ENLINK OHIO RIVER VALLEY PIPELINE, LLC — Warning Letter

120196001W_Warning Letter_01082019_text.pdf, page 1Official PDFWARNING LETTER OVERNIGHT EXPRESS DELIVERY January 8, 2019 Michael LeBlanc Senior Vice President - Operations EnLink LBU-ORV 60995 Derrick Road Plaquemine, LA 70764 CPF 1-2019-6001W Dear Mr. LeBlanc: From March 20 to May 24, 2018, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected the EnLink LBU-ORV (EnLink) crude oil pipeline system in the vicinity of Nashport, Ohio. As a result of the inspection, it is alleged that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violation(s) are: 1. § 195.428 Overpressure safety devices and overfill protection systems. (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used. EnLink failed to adequately document its inspection and testing of pressure limiting devices. Specifically, the records of inspection and testing of the overpressure protection (OPP) devices#

120196001W_Warning Letter_01082019_text.pdf, page 2CPF 1-2019-6001W (pump outlet high pressure switches) at Corning Station and Black Run Station failed to demonstrate that the devices functioned properly or were adequate from the standpoint of reliability of operation. During the inspection, records of the inspection and testing of OPP devices at the Corning and Black Run Stations were reviewed for 2015-2018. It was established that the MOP of the pipeline downstream of the Corning Station is 939 psig. The records documenting the 2015 and 2016 tests of the pump OPP device noted that the set pressure was left below this MOP. The 2017 and 2018 test records for the OPP device documented the set pressure was left above the MOP of the pipeline, in both years, at 950 psig. No comments noting a change were included in the records, and no documentation through a Management of Change (MOC) memorandum was provided during the inspection. In addition, the 2016 test record did not clearly document what “as-left” set pressure was confirmed, since a range of values were recorded. For the Black Run Station OPP device, the records demonstrated that it was set to operate at 900 psig in 2017. The MOP of the pipeline downstream of the Black Run Station is 892 psig, and the 2017 test record documented that the set pressure was left above the MOP of the pipeline. No comments noting a change were included in the records, and no documentation through a Management of Change (MOC) memorandum was provided during the inspection. Additionally, the 2018 test record does not document any “as-left” set pressure, but only notes that the gauge is “in spec.”. Therefore, EnLink failed to adequately document its inspection and tests of the OPP devices at the Corning and Black Run Stations. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related series of violations. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in EnLink being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-2019-6001W. 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 120196001W_Warning Letter_01082019_text Page 2 of 3#

120196001W_Warning Letter_01082019_text.pdf, page 3CPF 1-2019-6001W 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). No reply to this letter is required. If you choose to reply, please submit all correspondence in this matter to Robert Burrough, Director, PHMSA Eastern Region, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Please refer to CPF 1-2019-6001W 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 a CD accompanied by the original paper copy to the Eastern Region Office. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 120196001W_Warning Letter_01082019_text Page 3 of 3#