{"operation":"document","citation":"CPF 120111005W","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":"2011-04-21","effective_on":null,"summary":"CLOSED warning letter citing 192.927(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120111005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120111005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120111005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120111005W","body":"Warning Letter involving TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulation as 192.927(c). The case was opened on 2011-04-21 and is reported as closed as of 2011-04-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120111005W_Warning Letter_04212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111005W/120111005W_Warning%20Letter_04212011.pdf\n\n120111005W_Warning Letter_04212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120111005W/120111005W_Warning%20Letter_04212011_text.pdf\n\n120111005W_Warning Letter_04212011_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nWARNING LETTER\nOVERNIGHT EXPRESS MAIL\nApril 21, 2011\nMr. Andy Drake\nVice President of Transmission Services\nSpectra Energy Transmission, LLC\n5400 Westheimer Court\nHouston, TX 77056\nCPF 1-2011-1005W\nDear Mr. Drake:\nBetween August 31 and October 21 of 2010, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Spectra Energy\nTransmission, LLC’s (Spectra) procedures for the Gas Integrity Management Program in Houston, TX.\nAs a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are:\n1. Direct Assessment Plan\n§192.911 What are the elements of an integrity management program?\n(d) A direct assessment plan, if applicable, meeting the requirements of § 192.923, and depending\non the threat assessed, of § § 192.925, 192.927, or 192.929.\n§192.927 What are the requirements for using Internal Corrosion Direct Assessment (ICDA)?\n(c) The ICDA plan. An operator must develop and follow an ICDA plan that provides for\npreassessment, identification of ICDA regions and excavation locations, detailed examination of\npipe at excavation locations, and post-assessment evaluation and monitoring. (3) Identification of\nlocations for excavation and direct examination. An operator's plan must identify the locations\nwhere internal corrosion is most likely in each ICDA region. In the location identification process,\nan operator must identify a minimum of two locations for excavation within each ICDA Region\n\n\n\n120111005W\nwithin a covered segment and must perform a direct examination for internal corrosion at each\nlocation, using ultrasonic thickness measurements, radiography, or other generally accepted\nmeasurement technique. One location must be the low point (e.g., sags, drips, valves, manifolds,\ndead-legs, traps) within the covered segment nearest to the beginning of the ICDA Region. The\nsecond location must be further downstream, within a covered segment, near the end of the ICDA\nRegion. If corrosion exists at either location, the operator must-\nSpectra’s ICDA plan did not identify a minimum of two locations for excavation within each ICDA Region\nwithin a covered segment. The pipeline safety regulations define a ‘covered segment’ as a “segment of gas\ntransmission pipeline located in a high consequence area.” 1\nAlthough Spectra’s ICDA plan provided identification of the locations where internal corrosion is most likely\nin each ICDA region, pursuant to §192.927, the location identification process must identify a minimum of\ntwo locations for excavation within each ICDA Region within a covered segment. One location must be the\nlow point (e.g., sags, drips, valves, manifolds, dead-legs, traps) within the covered segment nearest to the\nbeginning of the ICDA Region. The second location must be further downstream, within a covered segment,\nnear the end of the ICDA Region. Based on a review of the configuration of Algonquin Line F-1 shown on\nthe Dig Map and F-System & Algonquin Line F-1 ICDA Report, in October 2007 Spectra excavated two\nlocations and had performed a direct examination for internal corrosion at each location. However, one\nexcavation was within a High Consequence Area (HCA) and another was outside a HCA.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each\nviolation for each day the violation persists up to a maximum of $1,000,000 for any related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe item identified in this letter. Failure to do so will result in Spectra being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to Byron Coy, PE,\nDirector, PHMSA Eastern Region, 820 Bear Tavern Rd, Suite 103, W. Trenton, NJ, 08628 and please refer to\nCPF 1-2011-1005W. Be advised that all material you submit in response to this enforcement action is subject\nto being made publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n1 49 C.F.R. §192.903\n120111005W_Warning Letter_04212011 Page 2 of 3","truncated":false,"body_characters":5735}