# TEXAS EASTERN TRANSMISSION, LP — Notice of Probable Violation **Citation:** CPF 32025027NOPV **Type / status:** enforcement / historical **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2025-07-01 CLOSED notice of probable violation citing 192.605(a). ## Document text Notice of Probable Violation involving TEXAS EASTERN TRANSMISSION, LP. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2025-07-01 and is reported as closed as of 2026-01-26. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 32025027NOPV_Closure Letter_01262026_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Closure%20Letter_01262026_(24-299195).pdf 32025027NOPV_Closure Letter_01262026_(24-299195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Closure%20Letter_01262026_(24-299195)_text.pdf 32025027NOPV_Final Order_10202025_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Final%20Order_10202025_(24-299195).pdf 32025027NOPV_Final Order_10202025_(24-299195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Final%20Order_10202025_(24-299195)_text.pdf 32025027NOPV_Operator Response to Notice_07312025_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Operator%20Response%20to%20Notice_07312025_(24-299195).pdf 32025027NOPV_PCO_07012025_(24-299195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_PCO_07012025_(24-299195).pdf 32025027NOPV_PCO_07012025_(24-299195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_PCO_07012025_(24-299195)_text.pdf 32025027NOPV_Final Order_10202025_(24-299195)_text.pdf October 20, 2025 VIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com Ms. Cynthia Hansen President & Chief Operating Officer Texas Eastern Transmission, LP 915 North Eldridge Parkway Houston, Texas 77079 Re: CPF No. 3-2025-027-NOPV Dear Ms. Hansen: Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of violation and specifies actions that need to be taken to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by e- mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5. Thank you for your cooperation in this matter. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety Enclosures (Final Order and NOPV) cc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA Mr. Peter Seydewitz, Director, Operational Excellence, Peter.Seydewitz@enbridge.com Ms. Salima Abdulla, Manager, Operational Compliance, Salima.Abdulla@enbridge.com Mr. Michael McGrath, Strategic Advisor, Operational Compliance, Michael.McGrath@enbridge.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, ) a subsidiary of Enbridge Inc., ) CPF No. 3-2025-027-NOPV ) Respondent. ) ____________________________________) FINAL ORDER On July 1, 2025, pursuant to 49 CFR § 190.207, the Acting Director, Central Region, Office of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Texas Eastern Transmission, LP (Respondent). The Notice proposed finding that Respondent had violated the pipeline safety regulations in 49 CFR Part 192. The Notice also proposed certain measures to correct the violation. Respondent did not contest the allegation of violation or corrective measures. Pursuant to 49 CFR § 190.213, I find Respondent violated the pipeline safety regulation listed below, as more fully described in the enclosed Notice, which is incorporated by reference: 49 CFR § 192.605(a) (Item 1) ─ Respondent failed to follow its manual of written procedures for conducting operations and maintenance activities and for emergency response. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. Compliance Actions Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the actions proposed in the enclosed Notice to correct the violation. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Upon completion of the ordered actions, Respondent may request that the Director close the case. Respondent previously submitted evidence to show appropriate actions have been started to correct the violations. This evidence is currently under review by the Director. Failure to comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this order are effective upon service in accordance with 49 CFR § 190.5. ___________________________________ __________________________ Linda Daugherty Date Issued Acting Associate Administrator for Pipeline Safety NOTICE OF PROBABLE VIOLATION and PROPOSED COMPLIANCE ORDER VIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com; peter.seydewitz@enbridge.com; salima.abdulla@enbridge.com; michael.mcgrath@enbridge.com July 1, 2025 Ms. Cynthia Hansen President / Chief Operating Officer Texas Eastern Transmission, LP 915 North Eldridge Parkway Houston, TX 77079 CPF 3-2025-027-NOPV Dear Ms. Hansen: For the weeks of May 13, June 3, and June 24, 2024, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Texas Eastern Transmission, LP’s procedures and records for the new gas integrity rule1 in Houston, Texas. As a result of the inspection, it is alleged that Texas Eastern Transmission, LP’s (TET) has committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. 1 Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments, 84 Fed. Reg. 52,180 (October 1, 2019). Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. TET did not follow its manual of written procedures in accordance with § 192.605(a). Specifically, TET did not follow its “Pipeline Integrity – Integrity Management Plan” (IMP), section 7.3.1 which required the identification of Moderate Consequence Areas (MCA) for the purpose of conducting baseline assessments in accordance with § 192.710(b). Section 7.3.1 referenced procedure OC-52.201 – “HCA/MCA Identification Process” which states in section 3 that “HCAs and MCAs shall be identified, evaluated, and published once per calendar year, not to exceed a period of 15 months for all US Enbridge (as built/in service) gas transmission pipelines.” During PHMSA’s inspection, PHMSA inspectors reviewed TET’s pipeline system for MCAs and determined that six MCAs were missed at the time of the inspection. A historical review of publicly available satellite imagery found that these locations existed prior to the effective date of the regulation, which was July 1, 2020. The missed MCAs discovered during PHMSA’s inspection were as follows: Location • 40.439063°, -78.978202° - ARMA-LILL/12 was not designated as an MCA even though it met the 5 buildings intended for human occupancy density count within a potential impact radius. The adjacent lines ARMA-LILL/19 and ARMA-LILL/27 were designated as MCAs within this area. • 40.338835°, -75.078314° - EAGL-LAMT/1 line segment had an MCA identified in this area due to the house density. However, the MCA should have been longer than what was designated in the map. This MCA was right next to a designated high consequence area (HCA) for this line. The adjacent line EAGL-LAMT/2 was designated an HCA throughout this entire area. • 40.116594°, -75.272552° - EAGL-LAMT/1-B-2 had an MCA established for the PA Turnpike (Hwy 276). However, the MCA stopped short of a location where the pipe segments met the house density count requirement. Therefore, the MCA should have been expanded to include this area. • 40.134355°, -75.248624° - EAGL-LAMT/1-B-1 did not have an MCA designated at this location, despite it meeting the criteria due to the housing density. • 40.111930°, -75.270010° - EAGL-LAMT/1-B-1 and EAGL-LAMT/1-B-2 were not identified MCAs at this location, despite meeting the criteria due to housing density. This area was adjacent to existing MCAs on both lines. • 40.081469°, -75.134934° - EAGL-LAMT/1-F did not have an MCA designated in this area, despite meeting the criteria due to housing density. Thus, TET did not follow its IMP, Section 7.3.1, for the identification of MCAs in six locations, in violation of § 192.605(a). Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related series of violations. For violation occurring on or after December 28, 2023 and before December 30, 2024 the maximum penalty may not exceed $266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023 the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023 the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022 the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021 the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019, and before January 11, 2021 the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case and have decided not to propose a civil penalty assessment at this time. Proposed Compliance Order With respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Texas Eastern Transmission, LP. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. All material you submit in response to this enforcement action may be 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). Following your receipt of this Notice, you have 30 days to respond as described in the enclosed Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. The Region Director may extend the period for responding upon a written request timely submitted demonstrating good cause for an extension. In your correspondence on this matter, please refer to CPF 3-2025-027-NOPV and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, David Barrett Acting Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Mr. Peter Seydewitz, Director - Operational Excellence Ms. Salima Abdulla, Manager – Operational Compliance Mr. Michael McGrath, Strategic Advisor, Operational Compliance Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Texas Eastern Transmission, LP a Compliance Order incorporating the following remedial requirements to ensure the compliance of Texas Eastern Transmission, LP, with the pipeline safety regulations: A. In regard to Item 1 of the Notice pertaining to missed Moderate Consequence Areas (MCAs), Texas Eastern Transmission, LP, must review all processes that are associated with the identification of MCAs to determine how existing structure MCAs were not previously identified and provide documentation of the review and approval to the Director, Central Region within 90 days of issuance of the Final Order. Once this review is complete, Texas Eastern Transmission, LP, must ensure all MCAs and other pipe segments subject to § 192.710 are identified and submit the final results to the Director, Central Region for review and approval within 180 days of issuance of the Final Order. B. It is requested (not mandated) that Texas Eastern Transmission maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 32025027NOPV_Closure Letter_01262026_(24-299195)_text.pdf U.S. Department of Transportation Pipeline and Hazardous Materials Safety 901 Locust Street, Suite 480 Kansas City, MO 64106 VIA ELECTRONIC MAIL TO: cynthia.hansen@enbridge.com January 26, 2026 Ms. Cynthia Hansen President / Chief Operating Officer Texas Eastern Transmission, LP 915 North Eldridge Parkway Houston, TX 77079 RE: CPF 3-2025-027-NOPV Dear Ms. Hansen: On October 20, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Texas Eastern Transmission, LP (“TET”) a Final Order, pursuant to 49 CFR § 190.213. This Order included a Compliance Order. Based on our review of the documentation provided, it has been determined that TET has complied with the terms of the 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, David Barrett Acting Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Mr. Peter Seydewitz, Director - Operational Excellence, peter.seydewitz@enbridge.com; Ms. Salima Abdulla, Manager – Operational Compliance, salima.abdulla@enbridge.com Mr. Michael McGrath, Strategic Advisor, Compliance, michael.mcgrath@enbridge.com ## Provenance - Official: Yes - Source: - Source ID: `phmsa-enforcement` - SHA-256: `cea8eac7ee84db4b7ba430045e6bdf4c6b17e9221884685d53f6949b5b94bfae` - Retrieved: 2026-08-20T04:44:44.458Z - Exported: 2026-08-23T11:17:25.785Z - Document slug: `phmsa-enforcement-32025027nopv` ### Source metadata ```json { "cpf": "32025027NOPV", "operator": "TEXAS EASTERN TRANSMISSION, LP", "region": "Central", "pipelineType": "INTERSTATE GAS TRANSMISSION", "caseStatus": "CLOSED", "citedSections": [ "192.605(a)" ], "dataAsOf": "08/04/2026 12PM", "caseDataAsOf": "2026-08-04", "attachmentCount": 7, "attachments": [ { "name": "32025027NOPV_Closure Letter_01262026_(24-299195).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Closure%20Letter_01262026_(24-299195).pdf", "bytes": 147387, "category": "agency_document" }, { "name": "32025027NOPV_Closure Letter_01262026_(24-299195)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Closure%20Letter_01262026_(24-299195)_text.pdf", "bytes": 154695, "category": "agency_document" }, { "name": "32025027NOPV_Final Order_10202025_(24-299195).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Final%20Order_10202025_(24-299195).pdf", "bytes": 558308, "category": "agency_document" }, { "name": "32025027NOPV_Final Order_10202025_(24-299195)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Final%20Order_10202025_(24-299195)_text.pdf", "bytes": 216673, "category": "agency_document" }, { "name": "32025027NOPV_Operator Response to Notice_07312025_(24-299195).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_Operator%20Response%20to%20Notice_07312025_(24-299195).pdf", "bytes": 141272, "category": "party_submission" }, { "name": "32025027NOPV_PCO_07012025_(24-299195).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_PCO_07012025_(24-299195).pdf", "bytes": 312812, "category": "case_document" }, { "name": "32025027NOPV_PCO_07012025_(24-299195)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32025027NOPV/32025027NOPV_PCO_07012025_(24-299195)_text.pdf", "bytes": 174415, "category": "case_document" } ], "extractedAgencyDocumentCount": 2, "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" } ```