# ENBRIDGE ENERGY, LIMITED PARTNERSHIP — Notice of Probable Violation

**Citation:** CPF 320125013  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2012-07-05

CLOSED notice of probable violation citing 195.401(b), 195.402(a), 195.440(c), 195.452(h)(2), 195.452(h)(4), 195.452(i)(1), 195.452(i)(2)(i), 195.452(i)(2)(ii), 195.452(i)(2)(iii), 195.452(i)(2)(iv), 195.452(j)(2), 195.505(c), 195.52(a), 195.52(b), 195.54(a), 195.54(b).

## Document text

Notice of Probable Violation involving ENBRIDGE ENERGY, LIMITED PARTNERSHIP. PHMSA's enforcement data identifies the cited regulations as 195.401(b),  195.402(a),  195.440(c),  195.452(h)(2),  195.452(h)(4),  195.452(i)(1),  195.452(i)(2)(i),  195.452(i)(2)(ii),  195.452(i)(2)(iii),  195.452(i)(2)(iv),  195.452(j)(2),  195.505(c),  195.52(a),  195.52(b),  195.54(a),  195.54(b). The case was opened on 2012-07-05 and is reported as closed as of 2012-09-07. Proposed civil penalty: $3,699,200. Assessed civil penalty: $3,699,200. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320125013_Final Order_09072012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125013/320125013_Final%20Order_09072012.pdf

320125013_Final Order_09072012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125013/320125013_Final%20Order_09072012_text.pdf

320125013_Operator_Response_to_Notice_08102012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125013/320125013_Operator_Response_to_Notice_08102012.pdf

320125013_REVISED_NOPV_PCP_07052012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125013/320125013_REVISED_NOPV_PCP_07052012.pdf

320125013_REVISED_NOPV_PCP_07052012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125013/320125013_REVISED_NOPV_PCP_07052012_text.pdf

320125013_Final Order_09072012_text.pdf

September 07 2012
Mr. Richard Adams
Vice President, U.S. Operations
Enbridge Energy, Limited Partnership
City Center Office
1409 Hammond, Avenue
Superior, WI 54880-5247
CPF 3-2012-5013
Dear Mr. Adams:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation of PHMSA regulations and assesses an administrative civil penalty of $3,699,200. This
is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated
August 10, 2012. This enforcement action is now closed. Service of the Final Order by certified
mail is deemed effective upon the date of mailing, or as otherwise provided under
49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. David Coburn, Esq., Counsel for Respondent,
Steptoe & Johnson LLP, 1330 Connecticut Avenue, NW, Washington, DC 20036-1795
Mr. David Barrett, Director, Central Region, OPS
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
CERTIFIED MAIL - RETURN 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 )
Enbridge Energy, Limited Partnership, ) )
)
)
Respondent. )
____________________________________)
CPF No. 3-2012-5013
FINAL ORDER
Beginning on July 26, 2010, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), initiated
an investigation of an accident involving the Line 6B pipeline system operated by Enbridge
Energy, Limited Partnership (Enbridge or Respondent). Respondent is a subsidiary of Enbridge,
Inc., a Canadian company, and owns and operates approximately 17,700 miles of pipeline
transporting crude oil and natural gas in the Midwest. Line 6B is a part of Respondent’s
Lakehead Pipeline System.1
The investigation followed a failure that occurred on Enbridge’s 30-inch diameter Line 6B
pipeline near Marshall, Michigan, on July 25, 2010, and that ultimately resulted in the release of
more than 20,000 bbls of crude oil (Release).
2 The pipeline ruptured at approximately
17:58 EDT (all times cited below are Eastern Daylight Time, unless otherwise noted) on
July 25, 2010, approximately 0.6 miles downstream of the company’s Marshall pumping station,
while its Control Center Operations (CCO) in Edmonton, Alberta (Canada), was in the process of
executing a scheduled 10-hour shutdown of the pipeline (Scheduled Shutdown), as more fully
detailed in the Notice.
The investigation revealed a number of probable violations of regulations promulgated under the
federal Pipeline Safety Laws. As a result, the Director, Central Region, OPS (Director), issued
to Respondent, by letter dated July 2, 2012, a Notice of Probable Violation and Proposed Civil
1 SEC Form 10-K, Enbridge Energy Partners, LP, February 2011, at 6. Respondent also files annual reports with
PHMSA under the name Enbridge Energy, Limited Partnership, which is a subsidiary of Enbridge Energy Partners,
LP.
2 On July 28, 2010, PHMSA issued a Corrective Action Order (CAO) [CPF No. 3-2010-5008H] to Enbridge,
finding that Line 6B would be hazardous to life, property and the environment unless Enbridge took certain
corrective actions. Among other things, the CAO required a pressure reduction on the re-started line; testing and
evaluation of the failed pipe; submission of a plan for verification of pipeline integrity; and integration of various
assessment information to ensure the ongoing safe operation of the pipeline, considering all risk factors. That CAO
is still open.



2
Penalty. In accordance with 49 C.F.R. § 190.207, it proposed finding that Enbridge had
committed various violations of 49 C.F.R. Part 195 and proposed assessing an administrative
civil penalty of $3,699,200 for the alleged violations. On July 5, 2012, PHMSA issued a
corrected Notice of Probable Violation and Proposed Civil Penalty (Notice) to address several
typographical errors in the original letter. The Notice advised Enbridge that it had a right to
contest the allegations.
Enbridge submitted a preliminary response by letter on July 6, 2012. On August 10, 2012, the
company paid the proposed administrative civil penalty of $3,699,200, as provided under
49 C.F.R. § 190.209(a)(1). The company also submitted a formal response by letter of the same
date (Response). The Response stated that the company was not contesting the proposed
penalty, but indicated that Enbridge took “issue with many of the allegations set forth in the
NOPV” and “respectfully request[ed] that PHMSA take this [letter] into consideration.”3 Under
49 C.F.R. § 190.209(a)(1), however, payment of the penalty serves to close the case with
prejudice to Respondent. Therefore, the additional information provided and the defenses
asserted by Respondent are neither discussed nor considered in this Order. The findings and
conclusions set forth below are based entirely on the information referenced in the Notice and
discussed in this Order, insofar as such information relates to the specific regulatory violations
alleged in the Notice.
FINDINGS OF VIOLATION
In its Response, Enbridge, by counsel, did not contest the penalties proposed in the Notice for
the alleged violations of 49 C.F.R. Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(h)(1)-(2), which
states, in relevant part:
§ 195.452 4
Pipeline integrity management in high consequence areas.
(a) . . .
(h) What actions must an operator take to address integrity issues?
(1) General requirements. An operator must take prompt action to
address all anomalous conditions the operator discovers through the integrity
assessment or information analysis. In addressing all conditions, an operator
must evaluate all anomalous conditions and remediate those that could reduce
a pipeline’s integrity…
(2) Discovery of condition. Discovery of a condition occurs when an
operator has adequate information about the condition to determine that the
condition presents a potential threat to the integrity of the pipeline. An operator
must promptly, but no later than 180 days after an integrity assessment, obtain
sufficient information about a condition to make that determination, unless the
3 Response at 1.
4 High Consequence Areas (HCAs) are defined as high population areas, other populated areas, unusually sensitive
areas, and commercially navigable waterways. See 49 C.F.R. § 195.450.



3
operator can demonstrate that the 180-day period is impracticable.
The Notice alleged that Respondent violated 49 C.F.R. § 195.452(h)(1)-(2) by failing to
promptly obtain sufficient information about anomalous conditions on Line 6B to make a
determination that the conditions presented a potential threat to the integrity of the pipeline and
to take prompt action to address those conditions that could reduce the pipeline’s integrity.
Specifically, the Notice alleged that Enbridge failed, within 180 days after receiving a
contractor’s report on a high-resolution MFL integrity assessment that had been conducted on
Line 6B on October 13, 2007, to obtain sufficient information about the anomalies noted in the
report to determine whether they posed a potential threat to the integrity of the pipeline.
PHMSA asserted that the 180-day deadline was April 10, 2008, but that Enbridge failed to
implement pressure restrictions until July 17, 2009, approximately 462 days after the 180-day
deadline.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.452(h)(1)-(2)
by failing to promptly obtain sufficient information about anomalous conditions on Line 6B to
make a determination that the conditions presented a potential threat to the integrity of the
pipeline and to take prompt action to address such conditions.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(h)(4), which states, in
relevant part:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) . . .
(h) What actions must an operator take to address integrity issues?
(1) . . .
(4) Special requirements for scheduling remediation – (i) . . .
(iii) 180-day conditions. Except for conditions listed in paragraph (h)(4)(i)
or (ii) of this section, an operator must schedule evaluation and remediation of
the following within 180 days of discovery of the condition:…
(H) Corrosion of or along a longitudinal seam weld. . . .
(iv) Other conditions. In addition to the conditions listed in paragraphs
(h)(4)(i) through (iii) of this section, an operator must evaluate any condition
identified by an integrity assessment or information analysis that could impair
the integrity of the pipeline, and as appropriate, schedule the condition for
remediation. Appendix C of this part contains guidance concerning other
conditions that an operator should evaluate.
The Notice alleged that Respondent violated 49 C.F.R. § 195.452(h)(4) by failing to properly
schedule the evaluation and remediation of certain anomalous conditions that were required to be
remediated within 180 days of their discovery. Specifically, it alleged that, beginning with a
2004 Ultra-Sonic Wall Measurement (USWM) in-line inspection (ILI), Enbridge did not
schedule remediation of corrosion anomalies involving the longitudinal weld seam of pipe joint
#217720 within 180 days of discovery of the conditions, as required by§ 195.452(h)(4)(iii)(H).5
5 Pipeline Safety Violation Report (July 2, 2012) (Violation Report), Exhibit B.



4
The Notice further alleged that Enbridge failed to remediate other crack-like anomalies on the
same pipe joint #217720, as required by § 195.452(h)(4)(iii)(H) and in accordance with the
guidance set forth in Part 195, Appendix C(VII)(D) for scheduling remediation of anomalous
conditions.6 According to the Notice, assessments of this pipe joint had revealed corrosion or
crack-like anomalies that were longitudinal in orientation but Enbridge had failed to select the
joint for excavation. This same joint ultimately ruptured in service on July 25, 2012, resulting in
a release of crude oil.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.452(h)(4) by
failing to properly schedule the evaluation and remediation of certain anomalous conditions on
Line 6B that had to be remediated within 180 days of their discovery.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(i)(1) and (2)(i)-(iv),
which state, in relevant part:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) . . .
(i) What preventive and mitigative measures must an operator take to
protect the high consequence area? - (1) General requirements. An operator
must take measures to prevent and mitigate the consequences of a pipeline
failure that could affect a high consequence area. These measures include
conducting a risk analysis of the pipeline segment to identify additional actions
to enhance public safety or environmental protection. . .
(2) Risk analysis criteria. In identifying the need for additional preventive
and mitigative measures, an operator must evaluate the likelihood of a pipeline
release occurring and how a release could affect the high consequence area.
This determination must consider all relevant risk factors, including, but not
limited to:
(i) Terrain surrounding the pipeline segment, including drainage systems
such as small streams and other smaller waterways that could act as a conduit to
the high consequence area;
(ii) Elevation profile;
(iii) Characteristics of the product transported;
(iv) Amount of product that could be released; . . . .
6 Appendix C(VII) states, in relevant part:
VII. Conditions that may impair a pipeline’s integrity.
Section 195.452(h) requires an operator to evaluate and remediate all pipeline integrity
issues raised by the integrity assessment or information analysis. An operator must develop
a schedule that prioritizes conditions discovered on the pipeline for evaluation and
remediation. The following are some examples of conditions that an operator should
schedule for evaluation and remediation:
A . . .
D. An anomaly longitudinal on orientation….



5
The Notice alleged that Respondent violated 49 C.F.R. § 195.452(i)(1) and (2)(i-iv) by failing to
perform a proper risk analysis to identify the need for additional preventive and mitigative
measures to protect HCAs. Specifically, the Notice alleged that in preparing its risk analysis,
Enbridge failed to consider all relevant risk factors associated with the determination of the
amount of product that could potentially be released from a rupture on Line 6B.7
PHMSA asserted that Enbridge’s risk analysis process assumed a pipeline rupture of this
magnitude would be identified by instrumentation (SCADA and Leak Detection System) within
five minutes and that remotely-operated valves on either side of the rupture would be closed
within an additional three minutes.8 The Notice alleged that the company’s risk analysis should
have considered that the amount of product that could potentially be released would be impacted
by different operating scenarios, including transient conditions such as start-ups and shutdowns
or personnel response to abnormal operating conditions.9
Prior to the Failure, Enbridge estimated the worst-case scenario for an oil release at the Mile Post
(MP) 608 location would be 1,670 bbls initial volume out, plus 1,938 bbls stabilization loss
(drain down), or a total release of 3,608 bbls.10 The Notice alleged that the Failure demonstrated
that Enbridge had not properly recognized the risk associated with the actual release scenario, as
the isolation valves did not close until approximately 17 hours after the release occurred. It
further alleged that at least 20,000 bbls were actually released, 16,431 bbls more than Enbridge’s
worst-case scenario.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.452(i)(1) and
(2)(i)-(iv) by failing to perform a proper risk analysis to identify the need for additional
preventive and mitigative measures to protect HCAs.
Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(j)(2), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) . . .
(j) What is a continual process of evaluation and assessment to maintain a
pipeline’s integrity? - (1) General. After completing the baseline integrity
assessment, an operator must continue to assess the line pipe at specified
intervals and periodically evaluate the integrity of each pipeline segment that
could affect a high consequence area….
(2) Evaluation. An operator must conduct a periodic evaluation as
frequently as needed to assure pipeline integrity. An operator must base the
7 Violation Report, Exhibit B.
8 Id.
9 Violation Report, Exhibits B and C.
10 Violation Report, Exhibit C.



6
frequency of evaluation on risk factors specific to its pipeline, including the
factors specified in paragraph (e) of this section. The evaluation must consider
the results of the baseline and periodic integrity assessments, information
analysis (paragraph (g) of this section), and decisions about remediation, and
preventive and mitigative actions (paragraphs (h) and (i) of this section).
The Notice alleged that Respondent violated 49 C.F.R. § 195.452(j)(2) by failing to conduct
periodic evaluations as frequently as needed to assure pipeline integrity, based upon an analysis
of risk factors specific to its pipeline. Specifically, the Notice alleged that Enbridge did not
properly consider the results of corrosion and cracking assessments it had performed, nor did it
integrate the information from these assessments to properly ensure overall pipeline integrity.
According to the Notice, the PHMSA investigation, witness interviews, and a review of prior ILI
assessments of Line 6B (including 2004 USWM, 2005 USCD, 2007 MFL, and 2009 USWM
assessments) revealed that Enbridge had a long history of performing integrity assessments using
ILI tools, but that those assessment results had been evaluated independently and not properly
integrated in a fashion that would ensure pipeline integrity.
11
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.452(j)(2) by
failing to conduct periodic evaluations as frequently as needed to assure pipeline integrity, based
upon an analysis of risk factors specific to its pipeline.
Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.401(b), which states:
§ 195.401 General requirements.
(a) . . .
(b) Whenever an operator discovers any condition that could adversely
affect the safe operation of its pipeline system, it shall correct it within a
reasonable time. However, if the condition is of such a nature that it presents an
immediate hazard to persons or property, the operator may not operate the
affected part of the system until it has corrected the unsafe condition.12
The Notice alleged that Respondent violated 49 C.F.R. § 195.401(b) by failing to correct, within
a reasonable time after discovery, conditions that could adversely affect the safe operation of its
pipeline. Specifically, the Notice alleged that Enbridge failed to correct conditions that it
discovered as a result of a series of SCADA/instrumentation alarms and events occurring within
seconds and minutes of the Failure, including a 5-minute MBS (Material Balance System) alarm,
a Unit Shutdown on Low Suction Pressure, Low Pressure Alarms, and an abnormal and abrupt
pressure drop (to 0 psig) at the Marshall pumping station.
PHMSA asserted that the SCADA/instrumentation alarms and events indicated conditions that
11 Violation Report, Exhibits B, C and D.
12 Section 195.401 was amended subsequent to the date of the Failure, effective August 11, 2010.



7
could adversely affect the safe operation of the pipeline unless and until they were determined to
have been the result of known conditions that did not affect the safe operation of the pipeline.
The Notice alleged that Enbridge failed to investigate and mitigate the effects of such unsafe
conditions until approximately 17 hours after their discovery.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.401(b) by
failing to correct, within a reasonable time following discovery, conditions that could adversely
affect the safe operation of its pipeline.
Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (d)(1) and
(3-4), which states in relevant part:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
This manual shall be reviewed at intervals not exceeding 15 months, but at least
once each calendar year, and appropriate changes made as necessary to insure
that the manual is effective . . . .
(d) Abnormal operation. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety when
operating design limits have been exceeded:
(1) Responding to, investigating, and correcting the cause of:
(i) Unintended closure of valves or shutdowns;
(ii) Increase or decrease in pressure or flow rate outside normal operating
limits;
(iii) Loss of communications;
(iv) Operation of any safety device;
(v) Any other malfunction of a component, deviation from normal
operation, or personnel error which could cause a hazard to persons or
property. . .
(3) Correcting variations from normal operation of pressure and flow
equipment and controls.
(4) Notifying responsible operator personnel when notice of an abnormal
operation is received.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (d)(1) and (3-4) by
failing to follow a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies. Specifically, the
Notice alleged that Enbridge did not follow its own written procedures for responding to,
investigating, and correcting the cause of pressure events outside of normal operating limits
(LPM Invalid Pressure Alarms) that had been indicated during a scheduled 10-hour shutdown of
Line 6B (Scheduled Shutdown).13 The Notice further alleged that Enbridge did not notify
13 Violation Report, Exhibits E and F.



8
responsible personnel in accordance with the procedure.
PHMSA alleged that Respondent’s Line 6B controller had initiated the Scheduled Shutdown at
approximately 17:55 EDT. Beginning at 17:58, Line Pressure Monitor (LPM) Invalid Pressure
alarms at the Marshall pumping station had initiated and then cleared within a few seconds. The
Notice alleged that the LPM alarm occurred when the SCADA system sensed one or more
pressure transmitters at 0 psig, and then cleared when the pressure went above 0 psig.14 This
cycle repeated six times before it finally remained active at 18:02. The LPM alarm had been
designated by Enbridge procedures as a Severity Level 6 (S6 - Severe) Alarm.
PHMSA asserted that Enbridge had not developed a specific written procedure for responding to
an LPM Invalid Pressure Alarm, but had instead developed a written procedure for required
actions based on alarm severity. For an S6 -Severe Alarm, the procedures required the controller
to: (1) notify the Shift Lead; (2) advise on­site/on-call personnel; and (3) create a “FACMAN”
(an Enbridge term for a Facility Management record-keeping system used to document abnormal
operating conditions).15 PHMSA alleged that Enbridge failed to take any of these required
actions.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
(d)(1) and (3-4) by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 195. 402(a) and (d)(1) and
(3-4), as quoted above, by failing to follow a manual of written procedures for conducting
normal operations and maintenance activities and handling abnormal operations and
emergencies. Specifically, the Notice alleged that Enbridge did not follow its own written
procedures for responding to, investigating, and correcting the cause of pressure events outside
of normal operating limits (Low Pressure Alarms) that had been indicated during the Scheduled
Shutdown.16 The Notice further alleged that Respondent did not notify responsible personnel in
accordance with the procedure.
PHMSA alleged that the company’s Line 6B controller had initiated the Scheduled Shutdown at
approximately 17:55 on July 25, 2010. Beginning at 17:58, a Low Suction Pressure alarm
initiated, cleared within five seconds, then recurred and remained active 10 seconds later. The
Notice alleged that this alarm occurred when the suction pressure dropped below 25 psig, and
cleared when the suction pressure exceeded 25 psig. This alarm had been designated by
Enbridge procedures as a Severity Level 4 (S4- Warning) Alarm.17
14 Id.
15 Violation Report, Exhibit F.
16 Violation Report, Exhibit E.
17 Violation Report, Exhibit E.



9
PHMSA asserted that Enbridge had not developed a specific written procedure for responding to
a Low Suction Pressure Alarm, but had instead developed a written procedure for required
actions based on alarm severity. PHMSA explained that for an S4 -Warning Alarm, the
procedures required: (1) discretionary controller response to the alarm, depending on operating
conditions; (2) notification of the Shift Lead if unsure of response; (3) if multiple S4 alarms were
active for a related issue, the response and severity might be raised; (4) FACMAN creation might
be required; and (5) advising on-site/on-call personnel if required. PHMSA further asserted that
Enbridge had not taken any of the above actions, or any other actions, in response to this alarm.
PHMSA alleged that when the Marshall suction pressure abruptly dropped to 0 psig (which was
unexpected and abnormal), the drop dictated follow­up investigative actions in accordance with
the procedure to determine the reason/source of the alarm.
18
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
(d)(1) and (3-4) by failing to follow its own written procedures for conducting normal operations
and maintenance activities and handling abnormal operations and emergencies.
Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (d)(1) and
(3-4), as quoted above, by failing to follow a manual of written procedures for conducting
normal operations and maintenance activities and handling abnormal operations and
emergencies. Specifically, the Notice alleged that Enbridge did not follow its own written
procedures for responding to, investigating, and correcting the cause of an unintended shutdown
(Marshall Unit 2 was in Sequence Off Alarm) that occurred during the Scheduled Shutdown.
The Notice further alleged that Enbridge did not notify responsible personnel, as required by its
procedure.
PHMSA alleged that the Line 6B controller had initiated the Scheduled Shutdown at
approximately 17:55 on July 25, 2010. At 17:58, a Marshall Unit 2 Sequence Off Alarm
occurred, indicating that the Programmable Logic Controller (PLC) for the Marshall station had
stopped Unit 2 based on a condition sensed by the station control logic, which, in this
circumstance, was low suction pressure.19 PHMSA asserted that the alarm had been designated
by Enbridge procedures as a Severity Level 4 (S4-Warning) Alarm.20 Enbridge’s written
procedure for Pump Unit Lockout ­ Station required the controller to enter lockout information in
FACMAN.21 However, no FACMAN was created in response to this alarm. The Notice alleged
that Enbridge’s failure to respond to, investigate, and correct the cause of an unintended
shutdown resulted in a missed opportunity to identify the Failure when it occurred.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
18 Violation Report, Exhibits E and F.
19 Violation Report, Exhibit F.
20 Violation Report, Exhibit E.
21 Violation Report, Exhibit G.



10
(d)(1) and (3-4) by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Item 9: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (e)(4) and (7),
which states in relevant part:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
This manual shall be reviewed at intervals not exceeding 15 months, but at least
once each calendar year, and appropriate changes made as necessary to insure
that the manual is effective . . . .
(e) Emergencies. The manual required by paragraph (a) of this section
must include procedures for the following to provide safety when an emergency
condition occurs:
(1) . . .
(4) Taking necessary action, such as emergency shutdown or pressure
reduction, to minimize the volume of hazardous liquid or carbon dioxide that is
released from any section of a pipeline in the event of a failure . . . .
(7) Notifying fire, police, and other appropriate public officials of
hazardous liquid or carbon dioxide pipeline emergencies and coordinating with
them preplanned and actual responses during an emergency, including
additional precautions necessary for an emergency involving a pipeline system
transporting a highly volatile liquid.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (e)(4) and (7) by failing
to follow a manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. Specifically, the Notice alleged
that Enbridge failed to follow its Emergency Notification procedure, which required the company
to take necessary action to minimize the volume of hazardous liquid released when the Failure
occurred and to notify fire, police and other public officials during the emergency.22 The Notice
further alleged that Enbridge’s Suspected Column Separation procedure required the Shift Lead
to execute the Emergency Notification procedure.23
PHMSA alleged that a Suspected Column Separation condition was identified and reported to
the Shift Lead by CCO support personnel (an MBS Analyst) shortly after the Scheduled
Shutdown. The Line 6B controller initiated the Scheduled Shutdown at approximately 17:55 on
July 25, 2010. At 18:03, an MBS 5-Minute Alarm for the Griffith to Marshall section of Line 6B
occurred.24 The alarm was reported by the controller to the Shift Lead, who requested MBS
22 Violation Report, Exhibits E, F, and H.
23 Violation Report, Exhibit H.
24 The MBS 5-Minute Alarm is designated by Respondent as a Severity Level 6 (S6-Severe) Alarm. Id.



11
Support to analyze the leak detection alarm. The MBS Analyst reported back to the controller
(via telephone) and the Shift Lead (in person), that the MBS model was indicating column
separation, a condition in which the pipeline pressure is less than the vapor pressure of the
product. PHMSA asserted that although Enbridge’s written procedure, Suspected Column
Separation, required the Shift Lead to execute the Emergency Notification procedure, the Shift
Lead failed to do so. Execution of this procedure would have resulted in notification of Regional
Management (and field personnel), police and other public officials, and the CCO Admin On-
Call or Designate.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195. 402(a) and
(e)(4) and (7) by failing to follow its own manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Item 10: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (e)(4) and (7),
as quoted above, by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Specifically, the Notice alleged that Enbridge failed to follow its Emergency Notification
procedure that required it to take necessary action to minimize the volume of hazardous liquid
released when a failure occurred and to notify police and other public officials during an
emergency.25 It alleged that Enbridge failed to follow its Leak Triggers- SCADA Data
procedure, which required that if one or two leak triggers occurred, then Respondent must
execute its Suspected Leak procedure.26 The Notice also alleged that Enbridge failed to follow
its Confirmed Leak procedure, which required that if three or more triggers occurred, then the
Confirmed Leak procedure must be executed. PHMSA asserted that neither the Suspected Leak
procedure nor the Confirmed Leak procedure was executed by the CCO in response to the Leak
Triggers that occurred shortly after the Scheduled Shutdown.
PHMSA alleged that the Line 6B controller initiated the Scheduled Shutdown at approximately
17:55 on July 25, 2010. The pipeline ruptured at approximately 17:58, approximately 0.6 miles
downstream of the Marshall pumping station, resulting in a sudden drop in upstream discharge
pressure (0 psig). Multiple alarms and events were received within seconds of the rupture,
including low suction pressure at the Marshall pumping station, a shutdown at the Marshall
station, and invalid pressure(s) at the station. A 5-Minute MBS alarm occurred on the Griffith to
Marshall section of Line 6B at 18:03. These alarms and events all constituted Leak Triggers.
PHMSA asserted that had Enbridge followed either procedure, it would have led to the execution
of the Emergency Notification procedure by the Shift Lead, and Enbridge would have notified
Regional/Field personnel, police and other public officials, and the CCO Admin On-Call or
Designate.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
25 Violation Report, Exhibit I.
26 Id.



12
(e)(4) and (7) by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Item 12: The Notice alleged that Respondent violated 49 C.F.R. § 195.401(b), as quoted above,
by continuing to operate its pipeline system without correcting a condition that presented an
immediate hazard to persons or property. Specifically, the Notice alleged that at approximately
04:00 on July 26, 2010, Enbridge initiated the scheduled start-up of Line 6B after an
approximate 10-hour shutdown (First Restart).27 Enbridge was unable to build pressure at the
Marshall pumping station and multiple alarms occurred within minutes of initiating operation.
Alarms continued throughout the operation but Enbridge did not terminate the attempted First
Restart until after approximately one hour of operation.
The Notice alleged that approximately 10,600 bbls of crude oil was injected into the pipeline
during the First Restart, which increased the size of the release and resulted in the displacement
of a number of local residents, contamination of approximately 38 miles of the Kalamazoo River,
and contamination of affected fish and wildlife.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.401(b) by
operating its pipeline system without correcting a condition that presented an immediate hazard
to persons or property.
Item 13: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (e)(4), as
quoted above, by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Specifically, the Notice alleged that shortly after initiating the First Restart, Enbridge failed to
follow its own MBS Leak Alarm procedure, which required that if a leak detection (MBS) alarm
occurred, then the controller was to notify the Shift Lead and record the AOC (Abnormal
Operating Condition) in FACMAN.28 The procedure then required the Shift Lead to assess the
alarm and take appropriate action based on the assessment.
Recorded telephone transcripts and witness interviews indicated that the Line 6B controller
contacted the Shift Lead at 04:23, but did not specifically report that MBS alarms had occurred.
Then, the controller reported to the Shift Lead that the MBS was starting to react to some flow in
the area, but no FACMAN was created to record the AOC.
As discussed above, Respondent’s MBS Leak Alarm procedure required the Shift Lead to assess
an MBS alarm. If there were any doubt about the reliability of the leak detection model, the
Shift Lead must then execute the MBS Alarm-Analysis by MBS Support procedure. This required
that if, after 10 minutes, the analysis of the alarm was not complete then the pipeline was to be
shut down. Enbridge neither followed this procedure nor shut down the pipeline until 48 minutes
27 Violation Report, Exhibit K.
28 Violation Report, Exhibits K and L.



13
after the first MBS alarm occurred.
29
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
(e)(4) by failing to follow its manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
Item 14: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (d)(1) and
(3)-(4), which state, in relevant part:
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each pipeline
system a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
This manual shall be reviewed at intervals not exceeding 15 months, but at least
once each calendar year, and appropriate changes made as necessary to insure
that the manual is effective. . . .
(d) Abnormal operation. The manual required by paragraph (a) of this
section must include procedures for the following to provide safety when
operating design limits have been exceeded:
(1) Responding to, investigating, and correcting the cause of:
(i) Unintended closure of valves or shutdowns;
(ii) Increase or decrease in pressure or flow rate outside normal operating
limits;
(iii) Loss of communications;
(iv) Operation of any safety device;
(v) Any other malfunction of a component, deviation from normal
operation, or personnel error which could cause a hazard to persons or
property. . .
(3) Correcting variations from normal operation of pressure and flow
equipment and controls.
(4) Notifying responsible operator personnel when notice of an abnormal
operation is received. . . .
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (d)(1) and (3)-(4) by
failing to follow a manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies. Specifically, the
Notice alleged that Enbridge did not follow its procedure for responding to, investigating, and
correcting the cause of pressure outside of normal operating limits (Suspected Column
Separation) and for notifying responsible personnel in accordance with the company’s Suspected
Column Separation procedure.30
29 Violation Report, Exhibits K and L.
30 Violation Report, Exhibit H and M.



14
PHMSA alleged that Enbridge’s SCADA information indicated there was zero pressure at the
Marshall pumping station upon the First Restart, which was indicative of Suspected Column
Separation.31 Enbridge’s procedure, Suspected Column Separation, required that if the column
could not be restored within 10 minutes, then the controller must: (1) notify the Shift Lead; (2)
shut down the specific line; (3) sectionalize the line; (4) isolate the line; and (5) execute the
Abnormal Operations Condition Reporting procedure.
Telephone records indicated that the Line 6B controller did notify the Shift Lead at 04:23, just
prior to expiration of the 10 minutes that were allowed from the start of the upstream pumping
station (Mendon).32 SCADA information indicated, however, that the pipeline was not shut
down until approximately 05:00 (thereby exceeding the 10-minute requirement), that the pipeline
was not isolated, and that the Abnormal Operations Condition Reporting procedure was not
executed.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
(d)(1) and (3)-(4) by failing to follow its own written procedures for responding to, investigating,
and correcting the cause of pressure outside of normal operating limits (Suspected Column
Separation) and for notifying responsible personnel in accordance with the company’s Suspected
Column Separation procedure.
Item 15: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) and (e)(4) and (7),
as quoted above, by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Specifically, the Notice alleged that during the First Restart, Enbridge did not follow either its
Emergency Notification or Suspected Column Separation procedure to minimize the volume of
hazardous liquid released in the event of a failure or to notify fire, police, and other appropriate
public officials during an emergency.33
PHMSA alleged that company telephone records indicated that the Line 6B controller reported
problems getting pressure at the Marshall pumping station to the Shift Lead at 04:23, just prior to
expiration of the 10 minutes that were allowed from the start of the upstream pumping station
(Mendon). The Shift Lead then monitored the pressure at the Marshall pumping station and
observed pressures that were indicative of Column Separation. However, the Shift Lead did not
execute the Emergency Notification procedure, which would have resulted in notifications to
Regional Management (and field personnel), police, and other public officials, and the CCO
Admin On-Call or Designate.34
31 Violation Report, Exhibits E and K.
32 Violation Report, Exhibit K.
33 Id.
34 Violation Report, Exhibits K and L.



15
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a) and
(e)(4) and (7), by failing to follow its emergency procedures to minimize the volume of
hazardous liquid released in the event of a failure and failing to notify fire, police, and other
appropriate public officials during an emergency.
Item 16: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), as quoted above,
by failing to follow its manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies. Specifically, the
Notice alleged that during the First Restart, Enbridge personnel used a draft procedure that had
never been officially approved by the company for starting up a pipeline with column separation,
instead of following the company’s approved procedure, Suspected Column Separation.
35 The
Notice further alleged that under Respondent’s officially approved procedure, the line would
have been shut down and isolated and Enbridge management, field personnel, and emergency
responders would have been notified.36
PHMSA alleged that the draft/unapproved procedure included provisions for calculating an
amount of time that would be needed to integrate the column, based on calculations of the
volume drained from the pipeline, and the injection rate of product into the pipeline.37
According to PHMSA, witness interviews revealed that the unapproved procedure had been used
previously in the control room, on a different pipeline, in May 2010 and this fact was used to
justify continued operation of the line during the First Restart.38 Enbridge’s use of the
draft/unapproved procedure resulted in extended operation of the pipeline, additional product
being injected into the pipeline, and an increase in the amount of product released.39
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of all of the evidence, I find that Respondent violated
49 C.F.R. § 195.402(a) by failing to follow its manual of written procedures for conducting
normal operations and maintenance activities and handling abnormal operations and
emergencies.
Item 17: The Notice alleged that Respondent violated 49 C.F.R. § 195.401(b), as quoted above,
by continuing to operate its pipeline after discovering an unsafe condition that presented an
immediate hazard to persons and property. Specifically, the Notice alleged that at
approximately 07:20 on July 26, 2010, the Line 6B controller initiated another start-up of
35 Violation Report, Exhibit M.
36 Id.
37 Id.
38 Violation Report, Exhibits H, L, and M.
39 The Notice alleged that the Line 6B controller’s pod-mate (the person who operated pipelines at the adjacent
console) brought forward the unapproved procedure from May 2010 via an e-mail that had been used previously in
the control room, and that the Shift Lead who was attempting to assist the Line 6B controller used this unapproved
procedure to justify continued operation of Line 6B.



16
the line after discussing the circumstances surrounding the failed First Restart with CCO
Supervisors, support personnel, and On-Call Management (Second Restart). Again, Enbridge
received multiple alarms and indications of abnormal operating conditions but did not terminate the
Second Restart for at least 30 more minutes.
PHMSA alleged that approximately 5,831 bbls of crude oil was injected into the pipeline during
the Second Restart. The attempt to re-start the pipeline delayed corrective actions and allowed
additional oil to drain from the rupture during stabilization. The Notice alleged that the release
resulted in a number of local residents being displaced, the contamination of approximately 38
miles of the Kalamazoo River, and contamination of affected fish and wildlife.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.401(b) by
continuing to operate its pipeline after discovering an unsafe condition that presented an
immediate hazard to persons and property.
Item 18: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), (d)(1) and (3)-(4),
as quoted above, by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Specifically, the Notice alleged that, during the Second Restart, Enbridge did not follow either its
Emergency Notification or Suspected Column Separation procedure for responding to,
investigating, and correcting the cause of variations from normal operation of pressure to
minimize the volume of hazardous liquid released in the event of a failure or notifying fire,
police, and other appropriate public officials during an emergency.40 As noted above in Item 14,
Enbridge’s Suspected Column Separation procedure required that if the column could not be
restored within 10 minutes, then the controller must: (1) notify the Shift Lead; (2) shut down the
specific line; (3) sectionalize the line; (4) isolate the line; and (5) execute the Abnormal
Operations Condition Reporting procedure.
PHMSA alleged that Respondent’s SCADA information demonstrated that suspected column
separation at the Marshall pumping station persisted through the entire Second Restart process.41
The controller, with Shift Lead oversight, commenced the Second Restart after the circumstances
of the failed First Restart were discussed with CCO Supervisors, support personnel, and On-Call
Management.
42 Unit 4 at Mendon pumping station was started at 07:32. The SCADA indicated
that Unit 4 at Mendon was online at 07:35. The column was not restored, which by the
Suspected Column Separation procedure, required the Line 6B controller to shut down the
pipeline within 10 minutes. SCADA information showed that the Line 6B controller finally
began to shut down the line at 07:50, thereby exceeding the 10-minute requirement, that the
pipeline was not isolated and that the Abnormal Operations Condition Reporting procedure was
not executed.
40 Violation Report, Exhibits E and N.
41 Id.
42 Violation Report, Exhibits E, H and L.



17
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a), (d)(1)
and (3)-(4) by failing to follow either its Emergency Notification or its Suspected Column
Separation procedure for responding to variations from normal operation of pressure and flow
equipment and controls or notifying fire, police, and other appropriate public officials during an
emergency.
Item 19: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), (e)(4) and (7), as
quoted above, by failing to follow a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations and emergencies.
Specifically, the Notice alleged that during the Second Restart, Enbridge followed neither its
Emergency Notification nor Suspected Column Separation procedure to minimize the volume of
hazardous liquid released in the event of a failure or to notify fire, police, and other appropriate
public officials during an emergency.
PHMSA alleged that SCADA information indicated there was suspected column separation at
the Marshall pumping station when the Second Restart commenced.43 Enbridge’s Suspected
Column Separation procedure required the Shift Lead to execute the Emergency Notification
procedure if the column could not be restored within 10 minutes. According to PHMSA,
Enbridge’s SCADA information indicated the Second Restart was terminated at 07:50 when the
column could not be restored.44 Telephone records and witness interviews indicated the Shift
Lead monitored operations during the Second Restart but did not execute the Emergency
Notification procedure as required by the Suspected Column Separation procedure.
45
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.402(a), (e)(4)
and (7) by failing to follow its emergency procedures to minimize the volume of hazardous
liquid released in the event of a failure and failing to notify fire, police, and other appropriate
public officials during an emergency.
Item 21: The Notice alleged that Respondent violated 49 C.F.R. § 195.52(b), which states, in
relevant part:
§ 195.52 Telephonic notice of certain accidents.
(a) At the earliest practicable moment following discovery of a release of
hazardous liquid or carbon dioxide transported resulting in an event described in
§ 195.50, the operator of the system shall give notice, in accordance with
paragraph (b) of this section . . .
(b) Reports made under paragraph (a) of this section are made by telephone
to 800-424-8802 (in Washington, DC, 20590-0001 (202) 372-2428) and must
43 Violation Report, Exhibit H.
44 Violation Report, Exhibit E.
45 Violation Report, Exhibit L.



18
include the following information: . . .
(4) The time of the failure. . .
(6) All other significant facts known by the operator that are relevant to the
cause of the failure or extent of the damages.
46
The Notice alleged that Respondent violated 49 C.F.R. § 195.52(b) by failing to accurately report
the time of the Failure and other significant facts relevant to the extent of damages associated
with the pipeline rupture. Specifically, the Notice alleged that Enbridge provided NRC Report
#948903 at 13:33 on July 26, 2010, for the accident that occurred at 17:58 on July 25, 2010.47
The Notice further alleged Respondent’s NRC Report# 948903 incorrectly reported that the time
the Failure was discovered was 09:45 local time, that the material had not yet reached the
Kalamazoo River, and that the release had been secured.
PHMSA alleged that its witness interviews indicated CCO personnel on shift had already
discovered that the SCADA information indicated the rupture had likely occurred when the
pipeline was shut down the night before.48 The Notice alleged that soon after NRC Report
#948903 was filed, it became evident to Enbridge that the release was not secured, as oil was
moving down the Kalamazoo River. The impacts to people, property, and the environment were
immediately obvious when emergency response actions were initiated. PHMSA asserted that
Enbridge did not provide the NRC with any additional telephonic reports to correct and/or
augment the initial information that had been provided.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.52(b) by
failing to accurately report the time of the Failure and other significant facts relevant to the
extent of damages associated with the release.
Item 22: The Notice alleged that Respondent violated 49 C.F.R. § 195.54(a), which states:
§ 195.54 Accident reports.
(a) Each operator that experiences an accident that is required to be
reported under §195.50 shall as soon as practicable, but not later than 30
days after discovery of the accident, prepare and file an accident report on
DOT Form 7000-1, or a facsimile.
The Notice alleged that Respondent violated 49 C.F.R. § 195.54(a) by failing to prepare and file
an accident report on DOT Form 7000-1, or a facsimile, as soon as practicable, but not more than
30 days after discovery of an accident required to be reported under § 195.50. Specifically, the
Notice alleged that Enbridge failed to report currently available accident information on DOT
46 The Notice inadvertently quoted a revised version of § 195.54 that did not become effective until November 26,
2010, subsequent to the date of the Failure. The revised version made no substantive changes in the regulation and
does not affect the allegations in Item 21.
47 Violation Report, Exhibit O.
48 Violation Report, Exhibits E, N and O.



19
Form 7000-1 within 30 days of discovery of the Failure, which occurred on July 25, 2010.
The Notice alleged that Enbridge filed Report #20100181- 15259 on August 25, 2010, but it
contained inaccurate information.
49 The Report indicated that the local time and date of the
accident was 11:41 on July 26, 2010, when it had been clear within hours of discovery that the
failure date and time was approximately 17:58 on July 25, 2010. PHMSA further alleged that
the Report did not indicate the number of persons evacuated, even though daily EPA Pollution
Reports indicated the number of residences that had been evacuated, and Enbridge had paid for
alternative lodging for some evacuees.50 Enbridge reported that the estimated pressure at the
point and time of the accident was 0.00 psig, when the actual operating pressure at the point and
time of the Failure, as indicated by available SCADA information, was approximately 475
psig.51 Other fields within the Report concerning SCADA and CPM information were also
allegedly inaccurate, such that the report indicated that SCADA-based information had not
assisted with detection of the accident, that the CPM system was not fully functional at the time
of the accident, and that the CPM system did not assist with detection of the accident. The
Notice alleged that, in actuality, all of these systems were fully functional and provided proper
indications of the Failure.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.54(a) by
failing to prepare and file an accident report on DOT Form 7000-1, or a facsimile, as soon as
practicable, but not later than 30 days, following an accident required to be reported under
§ 195.50.
Item 23: The Notice alleged that Respondent violated 49 C.F.R. § 195.54(b), which states:
§ 195.54 Accident reports.
(a) Each operator that experiences an accident that is required to be
reported under §195.50 shall as soon as practicable, but not later than 30 days
after discovery of the accident, prepare and file an accident report on DOT
Form 7000-1, or a facsimile.
(b) Whenever an operator receives any changes in the information reported
or additions to the original report on DOT Form 7000-1, it shall file a
supplemental report within 30 days.
The Notice alleged that Respondent violated 49 C.F.R. § 195.54(b) by failing to file
supplemental accident reports within 30 days of receiving changes in the information originally
reported. Specifically, the Notice alleged that Enbridge did not submit supplemental reports
within 30 days of receiving changes or additions to the information originally reported on DOT
Form 7000-1 in Report #20100181-15259.52 Enbridge submitted the Original Form 7000-1
49 Violation Report, Exhibit P.
50 Id.
51 Violation Report, Exhibit E.
52 Violation Report, Exhibit P.



20
accident report on August 25, 2010, and supplemental reports on December 20, 2010, February
22, 2011 (two reports were submitted on this date), and March 6, 2012. The Notice alleged that
the supplemental reports filed by Enbridge contained inaccurate information.
PHMSA alleged that during its accident investigation, on December 5, 2011, a witness stated to
PHMSA representatives that Enbridge had determined that the total cost of damages associated
with the Failure was currently $720 million.53 The cost figure included in the February 22, 2011
report was $550 million. The Notice alleged that while it was unknown at what point the $720
million damage figure was determined, the reported value was not updated until March 6, 2012,
approximately three months after the interview.
The Notice further alleged that Enbridge reported all of the costs on the “Estimated other costs”
(8f) line item on DOT Form 7000-1, rather than in the appropriate cost categories provided.
Additional cost details were contained in a Supplemental Narrative, but still not allocated
according to the prescribed cost categories. Known details, such as the number of people
evacuated, the estimated release volume, the pressure at the point and time of the accident, and
SCADA, CPM, and other reporting elements were not updated until more than 18 months after
the Failure.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.54(b) by
failing to file a supplemental accident report within 30 days of receiving changes in the
information originally reported.
Item 24: The Notice alleged that Respondent violated 49 C.F.R. § 195.505(c), which states:
§ 195.505 Qualification program.
Each operator shall have and follow a written qualification program.
The program shall include provisions to:
(a) . . .
(c) Allow individuals that are not qualified pursuant to this subpart to
perform a covered task if directed and observed by an individual that is
qualified.
The Notice alleged that Respondent violated 49 C.F.R. § 195.505(c) by failing to have and
follow a written Operator Qualification (OQ) program that allowed individuals who were not
qualified to perform covered tasks only if directed and observed by individuals who were
qualified. Specifically, the Notice alleged that on the day of the Failure, Enbridge allowed a
previously-qualified controller, who had been off duty for an extended period of time, to operate
the Line 6B console, with a qualified controller assigned to oversee the operations.
PHMSA alleged that during the shift on July 25, 2010, from approximately 5:30 to 17:30, the
qualified controller, seated adjacent to the un-qualified controller, was performing other tasks
53 Violation Report, Exhibit Q.



21
and not directing and observing the line operations performed by the non-qualified employee, as
required by the company’s own written procedures.54 After initiating the Scheduled Shutdown
at 14:56, a number of control center alarms (leak triggers), including a five-minute MBS alarm,
multiple low-pressure alarms, and a Marshall pumping station “cascade” shutdown occurred,
indicating potential integrity issues with the pipeline.55 According to PHMSA, the non-qualified
controller did not respond to the alarms in accordance with Enbridge’s own written procedures,
and the qualified controller’s oversight of the operations was insufficient to ensure that the
required actions were taken.
Respondent did not contest the proposed penalty for this allegation of violation. Accordingly,
based upon a review of the record, I find that Respondent violated 49 C.F.R. § 195.505(c) by
failing to have and follow a written OQ program that allowed individuals who were not qualified
to perform covered tasks only if directed and observed by individuals who were qualified.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. In determining a penalty amount under 49 U.S.C. § 60122 and
49 C.F.R. § 190.225, I must consider the statutory assessment criteria, including the nature,
circumstances, and gravity of the violation; the degree of Respondent’s culpability; the history of
Respondent’s prior offenses; the Respondent’s ability to pay the penalty and any effect that the
penalty may have on its ability to continue doing business; and the good faith of Respondent in
attempting to comply with the pipeline safety regulations. The Notice proposed a total
administrative civil penalty of $3,699,200 for the violations cited above.
Item 1: The Notice proposed an administrative civil penalty of $97,800 for Respondent’s
violation of 49 C.F.R. § 195.452(h)(1)-(2), for failing to promptly obtain sufficient information
about anomalous conditions on Line 6B to make a determination that the conditions presented a
potential threat to the integrity of the pipeline and to take prompt action to address those
conditions that could reduce the pipeline’s integrity. Enbridge paid the proposed penalty, which
serves to close the case with prejudice to Respondent. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Respondent an administrative civil penalty of
$97,800 for violation of 49 C.F.R. § 195.452(h)(1)-(2).
Item 2: The Notice proposed an administrative civil penalty of $1,000,000 for Respondent’s
violation of 49 C.F.R. § 195.452(h)(4), for failing to properly schedule the evaluation and
remediation of certain anomalous conditions that were required to be remediated within 180 days
of their discovery. Enbridge paid the proposed penalty, which serves to close the case with
ASSESSMENT OF PENALTY
54 Violation Report, Exhibits E and H.
55 Id.



22
prejudice to Respondent. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent an administrative civil penalty of $1,000,000 for
violation of 49 C.F.R. § 195.452(h)(4).
Item 3: The Notice proposed an administrative civil penalty of $85,300 for Respondent’s
violation of 49 C.F.R. § 195.452(i)(1) and (2)(i)-(iv), for failing to perform a proper risk
analysis to identify the need for additional preventive and mitigative measures to protect HCAs.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $85,300 for violation of 49 C.F.R. § 195.452(i)(1)
and (2)(i)-(iv).
Item 4: The Notice proposed an administrative civil penalty of $1,000,000 for Respondent’s
violation of 49 C.F.R. § 195.452(j)(2), for failing to conduct periodic evaluations as frequently as
needed to assure pipeline integrity, based upon an analysis of risk factors specific to its pipeline.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $1,000,000 for violation of
49 C.F.R. § 195.452(j)(2).
Item 5: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.401(b), for failing to correct, within a reasonable time after
discovery, conditions that could adversely affect the safe operation of its pipeline. Specifically,
it alleged that Enbridge failed, within a reasonable time, to correct conditions that it had
discovered as a result of a series of SCADA/instrumentation alarms and events occurring within
seconds and minutes of the Failure. Enbridge paid the proposed penalty, which serves to close
the case with prejudice to Respondent. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Respondent an administrative civil penalty of $100,000 for
violation of 49 C.F.R. § 195.401(b).
Item 6: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (d)(1) and (3-4), for failing to follow a manual of written
procedures for conducting normal operations and maintenance activities and handling abnormal
operations and emergencies. Specifically, the Notice alleged that Enbridge failed to follow its
own written procedures for responding to, investigating, and correcting the cause of pressure
outside of normal operating limits that had been indicated by LPM Invalid Pressure Alarms
during the Scheduled Shutdown. Enbridge paid the proposed penalty, which serves to close the
case with prejudice to Respondent. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent an administrative civil penalty of $100,000 for violation
of 49 C.F.R. § 195.402(a) and (d)(1) and (3-4).
Item 7: The Notice proposed an administrative civil penalty of $41,200 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (d)(1) and (3-4), for failing to follow its manual of
written procedures for responding to, investigating, and correcting the cause of pressure events
outside of normal operating limits that had been indicated by Low Pressure Alarms during the
Scheduled Shutdown. Enbridge paid the proposed penalty, which serves to close the case with



23
prejudice to Respondent. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent an administrative civil penalty of $41,200 for violation
of 49 C.F.R. § 195.402(a) and (d)(1) and (3-4).
Item 8: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (d)(1) and (3-4), for failing to follow its manual of
written procedures for responding to, investigating, and correcting the cause of an unintended
shutdown that occurred during the Scheduled Shutdown. The Notice further alleged that
Respondent also failed to notify responsible personnel in accordance with the procedure.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $100,000 for violation of 49 C.F.R. § 195. 402(a)
and (d)(1) and (3-4).
Item 9: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (e)(4) and (7), for failing to follow its manual of written
procedures for taking necessary action to minimize the volume of hazardous liquid released in a
failure and to notify fire, police and other public officials during an emergency. Enbridge paid
the proposed penalty, which served to close the case with prejudice to Respondent. Accordingly,
having reviewed the record and considered the assessment criteria, I assess Respondent an
administrative civil penalty of $100,000 for violation of 49 C.F.R. § 195.402(a) and (e)(4)
and (7).
Item 10: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (e)(4) and (7), for failing to follow its manual of written
procedures for conducting normal operations and maintenance activities and handling abnormal
operations and emergencies. Specifically, the Notice alleged that Enbridge failed to follow
either its Suspected Leak or Confirmed Leak procedure in response to the Leak Triggers that
occurred shortly after the Scheduled Shutdown. As a result, Enbridge failed to execute its
Emergency Notification procedure, under which it would have notified Regional/Field personnel,
police, and other public officials, and the CCO Admin On-Call or Designate.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $100,000 for violation of 49 C.F.R. § 195.402(a)
and (e)(4) and (7).
Item 12: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.401(b), for operating its pipeline system without correcting a
condition that presented an immediate hazard to persons or property. Specifically, the Notice
alleged that Enbridge initiated the First Restart and then continued operating the line despite
unsuccessful attempts to build pressure at the Marshall pumping station and multiple alarms
occurring within minutes after the restart. Enbridge paid the proposed penalty, which serves to
close the case with prejudice to Respondent. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent an administrative civil penalty of
$100,000 for violation of 49 C.F.R. § 195.401(b).



24
Item 13: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (e)(4), for failing to follow its own written procedures
for conducting normal operations and maintenance activities and handling abnormal operations
and emergencies. Specifically, the Notice alleged that shortly after initiating the First Restart,
Enbridge failed to follow its own MBS Leak Alarm procedure, which required that if an MBS
alarm occurred, then the controller was to notify the Shift Lead, and record the abnormal
operating condition in the company’s FACMAN database.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $100,000 for violation of 49 C.F.R. § 195.402 (a)
and (e)(4).
Item 14: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (d)(1) and (3)-(4), for failing to follow its manual of
written procedures for conducting normal operations and maintenance activities and handling
abnormal operations and emergencies. Specifically, the Notice alleged that Enbridge did not
follow its Suspected Column Separation procedure for responding to, investigating, and
correcting the cause of pressure variations outside of normal operating limits and for notifying
responsible personnel. Enbridge paid the proposed penalty, which serves to close the case with
prejudice to Respondent. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent an administrative civil penalty of $100,000 for violation
of 49 C.F.R. § 195.402(a) and (d)(1) and (3)-(4).
Item 15: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a) and (e)(4)and (7), for failing to follow either its Emergency
Notification or Suspected Column Separation procedure to minimize the volume of hazardous
liquid released in the event of a failure or to notify fire, police and other appropriate public
officials during an emergency. Enbridge paid the proposed penalty, which serves to close the
case with prejudice to Respondent. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent an administrative civil penalty of $100,000 for violation
of 49 C.F.R. § 195.402(a) and (e)(4) and (7).
Item 16: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a), for failing to follow its own manual of written procedures
for conducting normal operations and maintenance activities and for handling abnormal
operations and emergencies. Specifically, it alleged that, during the First Restart, Enbridge
personnel used a draft procedure that had never been officially approved by the company for
starting up a pipeline with column separation. Enbridge paid the proposed penalty, which serves
to close the case with prejudice to Respondent. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent an administrative civil penalty of
$100,000 for violation of 49 C.F.R. § 195.402(a).
Item 17: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.401(b), for continuing to operate its pipeline after discovering an



25
unsafe condition that presented an immediate hazard to persons and property. Specifically, the
Notice alleged that Enbridge initiated and continued the Second Restart of Line 6B despite the
occurrence of additional alarms and problems in building pressure at the Marshall pumping
station. Enbridge paid the proposed penalty, which serves to close the case with prejudice to
Respondent. Accordingly, having reviewed the record and considered the assessment criteria, I
assess Respondent an administrative civil penalty of $100,000 for violation of
49 C.F.R. § 195.401(b).
Item 18: The Notice proposed penalty of $100,000 for Respondent’s violation of
49 C.F.R. § 195.402(a), (d)(1) and (3)-(4), for failing to follow either its Emergency Notification
or Suspected Column Separation procedure for responding to, investigating, and correcting the
cause of variations from normal operation of pressure to minimize the volume of hazardous
liquid released in the event of a failure or notifying fire, police, and other appropriate public
officials during an emergency. Enbridge paid the proposed penalty, which serves to close the
case with prejudice to Respondent. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent an administrative civil penalty of $100,000 for violation
of 49 C.F.R. § 195.402(a), (d)(1) and (3)-(4).
Item 19: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.402(a), (e)(4) and (7), for failing to execute its Emergency
Notification procedure during the Second Restart when the column could not be restored within
10 minutes. Under such procedure, Enbridge would have notified fire, police, and other
appropriate public officials of a hazardous liquid release emergency. Enbridge paid the proposed
penalty, which serves to close the case with prejudice to Respondent. Accordingly, having
reviewed the record and considered the assessment criteria, I assess Respondent an
administrative civil penalty of $100,000 for violation of 49 C.F.R. § 195.402(a), (e)(4) and (7).
Item 21: The Notice proposed an administrative civil penalty of $32,500 for Respondent’s
violation of 49 C.F.R. § 195.52(b), for failing to accurately report the time of the Failure and
other significant facts relevant to the extent of damages associated with the pipeline rupture. The
Notice further alleged that Enbridge’s NRC Report# 948903 incorrectly reported the time the
Failure was discovered as being 09:45 local time, that the material had not yet reached the
Kalamazoo River, and that the release had been secured. Enbridge paid the proposed penalty,
which serves to close the case with prejudice to Respondent. Accordingly, having reviewed the
record and considered the assessment criteria, I assess Respondent an administrative civil penalty
of $32,500 for violation of 49 C.F.R. § 195.52(b).
Item 22: The Notice proposed an administrative civil penalty of $23,700 for Respondent’s
violation of 49 C.F.R. § 195.54(a), for failing to prepare and file an accident report on DOT
Form 7000-1, or a facsimile, as soon as practicable, but not later than 30 days after discovery of
an accident required to be reported under § 195.50. Enbridge paid the proposed penalty, which
serves to close the case with prejudice to Respondent. Accordingly, having reviewed the record
and considered the assessment criteria, I assess Respondent an administrative civil penalty of
$23,700 for violation of 49 C.F.R. § 195.54(a).
Item 23: The Notice proposed an administrative civil penalty of $18,700 for Respondent’s



26
violation of 49 C.F.R. § 195.54(b), for failing to file supplemental accident reports within 30
days of receiving changes in the information originally reported. Specifically, it alleged that
Enbridge did not submit supplemental reports within 30 days of receiving changes or additions to
the information originally reported on DOT Form 7000-1, dated August 25, 2010, and that the
supplemental reports it did file contained inaccurate information.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $18,700 for violation of 49 C.F.R. § 195.54(b).
Item 24: The Notice proposed an administrative civil penalty of $100,000 for Respondent’s
violation of 49 C.F.R. § 195.505(c), for failing to have and follow a written OQ Program that
allowed individuals who were not qualified to perform covered tasks only if directed and
observed by individuals who were qualified. Specifically, it alleged that on the day of the
Failure, Enbridge allowed a previously-qualified controller, who had been off duty for an
extended period of time, to operate the Line 6B console without proper direction and observation
by a qualified controller.
Enbridge paid the proposed penalty, which serves to close the case with prejudice to Respondent.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent an administrative civil penalty of $100,000 for violation of 49 C.F.R. § 195.505(c).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items as discussed above, I assess Respondent a total administrative civil penalty of $3,699,200,
which amount has already been paid by Respondent.
WARNING ITEMS
With respect to Item 11 and 20, the Notice alleged probable violations of Part 195 but did not
propose an administrative civil penalty or compliance order for these items. Therefore, these are
considered to be warning items. The warnings were for:
49 C.F.R. § 195.440(c) (Item 11) ─ Respondent’s alleged failure to follow and
implement a public awareness program (PAP) meeting the general program
recommendations set forth in [American Petroleum Institute] Recommended
Practice 1162, and to evaluate its effectiveness in accordance with company
procedures. The Notice alleged a number of instances where actions taken by
members of the PAP target audience were not in accordance with the program
message (e.g. not associating the odor with that of a possible crude oil release, not
contacting Enbridge’s Emergency Number in response to the odor complaints,
and entry into the release area by untrained individuals).
49 C.F.R. § 195.195.52(a)(1-5)(Item 20) ─ Respondent’s alleged failure to
accurately report required accident information at the earliest practicable moment
following discovery of a reportable release.



27
Accordingly, having considered such information, I find, pursuant to 49 C.F.R. § 190.205, that
probable violations of 49 C.F.R. §§ 195.440(c) (Item 11) and 195.195.52(a)(1-5) (Item 20) have
occurred. If OPS finds a violation of these provisions in a subsequent inspection, Respondent
may be subject to future enforcement action.
This Order does not resolve any existing or potential civil or criminal liability that Enbridge may
have for any other violations of the federal Pipeline Safety Laws, or any regulations or orders
issued thereunder, not specifically enumerated herein. Further, this Order does not resolve any
existing or potential civil or criminal liability that Enbridge may have for violations of any other
federal laws arising from or otherwise related to the events or conduct giving rise to this Order or
to the consequences or damages resulting from the Failure.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320125013>
- Source ID: `phmsa-enforcement`
- SHA-256: `b126bdc81a8cf7a29680dca136f5012a97c84250832f6abd6199aef384080706`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-25T02:48:43.332Z
- Document slug: `phmsa-enforcement-320125013`

### Source metadata

```json
{
  "cpf": "320125013",
  "operator": "ENBRIDGE ENERGY, LIMITED PARTNERSHIP",
  "region": "Central",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
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    "195.402(a)",
    "195.440(c)",
    "195.452(h)(2)",
    "195.452(h)(4)",
    "195.452(i)(1)",
    "195.452(i)(2)(i)",
    "195.452(i)(2)(ii)",
    "195.452(i)(2)(iii)",
    "195.452(i)(2)(iv)",
    "195.452(j)(2)",
    "195.505(c)",
    "195.52(a)",
    "195.52(b)",
    "195.54(a)",
    "195.54(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
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  "extractedAgencyDocumentCount": 1,
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  "jurisdiction": "US",
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}
```