https://www.enbridge.com/~/media/Enb/Documents/Investor%20Relations/Texas%20Eastern%20Transmission/TE
TLP%20Q1%202019%20Financial%20Statements%20-%20Final.pdf?la=en (last accessed April 22, 2020).



CPF No. 2-2019-1002H
Page 3
Failure Site. Following confirmation of the Failure, Enbridge further isolated a portion
(Isolated Segment) of the Affected Segment by closing Valve 15-382 at MP 408.48 and
Valve 15-393 at the Danville Compressor Station near MP 427.5. Enbridge also shut
down and shut in Lines 10 and 25, which are blocked in between the Danville
Compressor Station and the Tompkinsville Compressor Station.
 The Failure resulted in the ejection of an approximately 30-foot long section of Line 15,
which landed approximately 481 feet from the Failure Site. Additionally, the Failure
resulted in a 43-foot long, 30-foot wide, 10-foot deep crater at the Failure Site. Gas
released from the Failure ignited, causing a fire that resulted in the death of one person,
the hospitalization of six people, and the destruction of several nearby homes and other
structures. Railroad tracks operated by Norfolk Southern Corporation (NSC) were also
damaged by the fire. NSC temporarily suspended rail service through the area. The fire
also scorched or burned approximately 30 acres of land, resulting in numerous burned
trees and grass.
 Fire fighters from the Lincoln County were the first responders to arrive at the Failure
Site. Other local fire departments responded to this event and evacuated approximately
75 people from the nearby Indian Camp subdivision. Casey County emergency medical
services transported one injured person to Ephraim McDowell emergency medical center
and Boyle County emergency medical services transported two injured persons to the
same emergency medical center. Other injured persons were self-transported to medical
centers.
 The Affected Segment contains 33.2 feet of A.O. Smith-manufactured pipe of similar
vintage and type to the pipe involved in the Failure. The origin of the Failure was
identified and the specimen pipe is under control of the NTSB. NTSB and PHMSA
investigators collected information related to potential causal factors and circumstances
that may have led to the Failure. The NTSB will conduct a metallurgical investigation to
determine the exact cause.
 Lines 10 and 25 run on either side of Line 15 in the immediate vicinity of the Failure
Site. The possibility of damage to Lines 10 and 25 from the concussive force of the
Failure or of thermal damage from the resulting fire was evaluated and determined to
have no impact on these lines.
 Following TETLP’s analysis, PHMSA approved a return to MAOP for Lines 10 and 25
on August 30, 2019, and August 23, 2019, respectively.
 On November 2, 2003, Line 15 failed at MP 501.72 near Morehead, Kentucky, between
the Danville Compressor Station and the Owingsville Compressor Station to the north of
the Danville Compressor Station. The 2003 failure also occurred on A.O.
Smith-manufactured pipe, and resulted from interactions between hard spots and mid-
wall lamination, and in PHMSA’s predecessor agency issuing a Corrective Action Order
to TETLP’s predecessor entity on November 6, 2003, in CPF 2-2003-1018H.



CPF No. 2-2019-1002H
Page 4
 TETLP reported that it performed an in-line inspection (ILI) to detect hard spots on
Line 15 in 2011. The company also reported that it ran an ILI with a magnetic flux
leakage tool in 2018 and an ILI with a dent and inertial measurement unit tool in 2019.
The 2018 tool data indicated a small dent with metal loss that did not require action under
federal pipeline safety regulations or TETLP’s procedures.
 The 2011 hard spot in-line inspection of Line 15 resulted in no evidence of hard spot
indications. A 2019 post-incident review of the same hard spot in-line inspection data
revealed ten hard spots located in the failed pipe joint. Further analysis revealed the
location of the Line 15 failure origin coincided with the locations of two newly
discovered hard spot indications.
Determination of Necessity for Amended Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous and requiring corrective action, is
set forth both in the above-referenced statute and 49 C.F.R. § 190.233.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of the Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
Affected Segment without corrective measures is or would be hazardous to life, property, or the
environment. In addition, having considered the uncertainties of the cause of the Failure, the
pressure at which gas is transported, the vintage and type of pipe, the risk of fire to the
environment and populated areas in the vicinity of the Affected Segment, I find that a failure to
issue this Order expeditiously to require immediate corrective action would result in the
likelihood of serious harm to life, property, or the environment.
Accordingly, this Amended Order mandating immediate corrective action is issued without prior
notice and opportunity for a hearing. The terms and conditions of this Amended Order are
effective upon receipt.
Within 10 days of receipt of this Amended Order, Respondent may contest its issuance and
obtain expedited review either by answering in writing or requesting a hearing under 49 C.F.R.
§ 190.211, to be held as soon as practicable under the terms of such regulation, by notifying the
Associate Administrator for Pipeline Safety in writing, with a copy to the Director, Southern
Region, PHMSA (Region Director). If Respondent requests a hearing, it will be held
telephonically or in-person in Atlanta, Georgia, or Washington, D.C, unless a different location
is expressly agreed-to in writing by the Director.



CPF No. 2-2019-1002H
Page 5
After receiving and analyzing additional data in the course of this investigation, PHMSA
may identify other corrective measures that need to be taken on the Affected Segment or
other pipelines in the TETLP system. In that event, PHMSA will notify Respondent of any
additional measures that are required and a further Amended Order will be issued, if necessary.
To the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
Definitions:
Affected Segment means the approximately 775-mile long, 30-inch diameter Line
15 that transports natural gas between Kosciusko, Mississippi and Uniontown,
Pennsylvania.
Isolated Segment means the approximately 19 miles of the Affected Segment
between the Danville Compressor Station at MP 427.5 and Valve 15-382 at MP
408.48. It is the portion of the Affected Segment that was shut-in after the Failure
on August 1, 2019, by closing main-line valves upstream and downstream of the
Failure Site and that remains shut-in as of August 8, 2019.
Director means the Director, Southern Region, Office of Pipeline Safety,
PHMSA.
Pursuant to 49 U.S.C. § 60112, I hereby order Texas Eastern Transmission, LP to immediately
take the following corrective actions for the Affected Segment:
1. Shutdown of Isolated Section. Texas Eastern Transmission, LP (TETLP) must not
operate the Isolated Segment until authorized to do so by the Director
Operating Pressure Restriction. With respect to the remainder of the Affected Segment
not shut down under Item 1, above, TETLP must reduce and maintain a twenty percent
(20%) pressure reduction in the actual operating pressure along the entire length of the
Affected Segment such that the operating pressure along the Affected Segment will not
exceed eighty percent (80%) of the actual operating pressure in effect immediately prior
to the Failure.
(A) This pressure restriction is to remain in effect until the Director provides written
approval for TETLP to either increase the pressure or return the pipeline to its
pre-Failure operating pressure. A copy of the TETLP Restart Plan was provided
to the Southern Region. After the region’s review, approval of the Restart Plan
was given to TETLP to return the pipeline to the pre-Failure operating pressure on
March 20, 2020.
(B) This pressure restriction requires any relevant remote or local alarm limits,
software programming set-points or control points, and mechanical over-pressure
devices to be adjusted accordingly.
2.



CPF No. 2-2019-1002H
Page 6
(C) When determining the pressure restriction set-points, TETLP must take into
account any ILI features or anomalies present in the Affected Segment to provide
for continued safe operation while further corrective actions are completed.
(D) TETLP must review the pressure restriction monthly by analyzing the operating
pressure data. TETLP must take into account any ILI features or anomalies
present in the Affected Segment and immediately reduce the operating pressure to
maintain the safe operations of the Affected Segment, if warranted by the monthly
review. TETLP must submit the results of the monthly review to the Director.
The results must include, at a minimum, the current discharge set-points
(including any additional pressure reductions), and any pressure exceedance at
discharge set-points.
3. Restart Plan. Prior to resuming operation of the Isolated Segment, TETLP developed
and submitted a written Restart Plan to the Director. The Director approved the Restart
Plan on March 20, 2020.
4. Return to Service. The Director approved the Restart Plan on March 20, 2020. TETLP
may return the Isolated Segment to service but the operating pressure must not exceed 80
percent of the actual operating pressure in effect immediately prior to the Failure, in
accordance with Item 2 above.
5. Removal or Modification of Pressure Restriction. The pressure restriction required by
the above Items may be removed or modified, as follows:
(A) The Director may allow the removal or modification of the pressure restriction
upon a written request from TETLP demonstrating that restoring the pipeline to
its pre-Failure operating pressure is justified based on a reliable engineering
analysis showing that the pressure increase is safe considering all known defects,
anomalies, and operating parameters of the pipeline.
(B) The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from TETLP demonstrating that temporary
mitigative and preventive measures are being implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director’s
determination will be based on the Failure cause and provision of evidence that
preventive and mitigative actions taken by TETLP provide for the safe operation
of the Affected Segment during the temporary removal or modification of the
pressure restriction. Appeals to determinations of the Director in this regard will
be decided by the Associate Administrator for Pipeline Safety.
6. Instrumented Leakage Survey. Within 180 days of receipt of this Amended Order,
TETLP must perform an aerial or ground instrumented leakage survey of the Affected
Segment. TETLP must investigate all leak indications and remedy all leaks discovered.
TETLP must submit documentation of this survey to the Director within 45 days of the
completion of the leak survey.
7. Records Verification. As recommended in PHMSA Advisory Bulletin 2012-06, verify
the records for the Affected Segment to confirm the maximum allowable operating



CPF No. 2-2019-1002H
Page 7
pressure (MAOP). The Affected Segment is bi-directional with two different MAOPs.
TETLP must confirm the MAOPs for both flow directions. TETLP must submit
documentation of this records verification to the Director within 45 days of receipt of this
Amended Order.
8. Review of Prior ILI Results. Within 30 days of receipt of this Amended Order, conduct
a review of the previous ILI results of the Affected Segment. TETLP must re-evaluate all
ILI results from the past 20 calendar years, include a review of the ILI vendors’ raw data
and analysis. TETLP must determine whether any features were present in the failed
pipe joint and/or any other pipe removed. Also, TETLP must determine if any features
are present elsewhere on the Affected Segment. TETLP must submit documentation of
this ILI review to the Director within 45 days of receipt of this Amended Order as
follows:
(A) List all ILI tool runs, tool types, and the calendar years of the tool runs.
(B) List, describe (type, size, wall loss, etc.), and identify the specific location of all
ILI features present in the failed joint and/or other pipe removed.
(C) Explain the process used to review the ILI results and the results of the
reevaluation.
TETLP has begun this re-evaluation and has been submitting monthly reports to the
Director, along with additional data. The latest report was received on March 11, 2020.
9. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing, including
failure analysis will be performed by the NTSB in accordance with NTSB procedures and
protocols. In the event the NTSB does not perform these functions, TETLP will be
responsible for completing all testing and analysis. If the NTSB does not perform the
analysis, TETLP must submit to the Director for prior approval a plan to complete the
testing and analysis.
10. Root Cause Failure Analysis. The NTSB will perform a root cause failure analysis
(RCFA) to determine the cause of the Failure. TETLP must incorporate the findings the
NTSB RCFA into its integrity management plan and operations and maintenance manual.
If the NTSB does not perform these tasks, TETLP must submit to the Director for prior
approval a plan to complete an RCFA.
11. Emergency Response Plan and Training Review. TETLP must review and assess the
effectiveness of its emergency response plan and operational actions with regards to the
Failure. TETLP must include in the review and assessment the on-scene response and
support, coordination, and communication with emergency responders and public
officials. Also, TETLP must include a review and assessment of the effectiveness of its
emergency training program. TETLP must amend its emergency response plan and
emergency training, if necessary, to reflect the results of this review. The documentation
of this Emergency Response Plan and Training Review must be included in the CAO
Documentation Report (see Item 14 for description of the CAO Documentation Report).



CPF No. 2-2019-1002H
Page 8
12. Public Awareness Program Review. TETLP must review and assess the effectiveness of
its Public Awareness Program with regards to the Failure. TETLP must amend its Public
Awareness Program, if necessary, to reflect the results of this review. The documentation
of this Public Awareness Program Review must be provided to the Director.
13. Remedial Work Plan (RWP).
(A) TETLP must submit a Remedial Work Plan (RWP) to the Director for approval
by August 2, 2020.
(B) The Director may approve the RWP incrementally without approving the entire
RWP.
(C) Once approved by the Director, the RWP will be incorporated by reference into
this Amended Order.
(D) The RWP must specify the tests, inspections, assessments, evaluations, and
remedial measures TETLP will use to verify the integrity of the Affected
Segment. The RWP must address all known or suspected factors and causes of
the Failure. TETLP should consider both the risks and consequences of another
failure arising from the same root cause as the August 1, 2019 Failure to develop
a prioritized schedule for RWP related work along the Affected Segment.
(E) The RWP must include a procedure or process to:
i. Identify pipe in the Affected Segment with characteristics similar to the
contributing factors identified for the Failure.
ii. Gather all data necessary to review the failure history (in service and
pressure test failures) of the Affected Segment and to prepare a written
report containing all the available information such as the locations, dates,
and causes of leaks and failures.
iii. Integrate the results and conclusions of the NTSB’s metallurgical testing
as well as those of the final RCFA, and other corrective actions required
by this Amended Order with all relevant pre-existing operational and
assessment data for the Affected Segment. Pre-existing operational data
includes, but is not limited to, construction, operations, maintenance,
testing, repairs, prior metallurgical analyses, and any third-party
consultation information. Pre-existing assessment data includes, but is not
limited to, ILI tool runs, hydrostatic pressure testing, direct assessments,
close interval surveys, and DCVG/ACVG surveys.
iv. Determine if conditions similar to those contributing to the Failure are
likely to exist elsewhere on the Affected Segment.
v. Conduct additional field tests, inspections, assessments, and/or evaluations
to determine whether, and to what extent, the conditions associated with
the Failure, and other failures from the failure history (see Item 13(E)(ii),



CPF No. 2-2019-1002H
Page 9
above) or any other integrity threats are present elsewhere on the Affected
Segment. At a minimum, this process must consider all failure causes and
specify the use of one or more of the following:
a. Inline inspection (ILI) tools that are technically appropriate for
assessing the pipeline system based on the cause of Failure, and
that can reliably detect and identify anomalies;
b. Hydrostatic pressure testing;
c. Close-interval surveys;
d. Cathodic protection surveys, to include interference surveys in
coordination with other utilities (e.g. underground utilities,
overhead power lines, etc.) in the area;
e. Coating surveys;
f. Stress corrosion cracking surveys;
g. Selective seam corrosion surveys; and
h. Other tests, inspections, assessments, and evaluations appropriate
for the failure causes.
Note: TETLP may use the results of previous tests, inspections,
assessments, and evaluations if approved by the Director, provided
the results of the tests, inspections, assessments, and evaluations
are analyzed with regard to the factors known or suspected to have
caused the Failure.
vi. Describe the inspection and repair criteria TETLP will use to prioritize,
excavate, evaluate, and repair anomalies, imperfections, and other
identified integrity threats. Include a description of how any defects will
be graded and a schedule for repairs or replacement.
vii. Based on the known history and condition of the Affected Segment,
describe the methods TETLP will use to repair, replace, or take other
corrective measures to remediate the conditions associated with the
pipeline Failure, and to address other known integrity threats along the
Affected Segment. The repair, replacement, or other corrective measures
must meet the criteria specified in Item 13(E)(iv), above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Segment
considering the results of the analyses, inspections, evaluations, and
corrective measures undertaken pursuant to the Amended Order.



CPF No. 2-2019-1002H
Page 10
ix. Implement specific actions TETLP will take on its entire pipeline system
as a result of the lessons learned from work on this Amended Order.
Incorporate lessons learned on TETLP’s entire pipeline system. TETLP
will report lessons learned in the CAO Documentation Report (see Item 14
for description of the CAO Documentation Report).
(F) TETLP must include a proposed schedule for completion of the RWP.
(G) TETLP must revise the RWP as necessary to incorporate new information
obtained during the NTSB and PHMSA’s failure investigation and remedial
activities taken under this Amended Order, to incorporate the results of actions
undertaken pursuant to this Amended Order, and/or to incorporate modifications
required by the Director.
i. TETLP must submit any plan revisions to the Director for prior approval.
ii. The Director may approve plan revisions incrementally.
iii. Any and all revisions to the RWP after it has been approved and
incorporated by reference into this Amended Order will be fully described
and documented in the CAO Documentation Report (CDR).
(H) Implement the RWP as it is approved by the Director, including any revisions to
the plan.
14. CAO Documentation Report (CDR). TETLP must create and revise, as necessary, a
CAO Documentation Report (CDR). When TETLP has concluded all the items in this
Amended Order it will submit the final CDR in its entirety to the Director. This will
allow the Director to complete a thorough review of all actions taken by TETLP with
regards to this Amended Order prior to approving the closure of this Amended Order.
The intent is for the CDR to summarize all activities and documentation associated with
this Amended Order in one document.
(A) The Director may approve the CDR incrementally without approving the entire
CDR.
(B) Once approved by the Director, the CDR will be incorporated by reference into
this Amended Order.
(C) The CDR must include but not be limited to:
i. Table of Contents;
ii. Summary of the pipeline Failure, and the response activities;
iii. Summary of pipe data/properties and all prior assessments of the Affected
Segment;



iv. v. vi. vii. viii. CPF No. 2-2019-1002H
Page 11
Summary of all tests, inspections, assessments, evaluations, and analysis
required by the Amended Order;
Summary of the Mechanical and Metallurgical Testing as required by the
Amended Order;
Documentation of all actions taken by TETLP to implement the RWP, the
results of those actions, and the inspection and repair criteria used;
Documentation of any revisions to the RWP including those necessary to
incorporate the results of actions undertaken pursuant to this Amended
Order and whenever necessary to incorporate new information obtained
during the failure investigation and remedial activities;
Lessons learned while completing this Amended Order;
ix. A description of specific actions TETLP will take on its entire pipeline
system as a result of the lessons learned from work on this Amended
Order; and
x. Appendices (if required).
Other Requirements:
1. Reporting. Submit monthly reports to the Region Director that: (1) include all available
data and results of the testing and evaluations required by this Amended Order; and (2)
describe the progress of the repairs or other remedial actions being undertaken. The first
monthly report for the period August 1 through August 31 is due on September 15, 2019.
The Region Director may change the interval for the submission of these reports.
2. Documentation of Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Amended Order.
Include in each monthly report the to-date total costs associated with: (1) preparation and
revision of procedures, studies and analyses; (2) physical changes to pipeline
infrastructure, including repairs, replacements and other modifications; and (3)
environmental remediation, if applicable.
3. Approvals. With respect to each submission requiring the approval of the Region
Director, the Region Director may: (a) approve the submission in whole or in part; (b)
approve the submission on specified conditions; (c) modify the submission to cure any
deficiencies; (d) disapprove the submission in whole or in part and direct Respondent to
modify the submission; or (e) any combination of the above. In the event of approval,
approval upon conditions, or modification by the Region Director, Respondent shall
proceed to take all action required by the submission, as approved or modified by the
Region Director. If the Region Director disapproves all or any portion of a submission,
Respondent must correct all deficiencies within the time specified by the Region Director
and resubmit it for approval.



CPF No. 2-2019-1002H
Page 12
4. Extensions of Time. The Region Director may grant an extension of time for compliance
with any of the terms of this Amended Order upon a written request timely submitted and
demonstrating good cause for an extension.
5. 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).
In your correspondence on this matter, please refer to “CPF No. 2-2019-1002H” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Amended Order are in addition to and do not waive any requirements
that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any
other order issued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other
provision of Federal or State law.
Respondent may appeal any decision of the Region Director to the Associate Administrator for
Pipeline Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Amended Order may result in the assessment of civil penalties and in
referral to the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Amended Order are effective upon service in accordance with
49 C.F.R. § 190.5.
April 28, 2020
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220191002H>
- Source ID: `phmsa-enforcement`
- SHA-256: `039974e8b15a368e07503cca86d37a58f5d9c774d8f30c0de6d50142ab2ed325`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T18:52:04.142Z
- Document slug: `phmsa-enforcement-220191002h`

### Source metadata

```json
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  "operator": "TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP)",
  "region": "Southern",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 8,
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  ],
  "extractedAgencyDocumentCount": 4,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP)"
}
```