{"operation":"document","citation":"CPF 12020014CAO","title":"ALGONQUIN GAS TRANSMISSION, L.L.C. (SPECTRA ENERGY PARTNERS, LP) — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-10-01","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020014cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020014cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12020014cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12020014CAO","body":"Corrective Action Order involving ALGONQUIN GAS TRANSMISSION, L.L.C. (SPECTRA ENERGY PARTNERS, LP). The dataset does not identify a cited regulation for this case. The case was opened on 2020-10-01 and is reported as closed as of 2021-11-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12020014CAO_Amended Corrective Action Order_10302020_(20-172418).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Amended%20Corrective%20Action%20Order_10302020_(20-172418).pdf\n\n12020014CAO_Amended Corrective Action Order_10302020_(20-172418)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Amended%20Corrective%20Action%20Order_10302020_(20-172418)_text.pdf\n\n12020014CAO_Closure Letter_11172021_(20-172418).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Closure%20Letter_11172021_(20-172418).pdf\n\n12020014CAO_Closure Letter_11172021_(20-172418)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Closure%20Letter_11172021_(20-172418)_text.pdf\n\n12020014CAO_Corrective Action Order_10012020_(20-172418).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Corrective%20Action%20Order_10012020_(20-172418).pdf\n\n12020014CAO_Corrective Action Order_10012020_(20-172418)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Corrective%20Action%20Order_10012020_(20-172418)_text.pdf\n\n12020014CAO_Operator Hearing Request Withdrawn_11042020_(20-172418).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Operator%20Hearing%20Request%20Withdrawn_11042020_(20-172418).pdf\n\n12020014CAO_Operator Request for Hearing and Statement of Issues_10132020_(20-172418).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12020014CAO/12020014CAO_Operator%20Request%20for%20Hearing%20and%20Statement%20of%20Issues_10132020_(20-172418).pdf\n\n12020014CAO_Amended Corrective Action Order_10302020_(20-172418)_text.pdf\n\nOctober 30, 2020\nVIA ELECTRONIC MAIL TO: bill.yardley@enbridge.com\nMr. William T. Yardley\nPresident, Gas Transmission and Midstream\nEnbridge, Inc.\n5400 Westheimer Court\nHouston, Texas 77056\nCPF No. 1-2020-014-CAO\nDear Mr. Yardley:\nEnclosed please find an Amended Corrective Action Order (ACAO) issued by the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the\nabove-referenced case. It requires Algonquin Gas Transmission, LLC, a subsidiary of Enbridge\nInc., to take certain corrective actions with respect to Algonquin’s Weymouth Compressor Station\nin Weymouth, Massachusetts.\nService of the ACAO by electronic mail is deemed complete upon transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: ACAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Robert Burrough, Director, Eastern Region, OPS\nMs. Michele Harradence, SVP & Chief Operating Officer, Gas Transmission and\nMidstream, michele.harradence@enbridge.com\nMr. Nathan Atanu, Manager, Operational Compliance, Algonquin Gas Transmission, LLC,\nnathan.atanu@enbridge.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nAlgonquin Gas Transmission, LLC, ) CPF No. 1-2020-014-CAO\na subsidiary of Enbridge, Inc., )\n)\n)\n)\nRespondent. )\n____________________________________)\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Amended Corrective Action Order (ACAO or Order) is being issued under the authority of\n49 U.S.C. § 60112 to require Algonquin Gas Transmission, LLC (AGT or Respondent), a\nsubsidiary of Enbridge, Inc.,1 to take the necessary corrective actions to protect the public,\nproperty, and the environment from potential hazards associated with the unplanned emergency\nshutdown events at its Weymouth Compressor Station in Weymouth, Massachusetts (Station).\nOn September 11, 2020, the Station experienced an O-ring gasket failure on a sump tank during\nthe Station’s commissioning activities (Event 1). The failure triggered the manual operation of the\nemergency shutdown system and the release of approximately 169 thousand cubic feet (mscf) of\nnatural gas. On September 30, 2020, at approximately 10:30 AM, the Station experienced an\nunplanned emergency shutdown, resulting in the release of approximately 195 mscf of natural gas\n(Event 2). The circumstances surrounding the failure of the O-ring gasket in Event 1, as well as\nthe cause for the emergency shutdown in Event 2 (collectively, Events), are under investigation.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS), initiated an investigation\nof the Events. As a result of our investigation and additional information provided by AGT,\nPHMSA is issuing this ACAO to clarify a few of the preliminary facts and to modify the\ndefinitions. The ACAO does not make any substantive changes to the corrective actions prescribed\nin the CAO.\nThe preliminary findings of the agency’s ongoing investigation are as follows:\n1 Enbridge, Inc. website, National Gas Transmission and Midstream, available at\nhttps://www.enbridge.com/About-Us/Natural-Gas-Transmission-and-Midstream.aspx (last accessed September 30,\n2020).\n\n\n\nCPF No. 1-2020-014-CAO\nPage 2\nPreliminary Findings:\n The Station is the final part of AGT’s Atlantic Bridge Pipeline Project (Project). The\nProject involved replacing a 6.3-mile (10-kilometer) 26-inch-diameter pipe section\nwith a 42-inch pipe in New York and Connecticut. The Project also involved installing\na new meter station in Connecticut, modifications to various metering stations spread\nacross several states, installation of four new compressor units at existing facilities, and\na new compressor station in Weymouth, Massachusetts. The Project was designed to\nprovide an additional 132,700 dekatherms of capacity on the AGT pipeline system and\nthe Maritimes & Northeast pipeline system.\n Weymouth, Massachusetts, is a heavily populated suburb outside of Boston,\nMassachusetts. The Station is in a high consequence area, and is located near Fore\nRiver Bridge, a heavily trafficked commuter road.\n The Station has a station design pressure of 1440 pounds per square inch gauge (psig).\n The Station experienced a gasket failure that triggered the manual activation of its\nemergency shutdown system, as well as an unplanned emergency shutdown due to\nunknown reasons, less than three weeks apart.\n There were no injuries or fatalities associated with the Events; however, the release of\nlarge quantities of pressurized natural gas in a heavily populated area carries a\nsubstantial risk of fire, explosion, and personal injury or death, and releases natural gas\ninto the environment.\n On September 30, 2020, the inlet pressure at the Station was 683 psig; the discharge\npressure at the time of the emergency shutdown was 707 psig.\n AGT is performing a root cause failure analysis on the O-ring gasket failure that caused\nEvent 1.\n The reason for Event 2 is unknown and under investigation.\n The Station is currently shut-in.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and, if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\n\n\n\nCPF No. 1-2020-014-CAO\nPage 3\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material are transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider\nappropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered that the\nStation had an O-ring gasket failure that triggered the manual operation of its emergency\nshutdown system and an unplanned emergency shutdown for unknown reasons within three\nweeks of each other; the uncertainties as to the cause of Event 2; and the Station’s location in a\nHigh Consequence Area, and proximity to populated areas and highly-trafficked public roads, I\nfind that continued operation of the Station without corrective measures is or would be hazardous\nto life, property, or the environment, and that failure to issue this Order expeditiously would\nresult in the likelihood of serious harm.\nAccordingly, this Amended Corrective Action Order mandating immediate corrective action is\nissued without prior notice and opportunity for a hearing. The terms and conditions of this Order\nare effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Eastern Region, PHMSA (Director). If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending or withdrawing\nthis Order, if warranted by new supporting information. To the extent consistent with safety,\nRespondent will be afforded notice and an opportunity for a hearing prior to the imposition of any\nadditional corrective measures.\nRequired Corrective Actions:\nDefinitions:\nIsolated Segment – Means the Weymouth Compressor Station, from inlet valves to outlet\nvalves.\n\n\n\nCPF No. 1-2020-014-CAO\nPage 4\nDirector – Means the Director, Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, Eastern Region. The Director’s address is 840 Bear\nTavern Road, Suite 300, West Trenton, NJ 08626.\nPursuant to 49 U.S.C. 60112, I hereby order AGT to immediately take the following corrective\nactions for the Isolated Segment:\n1. Shutdown of the Isolated Segment. The Isolated Segment is currently shut-in and not in\noperation. AGT must not operate the Isolated Segment until authorized to do so by the\nDirector.\n2. Restart Plan. Prior to resuming operation of the Isolated Segment, AGT must develop and\nsubmit a written Restart Plan to the Director for approval.\na. The Director may approve the Restart Plan incrementally without approving the\nentire plan but the Isolated Segment cannot resume operation until the Restart Plan\nis approved in its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases during\nstart-up, with each increment to be held for at least two hours.\nd. The Restart Plan must include sufficient surveillance of the Isolated Segment\nduring each pressure increment to ensure that no leaks are present when operation\nof the pipeline facility resumes.\ne. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those that caused the Events, including a review of construction and\ncommissioning records. AGT must address any findings that require remedial\nmeasures to be implemented prior to restart.\ng. The Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into AGT’s operations and maintenance procedures\nmanual.\n3. Return to Service. After the Director approves the Restart Plan, AGT may return the\nIsolated Segment to service but the operating pressure must not exceed eighty percent\n(80%) of the actual operating pressure in effect immediately prior to Event 2, in accordance\nwith Item 2 above.\n4. Removal of Pressure Restriction. The Director may allow the removal or modification of\nthe pressure restriction upon a written request from AGT demonstrating that restoring the\n\n\n\nCPF No. 1-2020-014-CAO\nPage 5\nIsolated Segment to its pre-Event 2 operating pressure is justified based on a reliable\nengineering analysis showing that the pressure increase is safe, considering all known\ndefects, anomalies, and operating parameters of the Isolated Segment.\n5. Temporary Removal of Pressure Restriction. The Director may allow the temporary\nremoval or modification of the pressure restrictions upon a written request from AGT\ndemonstrating that temporary mitigative and preventive measures are being implemented\nprior to and during the temporary removal or modification of the pressure restriction. The\nDirector's determination will be based on the known or suspected cause of Event 2 and the\nprovision of evidence that preventive and mitigative actions taken by the operator provide\nfor the safe operation of the Isolated Segment during the temporary removal or\nmodification of the pressure restriction. Appeals to determinations of the Director in this\nregard will be decided by the Associate Administrator for Pipeline Safety.\n6. Root Cause Failure Analysis. Within 90 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the\nDirector. The RCFA must be supplemented or facilitated by an independent third-party\nacceptable to the Director and must document the decision-making process and all factors\ncontributing to Event 2. The final report must include findings and any lessons learned and\nwhether the findings and any lessons learned are applicable to other locations within AGT’s\npipeline system.\nOther Requirements:\n7. Approvals. With respect to each submission that under this Order requires the approval of\nthe Director, the Director may: (a) approve, in whole or part, the submission; (b) approve\nthe submission on specified conditions; (c) modify the submission to cure any deficiencies;\n(d) disapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director, and resubmit it for approval.\n8. Extensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Order upon a written request timely submitted demonstrating good\ncause for an extension.\n9. Reporting. Submit monthly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first monthly report is due\non November 27, 2020. The Director may change the interval for the submission of these\nreports.\n10. Documentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action\nOrder. Include in each monthly report submitted, the to-date total costs associated with:\n\n\n\nCPF No. 1-2020-014-CAO\nPage 6\n(1) preparation and revision of procedures, studies and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, if applicable.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 1-2020-014-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The actions\nrequired by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued\nto Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of Federal\nor State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nOctober 30, 2020\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n12020014CAO_Corrective Action Order_10012020_(20-172418)_text.pdf\n\nOctober 1, 2020\nVIA ELECTRONIC MAIL TO: bill.yardley@enbridge.com\nMr. William T. Yardley\nPresident, Gas Transmission and Midstream\nEnbridge, Inc.\n5400 Westheimer Court\nHouston, Texas 77056\nCPF No. 1-2020-014-CAO\nDear Mr. Yardley:\nEnclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-\nreferenced case. It requires Algonquin Gas Transmission, LLC, a subsidiary of Enbridge Inc., to\ntake certain corrective actions with respect to Algonquin’s Weymouth Compressor Station in\nWeymouth, Massachusetts.\nService of the CAO by electronic mail is deemed complete upon transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Robert Burrough, Director, Eastern Region, OPS\nMs. Michele Harradence, SVP & Chief Operating Officer, Gas Transmission and\nMidstream, michele.harradence@enbridge.com\nMr. Nathan Atanu, Manager, Operational Compliance, Algonquin Gas Transmission, LLC,\nnathan.atanu@enbridge.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nAlgonquin Gas Transmission, LLC, ) CPF No. 1-2020-014-CAO\na subsidiary of Enbridge, Inc., )\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (CAO or Order) is being issued under the authority of 49 U.S.C.\n§ 60112 to require Algonquin Gas Transmission, LLC (AGT or Respondent), a subsidiary of\nEnbridge, Inc.,1 to take the necessary corrective actions to protect the public, property, and the\nenvironment from potential hazards associated with the multiple unplanned emergency shutdown\nevents at its Weymouth Compressor Station in Weymouth, Massachusetts (Station).\nOn September 11, 2020, the Station experienced an O-ring gasket failure on a sump tank during\nthe Station’s commissioning activities (Incident 1). The failure triggered the manual operation of\nthe emergency shutdown system and the release of approximately 169 thousand cubic feet (mscf)\nof natural gas. On September 30, 2020, at approximately 10:30 AM, the Station experienced an\nunplanned emergency shutdown, resulting in the release of approximately 275 mscf of natural gas\n(Incident 2). The circumstances surrounding the failure of the O-ring gasket in Incident 1, as well\nas the cause for the emergency shutdown in Incident 2 (collectively, Incidents) are under\ninvestigation.\nPursuant to 49 U.S.C. § 60117, PHMSA, Office of Pipeline Safety (OPS), initiated an investigation\nof the Incidents. The preliminary findings of the agency’s ongoing investigation are as follows:\nPreliminary Findings:\n The Station is part of the AGT’s Atlantic Bridge Pipeline Project (Project). The Project\ninvolves replacing a 6.3-mile (10-kilometer) 26-inch-diameter pipe section with a 42-\ninch pipe in New York and Connecticut. The Project also involves installing a new\n1 Enbridge, Inc. website, National Gas Transmission and Midstream, available at\nhttps://www.enbridge.com/About-Us/Natural-Gas-Transmission-and-Midstream.aspx (last accessed September 30,\n2020).\n\n\n\nCPF No. 1-2020-014-CAO\nPage 2\nmeter station in Connecticut, modifications to various metering stations spread across\nseveral states, installation of four new compressor units at existing facilities, and a new\ncompressor station in Weymouth, Massachusetts. When completed, the Project will\nprovide an additional 132,700 dekatherms of capacity on the AGT pipeline system and\nthe Maritimes & Northeast pipeline system.\n Weymouth, Massachusetts, is a heavily populated suburb outside of Boston,\nMassachusetts. The Station is in a high consequence area, and is located near Fore\nRiver Bridge, a heavily trafficked commuter road.\n The Station has a station design pressure of 1440 pounds per square inch gauge (psig).\n The Station experienced a gasket failure that triggered the manual activation of its\nemergency shutdown system, as well as an unplanned emergency shutdown due to\nunknown reasons, less than three weeks apart.\n There were no injuries or fatalities associated with the Incidents; however, the release\nof large quantities of pressurized natural gas in a heavily populated area carries a\nsubstantial risk of fire, explosion, and personal injury or death and releases harmful\nmethane into the environment.\n On September 30, 2020, the inlet pressure at the Station was 683 psig; the discharge\npressure at the time of the emergency shutdown was 707 psig.\n AGT is performing a root cause failure analysis on the O-ring gasket failure that caused\nIncident 1.\n The reason for Incident 2 is unknown and under investigation.\n The Station is currently shut-in.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and, if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\n\n\n\nCPF No. 1-2020-014-CAO\nPage 3\ndeteriorative qualities of the material, the sequence in which the material are transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider\nappropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered that the\nStation had an O-ring gasket failure that triggered the manual operation of its emergency\nshutdown system and an unplanned emergency shutdown for unknown reasons within the past\nthree weeks; the uncertainties as to the cause of Incident 2; and the Station’s location in a High\nConsequence Area, and proximity to populated areas and highly-trafficked public roads, I find\nthat continued operation of the Station without corrective measures is or would be hazardous to\nlife, property, or the environment, and that failure to issue this Order expeditiously would result\nin the likelihood of serious harm.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Southwest Region, PHMSA (Director). If a hearing is requested, it will be held in\naccordance with 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending or withdrawing\nthis Order, if warranted by new supporting information. To the extent consistent with safety,\nRespondent will be afforded notice and an opportunity for a hearing prior to the imposition of any\nadditional corrective measures.\nRequired Corrective Actions:\nDefinitions:\nAffected Pipeline – The Weymouth Compressor Station, including incoming pipeline, I-\n10, back to first upstream mainline valve.\nIsolated Segment – Means the Weymouth Compressor Station, from inlet valves to outlet\nvalves.\nDirector – Means the Director, Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety, Eastern Region. The Director’s address is 840 Bear\nTavern Road, Suite 300, West Trenton, NJ 08626.\n\n\n\nCPF No. 1-2020-014-CAO\nPage 4\nPursuant to 49 U.S.C. 60112, I hereby order AGT to immediately take the following corrective\nactions for the Affected Pipeline and Isolated Segment:\n1. Shutdown of the Isolated Segment. The Isolated Segment is currently shut-in and not in\noperation. AGT must not operate the Isolated Segment until authorized to do so by the\nDirector.\n2. Restart Plan. Prior to resuming operation of the Isolated Segment, AGT must develop and\nsubmit a written Restart Plan to the Director for approval.\na. The Director may approve the Restart Plan incrementally without approving the\nentire plan but the Isolated Segment cannot resume operation until the Restart Plan\nis approved in its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment\nduring the restart process and must include incremental pressure increases during\nstart-up, with each increment to be held for at least two hours.\nd. The Restart Plan must include sufficient surveillance of the Isolated Segment\nduring each pressure increment to ensure that no leaks are present when operation\nof the line resumes.\ne. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those that caused the Incidents, including a review of construction and\ncommissioning records. AGT must address any findings that require remedial\nmeasures to be implemented prior to restart.\ng. The Restart Plan must also include documentation of the completion of all\nmandated actions, and a management of change plan to ensure that all procedural\nmodifications are incorporated into AGT’s operations and maintenance procedures\nmanual.\nh. Prior to restart, AGT must submit to the Director a contingency plan to operate and\nmonitor the Isolated Segment during flooding conditions, including enhanced\npatrolling and surveillance.\n3. Return to Service. After the Director approves the Restart Plan, AGT may return the\nIsolated Segment to service but the operating pressure must not exceed eighty percent\n(80%) of the actual operating pressure in effect immediately prior to Incident 2, in\naccordance with Item 2 above.\n\n\n\nCPF No. 1-2020-014-CAO\nPage 5\n4. Removal of Pressure Restriction. The Director may allow the removal or modification of\nthe pressure restriction upon a written request from AGT demonstrating that restoring the\npipeline to its pre-Incident 2 operating pressure is justified based on a reliable engineering\nanalysis showing that the pressure increase is safe, considering all known defects,\nanomalies, and operating parameters of the pipeline.\nThe Director may allow the removal or modification of the pressure restriction upon a\nwritten request from AGT demonstrating that restoring the Affected Segment to its pre-\nIncident 2 operating pressure is justified, based on a reliable engineering analysis showing\nthat the pressure increase is safe, considering all known defects, anomalies, and operating\nparameters of the pipeline.\n5. Temporary Removal of Pressure Restriction. The Director may allow the temporary\nremoval or modification of the pressure restrictions upon a written request from AGT\ndemonstrating that temporary mitigative and preventive measures are being implemented\nprior to and during the temporary removal or modification of the pressure restriction. The\nDirector's determination will be based on the known or suspected cause of Incident 2 and\nthe provision of evidence that preventive and mitigative actions taken by the operator\nprovide for the safe operation of the Affected Segment during the temporary removal or\nmodification of the pressure restriction. Appeals to determinations of the Director in this\nregard will be decided by the Associate Administrator for Pipeline Safety.\n6. Root Cause Failure Analysis. Within 90 days following receipt of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the\nDirector. The RCFA must be supplemented or facilitated by an independent third-party\nacceptable to the Director and must document the decision-making process and all factors\ncontributing to Incident 2. The final report must include findings and any lessons learned\nand whether the findings and any lessons learned are applicable to other locations within\nAGT’s pipeline system.\nOther Requirements:\n7. Approvals. With respect to each submission that under this Order requires the approval of\nthe Director, the Director may: (a) approve, in whole or part, the submission; (b) approve\nthe submission on specified conditions; (c) modify the submission to cure any deficiencies;\n(d) disapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director, and resubmit it for approval.\n8. Extensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Order upon a written request timely submitted demonstrating good\ncause for an extension.\n9. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\n\n\n\nCPF No. 1-2020-014-CAO\nPage 6\nof the repairs or other remedial actions being undertaken. The first quarterly report is due\non January 4, 2021. The Director may change the interval for the submission of these\nreports.\n10. Documentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action\nOrder. Include in each monthly report submitted, the to-date total costs associated with:\n(1) preparation and revision of procedures, studies and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation, if applicable.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 1-2020-014-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The actions\nrequired by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued\nto Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of Federal\nor State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nOctober 1, 2020\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n12020014CAO_Closure Letter_11172021_(20-172418)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Bill.Yardley@enbridge.com\nNovember 17, 2021\nMr. William T. Yardley\nPresident, Gas Transmission and Midstream\nEnbridge, Inc.\n5400 Westheimer Court\nHouston, Texas 77056\nCPF 1-2020-014-CAO\nDear Mr. Yardley:\nOn October 1, 2020, and on October 30, 2020, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) issued a Corrective Action Order (CAO) and an Amended Corrective\nAction Order (ACAO), respectively, to Algonquin Gas Transmission, LLC (AGT), a subsidiary\nof Enbridge, Inc., with regard to the September 11, 2020 and September 30, 2020 events at\nWeymouth Compressor Station. The ACAO included a list of various required Corrective Actions.\nWe have received a final monthly report, dated August 13, 2021, from Mr. Nathan Atanu,\nManager, Operational Compliance. We have also received eight earlier monthly reports, submitted\nas part of the final Corrective Action deliverable, required under item 9 of the ACAO.\nSubsequently, a letter from Mr. Atanu was received on August 18, 2021 requesting closure of the\nACAO.\nDuring our review of the documentation, a PHMSA investigator performed multiple on-site visits\nto verify completion of corrective actions. The investigator was on site to view Phase 1 through\nPhase 4 of the approved Restart Plan from December 4 to 7, 2020. The Weymouth Compressor\nStation was operating at 683 pounds per square inch gauge (psig) at the time of Event 2. Leakage\nsurveys of the Isolated Segment of Weymouth Compressor Station were performed and reviewed\nduring the two (2) hour hold periods of each phase. After receiving appropriate approval to proceed\nto Phase 5 of the Restart Plan, AGT completed a Temporary Removal of Pressure Restriction,\nwhich was also verified by the investigator.\nThe Root Cause Failure Analysis (RCFA) was received by PHMSA on December 22, 2020. The\nACAO requires that all recommendations from the RCFA be incorporated into AGT’s Operations\nand Maintenance Manual. This was completed and subsequently reviewed and verified by the\nPHMSA investigator on August 18, 2021.\nPHMSA reminds AGT of the requirements enacted by Congress and described in Section 114 of\nthe “Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020” (PIPES Act of\n2020), which requires all pipeline operators to address the elimination of hazardous leaks and\nminimization of releases of natural gas. Please refer to PHMSA Advisory Bulletin ADB-2021-\n01, for more information on this self-executing provision. PHMSA will be conducting\ninspections of these modified plans in 2022.\n\n\n\nCPF 1-2020-014-CAO\nPHMSA also requests that AGT continue to maintain relationships and open communication with\nstate and local authorities such as the Massachusetts Department of Environmental Protection, the\nTown of Weymouth, the Town of Braintree, and the City of Quincy.\nPHMSA is also aware that AGT has initiated and completed additional safety measures in addition\nto the requirements of the ACAO. For example, AGT has utilized Pipeline Safety Management\nSystem (PSMS) principles to perform additional risk assessments to Weymouth Compressor\nStation systems outside the scope of the ACAO and have incorporated the lessons learned. AGT\nhad a third party review the Emergency Shutdown (ESD) system and have incorporated all the\nrecommended enhancements into policies and procedures. Finally, AGT continues to perform\nweekly leakage surveys throughout the compressor station, a practice which started back in\nNovember 2020.\nBased on our review of the documentation you provided, it has been determined that you have\ncomplied with the terms of this Order. Accordingly, this CAO is now closed. It is our expectation\nthat AGT will aggressively implement methane emission reduction strategies at this facility and\nother locations along its pipeline systems. As noted previously, PHMSA will be inspecting all\npipeline facilities across the country to ensure alignment with statutory requirements for redu","truncated":true,"body_characters":40462}