{"operation":"document","citation":"CPF 120171016M","title":"TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-10-30","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171016m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171016m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171016m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171016M","body":"Notice of Amendment 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 2017-10-30 and is reported as closed as of 2018-06-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171016M_Closure Letter_06072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171016M/120171016M_Closure%20Letter_06072018.pdf\n\n120171016M_Closure Letter_06072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171016M/120171016M_Closure%20Letter_06072018_text.pdf\n\n120171016M_Notice Of Amendment_10302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171016M/120171016M_Notice%20Of%20Amendment_10302017.pdf\n\n120171016M_Notice Of Amendment_10302017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171016M/120171016M_Notice%20Of%20Amendment_10302017_text.pdf\n\n120171016M_Operator Response To Notice and Request For Hearing_11282017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171016M/120171016M_Operator%20Response%20To%20Notice%20and%20Request%20For%20Hearing_11282017.pdf\n\n120171016M_Notice Of Amendment_10302017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nOctober 30, 2017\nMichelle Harradence\nVP Gas Transmission & Midstream Operations\nTexas Eastern Transmission, LP (Enbridge Inc.)\n5400 Westheimer Court\nHouston, TX 77251-1642\nCPF 1-2017-1016M\nDear Ms. Harradence:\nOn August 1-2, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nTexas Eastern Transmission, LP a subsidiary of Enbridge Inc. (Enbridge); Lebanon Extension in\nPennsylvania.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nEnbridge’s plans or procedures, as described below:\n1. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nEnbridge’s written specifications or standards for constructing each transmission line in\naccordance with 49 C.F.R. Part 192 were inadequate. Specifically, Enbridge’s Construction\nSpecifications failed to restrict miter joint deflection as specified in § 192.233 (a).\nSection 192.233 (a) states, “A miter joint on steel pipe to be operated at a pressure that produces a\nhoop stress of 30 percent or more of SMYS may not deflect the pipe more than 3°.”\nDuring the inspection, the PHMSA inspector requested Enbridge’s construction specifications or\nstandards addressing miter joint requirements. Enbridge provided Spectra Energy Construction\n\n\n\nCPF 1-2017-1016M\nSpecification – Onshore Compressor Stations - CS1.7, revised 02/22/2016 (Procedure). Regarding\nmiter joints, the Enbridge Procedure states \"Miter joints are not to be performed without written\napproval from the Company’s Metallurgical Services\", but did not restrict a miter joint on steel\npipe to be operated at a pressure that produces a hoop stress of 30 percent or more of SMYS to a\n3° deflection.\nTherefore, Enbridge written specifications and standards for construction were inadequate\nregarding the requirements of § 192.233 (a).\n2. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nEnbridge’s written specifications or standards for constructing each transmission line in\naccordance with 49 C.F.R. Part 192 were inadequate. Specifically, Enbridge’s Construction\nSpecifications failed to require the determination of the design pressure for steel pipe to be in\naccordance with the formula specified in § 192.105 (a).\nSection 192.105 (a) states in part:\n“(a) The design pressure for steel pipe is determined in accordance with the following formula:\nP = (2 St/D) × F × E × T”\nDuring the inspection, the PHMSA inspector requested Enbridge’s design and construction\nspecifications regarding design pressure requirements for steel pipe. Enbridge provided Enbridge\nConstruction Design Specification – Onshore Pipelines – DS-PL1.9, revised 06/12/2017\n(Procedure). Enbridge’s Procedure did not have a requirement for the design pressure for steel pipe\nto be determined in accordance with the formula: P = (2 St/D) × F × E × T.\nTherefore, Enbridge’s written specifications and standards for construction were inadequate\nregarding the requirements of § 192.105 (a).\n3. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nEnbridge’s written specifications or standards for constructing each transmission line in\naccordance with 49 C.F.R. Part 192 were inadequate. Specifically, Enbridge’s Construction\nSpecifications failed to require that each buried or submerged pipeline installed after July 31, 1971\nbe protected against external corrosion as specified in § 192.455 (a).\nSection 192.455 (a) states:\n“(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or submerged\npipeline installed after July 31, 1971, must be protected against external corrosion, including the\nfollowing:\n120171016M_Notice Of Amendment_10302017_text Page 2 of 4\n\n\n\nCPF 1-2017-1016M\n(1) It must have an external protective coating meeting the requirements of §192.461.\n(2) It must have a cathodic protection system designed to protect the pipeline in accordance with\nthis subpart, installed and placed in operation within 1 year after completion of construction.”\nDuring the inspection, the PHMSA inspector requested Enbridge’s construction specifications or\nstandards regarding requirements for the installation of cathodic protection and external corrosion\ncontrol for newly constructed transmission lines. Enbridge provided Spectra Energy Construction\nSpecification – Painting and Coating CS-ABC.2, Section 11, revised 04/18/2016 (Procedure). The\nProcedure did not require that each buried or submerged pipeline installed after July 31, 1971,\nmust be protected against external corrosion as required by § 192.455 (a).\nTherefore, Enbridge’s written specifications and standards for construction were inadequate\nregarding the requirements of § 192.455 (a).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment 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\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Enbridge maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-1016M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\n120171016M_Notice Of Amendment_10302017_text Page 3 of 4\n\n\n\nCPF 1-2017-1016M\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120171016M_Notice Of Amendment_10302017_text Page 4 of 4\n\n120171016M_Closure Letter_06072018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 7, 2018\nMr. Rick Kivela\nManager, Operational Compliance\nTexas Eastern Transmission, LP (Enbridge Inc.)\n5400 Westheimer Court\nHouston, TX 77251-1642\nCPF 1-2017-1016M\nDear Mr. Kivela:\nOn August 1 and 2, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nTexas Eastern Transmission, LP’s (TETLP), a subsidiary of Enbridge Inc., Lebanon Extension in\nPennsylvania. As a result of the inspection, TETLP was issued a Notice of Amendment (NOA) on\nOctober 30, 2017, which alleged inadequacies in your procedures.\nEnbridge, on behalf of its subsidiary, responded to the inadequacies alleged in the NOA on\nNovember 28, 2017, and submitted applicable procedures that were not previously provided during\nthe inspection. Enbridge also requested a telephonic hearing to be scheduled at a mutually\nagreeable time. My staff has completed its review of the procedures that were submitted, and it\nappears that the procedures address the issues identified in the NOA.\nThis letter is to inform you no further action is necessary, and this case is now closed. The need\nfor a hearing is now moot. Thank you for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":10776}