CPF 220071003W
CPF 220071003W
220071003W_Warning Letter_01262007.pdf, page 1Official PDFU.S. Deporlmenl of Tronsporfotion Plpetlne ond Hozqrdous ilotedols Sofety Adminlclrstlon 233 Peachtree Street Ste. 600 Adanta, GA 30303 WARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REOUESTED January 26,2007 Mr. Rich Adams Vice President Enbridge Pipelines (AlaTenn) LLC 1100 Louisiana Street Suire 3300 Houston. Texas77002 cPF 2-2007-1003W Dear Mr. Adams: On 18 to 20 December 2006, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your records in Muscle Shoals, Alabama and facilities in Alabama, Mississippi, and Tennessee. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations Title 49, Code of Federal Regulations. The items inspected and the probable violations are: $192.459 External corrosion control: Examination of buried pipeline when exposed. Whenever an operator has knowledge that any portion of a buried pipeline is exposed, the exposed portion must be examined for evidence of external corrosion ifthe pipe is bare, or ifthe coating is deteriorated. Ifexternal corrosion requiring remedial action under $$192.483 through 192.489 is found, the operator shall investigate circumferentially and longitudinally beyond the exposed portion (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinify of the exposed portion. Enbridge did not have records indicating the external examination for corrosion ofpipe exposed as part of work involved with a Teruressee Departrnent of Transportation#
220071003W_Warning Letter_01262007.pdf, page 2) 3. project on US Highway 64 near Selmer, Tennessee. Subsequent to the PHMSA inspection, Enbridge documented the examination when personnel examined a piece of the removed pipe held in their yard. Enbridge also reviewed project records and interviewed project personnel. Enbridge found no evidence of corrosion on the pipe, none was documented in daily project records, and project personnel did not see any when they checked the pipe as it was removed. S192,475 Internal corrosion control: General' (b) whenever any pipe is removed from a pipetine for any reason, the internal surface must be inspected for evidence of corrosion. Enbridge did not have records indicating the intemal examination for corrosion of pipe removed as part of work involved with a Tennessee Department of Transportation project on IJS Highway 64 near Selmer, Tennessee. Subsequent to the PHMSA inspection, Enbridge documented the inspection when personnel examined a piece of the removed pipe held in their yard. Enbridge also reviewed project records and interviewed project personnel. Enbridge found no evidence of corrosion on the pipe' none was documented in daily project records, and project personnel did not see any when they checked the pipe as it was removed. 9192.625 Odorization of gas. (a) A combustible gas in a distribution line must contain a natural odorant or be odorized so that at a concentration in air of one-fifth of the lower explosive limit' the gas is readily detectable by a person with a normal sense of smell. (b) After December 31, 1976, a combustible gas in a transmission line in a Class 3 or class 4 location must comply with the requirements of paragraph (a) of this section unlessl (1) At least 50 percent of the length of the line downstream from that location is in a Class I or Class 2 location The last 3.93 miles of Enbridge's l0" and 12" Decaturto Huntsville pipelines are in Class 3 areas in Madison County, Alabama. The natural gas is not odorized. Under 49 United States Code, S 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violations persists up to a maximum of $1,000,000 for any 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 ihis letter. Be advised that failwe to do so will result in Enbridge Pipelines (AlaTenn) LLC 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 2-2007-1003W. o#
220071003W_Warning Letter_01262007.pdf, page 3Sincerely, .h w6 / Linda Daugherty Director, Southern Region Pipeline and Hazardous Materials Safetv Administration#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.