# TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Warning Letter

- **operation:** document
- **citation:** CPF 120091004W
- **title:** TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-05-14
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.467(c), 192.727(c), 192.727(g).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120091004w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120091004W
**body:**

Warning Letter involving TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulations as 192.467(c),  192.727(c),  192.727(g). The case was opened on 2009-05-14 and is reported as closed as of 2009-05-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120091004W_operator response to notice letter_07212009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091004W/120091004W_operator%20response%20to%20notice%20letter_07212009.pdf

120091004W_warning letter_05142009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091004W/120091004W_warning%20letter_05142009.pdf

120091004W_warning letter_05142009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120091004W/120091004W_warning%20letter_05142009_text.pdf

120091004W_warning letter_05142009_text.pdf

U.S. Department 820 Bear Tavern RD
of Transportation Suite 306
West Trenton, NJ 08628
Pipeline and
Hazardous Materials
Safety Administration
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
May 14, 2009
Mr. Greg Bilinski
Vice President, Operations
Spectra Energy Transmission, LLC
5400 Westheimer
Houston, Texas 77056
CPF 1-2009-1004W
Dear Mr. Bilinski:
During May 2008, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) and the New York Public Service Commission, pursuant to Chapter
601 of 49 United States Code inspected your Texas Eastern Transmission, LP (TETCO) facilities
in Hanover, New Jersey and Staten Island, New York.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:



1. §192.467 External corrosion control: Electrical isolation.
(c) Except for unprotected copper inserted in a ferrous pipe, each pipeline must be
electrically isolated from metallic casings that are a part of the underground system.
However, if isolation is not achieved because it is impractical, other measures must
be taken to minimize corrosion of the pipeline inside the casing.
TETCO has a shorted casing in Linden, NJ. (MP 1469.7 to 1473.8) in a Class 3 area. TETCO’s
written procedures require that the shorted casing be leak surveyed quarterly, not to exceed 4
months. TETCO twice exceeded the 4-month interval: July 25 to December 1, 2006 and
December 1, 2006 to April 3, 2007.
The probable violation is based on TETCO’s Pipeline Patrol and Leak Survey Reports for the
specified time periods.
2. §192.727 Abandonment or deactivation of facilities.
(c) Except for service lines, each inactive pipeline that is not being maintained
under this part must be disconnected from all sources and supplies of gas;
purged of gas; in the case of offshore pipelines, filled with water or inert
materials; and sealed at the ends. However, the pipeline need not be purged
when the volume of gas is so small that there is no potential hazard.
At the Hanover, New Jersey compressor station, there are two Pratt and Whitney compressor
units which TETCO has not operated since 2002. It is our understanding that TETCO is
planning to remove these compressors from service and has not performed valve maintenance on
the suction and discharge valves associated with these compressor units since 2002 due to the
pending abandonment of these facilities. Since these pipeline facilities have been inactive and
not maintained since 2002, TETCO should have disconnected the compressor units from all
sources and supplies of gas, purged the inactive facilities, and sealed at the ends.
This probable violation is based upon the valve/regulator testing sheets for the years 2006 and
2007.
3. §192.727 Abandonment or deactivation of facilities.
(g) For each abandoned offshore pipeline facility or each abandoned onshore
pipeline facility that crosses over, under or through a commercially navigable
waterway, the last operator of that facility must file a report upon abandonment of
that facility…
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The information in the report must contain all reasonably available information
related to the facility, including information in the possession of a third party. The
report must contain the location, size, date, method of abandonment, and a
certification that the facility has been abandoned in accordance with all applicable
laws.
Between July 15 and July 19, 2002, TETCO abandoned a pipeline underlying the navigable
waterway, Arthur Kill, in the states of New Jersey and New York. The pipeline was Line 1R, a
transmission line 0.46 miles in length. This abandoned pipeline was not reported to PHMSA as
required by the regulation.
The evidence for the probable violation is the operator’s Pipeline Deactivation Report.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the items identified in this letter.
Failure to do so will result in TETCO being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 1-2009-1004W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Byron E. Coy, P.E.
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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