STECKMAN RIDGE, LP (SPECTRA ENERGY PARTNERS, LP) — Notice of Probable Violation

case documentOfficial PDF120181025_NOPV-PCO_12262018.pdf#

case documentOfficial PDF120181025_NOPV-PCO_12262018_text.pdf#

party submissionOfficial PDF120181025_Operator Response to Notice_01242019.pdf#

120181025_Closure Letter_03062020_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY March 6, 2020 Mr. William Yardley President, Gas Transmission & Midstream Enbridge, Inc. 5400 Westheimer Court P.O. Box 1642 Houston, TX 77251-1642 CPF 1-2018-1025 Dear Mr. Yardley: On June 27, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Steckman Ridge, LP (Steckman), a subsidiary of Spectra Energy Partners, LP, an Enbridge Company, a Final Order in the above-referenced case. The Final Order included a Compliance Order. Based on our review of the documentation provided to PHMSA on January 29, 2020, it has been determined that Steckman has complied with the terms of this 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, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

120181025_Final Order_06272019_text.pdf, page 1Official PDFJune 27, 2019 Mr. William Yardley President, Gas Transmission & Midstream Enbridge, Inc. 5400 Westheimer Court Houston, Texas 77056 Re: CPF No. 1-2018-1025 Dear Mr. Monaco: 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 by Steckman Ridge LP, a subsidiary of Spectra Energy Partners, LP, an Enbridge Company, to comply with the pipeline safety regulations. When the terms of the compliance order have been completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing, as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Mr. Robert Burroughs, Director, Eastern Region, Office of Pipeline Safety, PHMSA Mr. Rick Kivela, Manager, Operational Compliance, Enbridge, 5400 Westheimer Court, Houston, Texas 77056 CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120181025_Final Order_06272019_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 __________________________________________ In the Matter of ) Steckman Ridge LP, ) CPF No. 1-2018-1025 a subsidiary of Spectra Energy Partners, LP, ) ) ) ) Respondent. ) __________________________________________) FINAL ORDER From January 22 through August 24, 2018, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Steckman Ridge, LP (Steckman Ridge or Respondent), as part of the “Spectra TX Eastern North” system inspection, in Bedford County, Pennsylvania. Steckman Ridge is a subsidiary of Spectra Energy Partners, LP, an Enbridge company,1 and operates a natural gas storage field in Bedford County, Pennsylvania.2 As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated December 26, 2018, a Notice of Probable Violation and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Steckman Ridge had violated 49 C.F.R. § 192.616(a) and proposed ordering Respondent to take certain measures to correct the alleged violation. Enbridge, on behalf of Steckman Ridge, responded to the Notice by letter dated January 24, 2019 (Response). The company did not contest the allegation of violation and agreed to complete the proposed compliance actions. Respondent did not request a hearing and therefore has waived its right to one. FINDING OF VIOLATION In its Response, Steckman Ridge did not contest the allegation in the Notice that it violated 49 C.F.R. Part 192, as follows: 1 Enbridge, Inc. acquired Spectra Energy Partners, LP in December 2018. Spectra Energy Partners, LP, website, available at http://www.spectraenergypartners.com/ (last accessed Apr. 8, 2019). 2 Pipeline Safety Violation Report (Violation Report) (Dec. 26, 2018) (on file with PHMSA), at 1.#

120181025_Final Order_06272019_text.pdf, page 3CPF No. 1-2018-1025 Page 2 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.616(a), which states: § 192.616 Public awareness. (a) Except for an operator of a master meter or petroleum gas system covered under paragraph (j) of this section, each pipeline operator must develop and implement a written continuing public education program that follows the guidance provided in the American Petroleum Institute’s (API) Recommended Practice (RP) 1162 (incorporated by reference, see § 192.7). The Notice alleged that Respondent violated 49 C.F.R. § 192.616(a) by failing to implement portions of its written continuing public education program. Specifically, the Notice alleged that Steckman Ridge failed to follow its External Communication Plan (versions dated April 29, 2015 and February 22, 2017) by not distributing message mailings related to storage facilities to various stakeholders within the time periods required by the plan.3 Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.616(a) by failing to implement portions of its written continuing public education program that required delivery of storage facility mailings to stakeholders at certain intervals. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49 C.F.R. § 192.616(a). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of gas or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 192.616(a) (Item 1), Respondent must provide unique facility public awareness messages relative to the Steckman Ridge storage facility to the required stakeholders, as defined in Table 4 of its prior External Communication Plans effective during the timeframe of violation, within 60 days of receipt of this Final Order, and must provide record to PHMSA of this distribution within 90 days of receipt of this Final Order. 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. It is requested (not mandated) that Respondent maintain documentation of the safety 3 See Exhibits 3 and 4 to Violation Report at Table 4 (listing message mailing delivery frequencies).#

120181025_Final Order_06272019_text.pdf, page 4CPF No. 1-2018-1025 Page 3 improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. 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. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. June 27, 2019 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#