TEXAS EASTERN TRANSMISSION, LP (SPECTRA ENERGY PARTNERS, LP) — Notice of Amendment

party submissionOfficial PDF120191023M_Operator Response to Notice_02182020.pdf#

120191023M_Notice of Amendment_12192019_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY December 19, 2019 Ms. Michele Harradence VP, Gas Transmission & Midstream Operations Texas Eastern Transmission, LP 5400 Westheimer Court Houston TX 77056 CPF 1-2019-1023M Dear Ms. Harradence: From August 20 - 22, 2019, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected Texas Eastern Transmission, LP’s (Texas Eastern) procedures for the Accident Underground Natural Gas Storage (UNGS) facility in Garrett County, MD. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Texas Eastern’s plans or procedures, as described below: 1. § 192.12 Underground natural gas storage facilities. (a) …. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. Texas Eastern’s written procedures for implementing the requirements of API RP 1171 were inadequate. Specifically, Texas Eastern’s procedures did not adequately define annular gas threshold levels, as required by API RP 1171, Section 9.3.2.#

120191023M_Notice of Amendment_12192019_text.pdf, page 2CPF 1-2019-1023M 2. Section 9.3.2 states in part: The operator shall evaluate each annular gas occurrence that exceeds operator- or regulatory-defined threshold levels determined from well integrity evaluation and from risk assessment. Texas Eastern’s method for calculating annular gas threshold levels resulted in some threshold levels exceeding the MAOP of the field. § 192.12 Underground natural gas storage facilities. (a) …. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. Texas Eastern’s written procedures for implementing the requirements of API RP 1171 were inadequate. Specifically, Texas Eastern’s procedures did not adequately address how it would monitor for the presence of annular gas, as required by API RP 1171, Section 9.3.2. Section 9.3.2 states in part: The operator shall monitor for presence of annular gas by measuring and recording annular pressure and/or annular gas flow. Texas Eastern’s procedure for monitoring gas in an annulus open to the atmosphere required measuring the pressure buildup after a 5-minute shut-in time. Texas Eastern did not include subsequent actions if gas is detected in the annulus. The process is inadequate due to the lack of follow-up actions if gas is detected. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. 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). 120191023M_Notice of Amendment_12192019_text Page 2 of 3#

120191023M_Notice of Amendment_12192019_text.pdf, page 3CPF 1-2019-1023M Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Texas Eastern Transmission, LP maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2019-1023M on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office. Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings 120191023M_Notice of Amendment_12192019_text Page 3 of 3#

120191023M_Closure Letter_02212020_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY February 21, 2020 Ms. Michele Harradence VP, Gas Transmission & Midstream Operations Texas Eastern Transmission, LP 5400 Westheimer Court Houston TX 77056 CPF 1-2019-1023M Dear Ms. Harradence: From August 20 - 22, 2019, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Texas Eastern Transmission, LP's (TETLP) procedures for the Accident Underground Natural Gas Storage (UNGS) facility in Garrett County, MD. As a result of the inspection, TETLP was issued a Notice of Amendment on December 19, 2019, which proposed amendment of your procedures. TETLP submitted its amended procedures on February 18, 2020. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#