{"operation":"document","citation":"CPF 120151017W","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":"2015-08-04","effective_on":null,"summary":"CLOSED warning letter citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120151017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120151017W","body":"Warning Letter involving TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulation as 192.303. The case was opened on 2015-08-04 and is reported as closed as of 2015-08-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120151017W_Warning Letter_08042015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151017W/120151017W_Warning%20Letter_08042015.pdf\n\n120151017W_Warning Letter_08042015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120151017W/120151017W_Warning%20Letter_08042015_text.pdf\n\n120151017W_Warning Letter_08042015_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nAugust 4, 2015\nJ. Andrew Drake\nVice President, Operations & EHS\nTexas Eastern Transmission LP (Spectra Energy Corp)\n5400 Westheimer Court\nHouston, TX 77056\nCPF 1-2015-1017W\nDear Mr. Drake:\nFrom June 22 to 25, 2015, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, pursuant to Chapter 601 of 49 United States Code inspected\nconstruction activities associated with Texas Eastern Transmission LP’s (a subsidiary of Spectra Energy\nCorp) (Spectra) DOT Replacement Armagh project in Munster, Pennsylvania.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are:\n1. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with this part.\nSpectra failed to follow its written construction specifications during construction of its transmission line.\nSpecifically, Spectra did not document the environmental conditions during coating application on an\ninspection frequency of nominally one weld per hour minimum, as required by its written construction\nspecifications CS-PC1.6, Field Application of Liquid Epoxy Coating.\nSpectra’s written construction specification CS-PC1.6, Field Application of Liquid Epoxy Coating,\nRevision Date 2/11/2014, Section 8, 8A1 & 8A1.1, states that “Company coating inspector shall document\n(See Form TS-035) the following on an inspection frequency of nominally one weld per hour minimum:\nEnvironmental conditions (temperature, RH, dew point).\"\n\n\n\nCPF 1-2015-1017W\nDuring the field inspection conducted the week of June 22, 2015, the PHMSA inspector reviewed Daily\nCoating Application Inspection Reports (Below Ground), Form TS-035.3, for the Line 12 and Line 19\nDOT replacement project. The report dated May 29, 2015 indicated 23 welds on Line 12 were coated\nwith SP-2888-RG liquid epoxy coating on this date from 0800 EST to approximately 1330 EST. Of these\n23 welds, 12 consecutive welds coated from 800 EST to 1100 EST indicated identical readings for\ntemperature, relative humidity, and dew point. All 23 welds had identical relative humidity values of 61%\nannotated in this record. Two unique dew points were annotated in the record of 51°F and 45°F. Three\nunique temperatures were annotated in the record of 64.9°F, 71°F and 75°F, with 64.9°F recorded for 15\ntotal welds spanning 0800 EST to 1145 EST.\nThe data entered on this record indicates that new hourly measurements were not being captured. A\nsubsequent review of the field notes from the coating inspector’s notebook, provided after the inspection,\ndocuments only two sets of measurements taken at 0800 EST (64.9°F Temp, 51°F dew point, 61% RH)\nand at 1100 EST (65°F Temp, 52°F dew point, no RH noted). No other values were present in the field\nnotes for temperature, dew point or relative humidity.\n2. §192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with this part.\nSpectra failed to follow its written construction specifications during construction of its transmission line.\nSpecifically, Spectra performed coating application when the relative humidity exceeded 85%, as\nprohibited by its written construction specifications CS-ABC.0, Painting and Coating - Section I -\nGeneral Requirements.\nSpectra’s written construction specification CS-ABC.0, Painting and Coating - Section I - General\nRequirements, Orig. Issue Date 1/23/2014, Section 11, 11D6, states in part \"Except in Company-\nidentified special application situations, the surface temperature shall be 5°F (3°C) minimum above the\ndew point, and the humidity shall be 85% maximum.”\nDuring this field inspection conducted the week of June 22, 2015, the PHMSA inspector reviewed Daily\nCoating Application Inspection Reports (Below Ground), Form TS-035.3, for the Line 12 and Line 19\nDOT replacement project. The report for June 3, 2015, indicated that tie in weld RTB-TI-074 on Line 12\nwas coated when the relative humidity was 87% with a temperature of 56°F and a dew point of 52°F.\nThis tie-in weld is not considered a special application situation under Section 13D of Spectra’s\nconstruction specification CS-ABC.0, Painting and Coating - Section I - General Requirements, and thus\nis subject to the 85% maximum relative humidity requirement.\nThe inspector noted high fluctuation in the field regarding the equipment used to measure these values,\nthe Fluke 971, with a +/-2.5 % relative humidity error according to Fluke’s product specifications. Field\nnotes from the coating inspector were reviewed, which show a value recorded in their notebook of 83%\nfor relative humidity at the time of this weld. Spectra attributed the 87% value to a typographical error.\nHowever, historical local weather data from a nearby KJST Johnstown-Cambria Co Airport (acquired\nonline from wunderground.com) indicates humidity levels on June 3, 2015 ranged from 86% to 93%,\nwith 2:54 PM data (exact time noted on the record) indicating a 55.9°F temperature, a 52°F dew point,\nand an 87% relative humidity, matching what was recorded on the reviewed record in question.\nAdditionally, established methods for calculating relative humidity from temperature and dew point using\nthe Clausius-Clapeyron equation with August-Roche-Magnus approximation yield a relative humidity %\nof 86.41% given the values recorded on the record and 86.72% for the values found on the historical\nweather data.\n120151017W _WL_08042015 Page 2 of 3\n\n\n\nCPF 1-2015-1017W\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item(s) identified in this letter. Failure to do so will result in Texas Eastern\nTransmission LP being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF\n1-2015-1017W. Please send all correspondence in this matter to Byron Coy, PE, Director, PHMSA\nEastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628. Be advised that all material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120151017W _WL_08042015 Page 3 of 3","truncated":false,"body_characters":8386}