{"operation":"document","citation":"CPF 220125008W","title":"ENTERPRISE PRODUCTS OPERATING LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-07-25","effective_on":null,"summary":"CLOSED warning letter citing 195.452(f)(1), 195.452(f)(3), 195.452(g), 195.452(i)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220125008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220125008W","body":"Warning Letter involving ENTERPRISE PRODUCTS OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(1),  195.452(f)(3),  195.452(g),  195.452(i)(4). The case was opened on 2012-07-25 and is reported as closed as of 2012-07-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220125008W_warning letter_07252012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125008W/220125008W_warning%20letter_07252012.pdf\n\n220125008W_warning letter_07252012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125008W/220125008W_warning%20letter_07252012_text.pdf\n\n220125008W_warning letter_07252012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 25, 2012\nMr. Terry Hurlburt\nSenior Vice President of Operations\nEnterprise Products Operating LLC\n1100 Louisiana Street\nHouston, TX 77002\nCPF 2-2012-5008W\nDear Mr. Hurlburt:\nFrom June 14 to October 22, 2010, and from April 25 - 27, 2011, representatives of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) inspected Enterprise\nProducts Operating LLCa\n(Enterprise) Integrity Management Program (IMP) and pipeline\nfacilities in Texas, Louisiana, Arkansas, Tennessee, Missouri, Indiana, Kentucky, Illinois,\nOhio, and Pennsylvania, pursuant to Chapter 601 of 49 United States Code.\n1. § 195.452 Pipeline integrity management in high consequence areas.\n. . . (f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high consequence\narea;\nEnterprise did not adequately identify which pipeline segments could affect a high\nconsequence area (HCA) because it did not conduct an HCA identification or re-analysis,\nin a timely manner, subsequent to changing the product transported from McRae to West\nMemphis in Line P74.\na TE Products Pipeline, LLC (TEPPCO) was the operator of record at the initiation of the inspection in June\n2010. Effective August 17, 2010, TE Products Pipeline, LLC under operator identification number (OPID\nnumber) 19237 was legally changed to Enterprise Products Operating LLC, under OPID number of 31618.\n\n\n\nOn November 12, 2009, Enterprise changed the product transported in its Line P74 from a\nhighly volatile liquid (HVL) to a non-HVL. HVL and non-HVL products can have\nsignificantly different flow and dispersion characteristics when released from a pipeline.\nAt the time of the PHMSA field inspection of Line P74 on October 21, 2010, Enterprise\nhad previously identified “could-affect HCA segments” on the McRae to West Memphis\nLine P74 that were based on dispersion characteristics of the previously transported HVLs\n(propane and butane). While Enterprise began non-HVL flow in Line P74 on\nNovember 12, 2009, it had not performed overland spread and water transport analyses to\ndetermine if the change in product spread characteristics resulted in new “could-affect\nHCA segments.”\nAdditionally, Enterprise's Pipeline Integrity Group was aware, as early as March 23, 2009,\nthat Line P74 was transporting non-HVLs but Enterprise had not re-scheduled or\ncompleted an HCA re-analysis prior to PHMSA's inquiries made subsequent to the\nOctober 21, 2010, field inspection. The HCA re-analysis could have taken two years or\nmore to complete after the product was first changed in the pipeline.\n2. § 195.452 Pipeline integrity management in high consequence areas.\n. . . (f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high consequence\narea;\nEnterprise’s IMP process did not properly identify which pipeline segments could affect\nan HCA because it did not include an adequate analysis of the dispersion of vapors from\nthe release of highly volatile liquids and volatile liquids.\nEnterprise’s process did not provide a technical justification for the identification of which\npipeline segments could affect an HCA because at the time of the determination the\nPotential Impact Radii (PIR) for Line P2 and Line P-63 were not available. Additionally,\nthe PIR for Line P-35 had been incorrectly changed during the process from the correct\nvalue of 5,000 feet to 3,500 feet by Enterprise’s contractor during the HCA determination\nprocess. The correct PIR for each pipeline segment was necessary to identify which\npipeline segments could affect a high consequence area due to a release of highly volatile\nliquids.\n3. § 195.452 Pipeline integrity management in high consequence areas.\n. . . (f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\n2\n\n\n\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n. . . (3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nEnterprise did not properly complete an analysis that integrated all available information\nabout the integrity of its entire pipeline and the consequences of a failure as follows:\na) The DRAS common risk model Enterprise used in its IMP to perform a minimal risk\nanalysis relied on Enterprise’s PODS database. The data input into the DRAS model\nfrom PODS, however, was not sufficient in that PODS did not have all the data\nrequired to perform the minimal risk analysis. Moreover, Enterprise was unable to\nretrieve the following data via its risk model Data View application when requested to\ndo so by the PHMSA inspectors during the inspection.\n− P2 Mainline Coating Type - Priority 2 (previous list indicated Priority 1)\n− P40 Mainline Coating Type - Priority 2 (previous list indicated Priority 1)\n− P2 Pipe Grade - Priority 1\n− P2 ILI Technology - Priority 3 (previous list indicated Priority 1)\n− P2 ILI Date - Priority 3 (previous list indicated Priority 1)\n− Information on Ohio River Crossing on the A1/A3 lines, Lines P2 and P62\nMississippi River Crossings\nThe priorities shown above are from a list Enterprise provided to PHMSA on\n08/27/2010. Priority 1 risk data are those elements that are essential to risk and which\nmust be included to allow the risk model to provide the minimal risk results set.\nb) Enterprise did not use adequate and appropriate processes to input data and\ninformation into the risk analysis process. Enterprise converted from its TEPPCO\nBass Trigon IAP risk model to the DRAS risk model in May 2010. During the\nPHMSA inspection, Enterprise determined that the data provided to the common risk\nmodel vendor (DRAS) was not read properly into the model; thus, invalidating the\nresults. On July 22, 2010, Enterprise declared the DRAS model invalid and reverted\nback to the previously used TEPPCO Bass Trigon IAP model.\nc) Enterprise had incorrect data in its PODS database. Maps and drawings using PODS-\nextracted data indicated the following PODS data were incorrect.\n− Drawing number TEPPCO Southern - P22-PAL_003, dated 08/20/2010,\nincorrectly indicated the route of Line P22 as traversing under three buildings in\nthe (HCA) area upstream of milepost 5.\n− Drawing number TEPPCO Southern - P22-PAL_005, dated 08/20/2010,\nincorrectly identified the year of construction of pipeline segments as 1990 -\nconstruction years were 1953-1955.\n− Map number F16_0180_E, dated 09/09/2010,\n- Incorrectly indicated that a valve existed on Line P22 near Benton, AR; and,\n- Did not indicate a 3,661-foot segment as an HCA. This segment was\ndetermined to be an HCA in 2004 by Bass Trigon, but the HCA data was not\nresident in the PODS database.3\n\n\n\n− A Line P74 main line valve located at approximately mile post (MP) 6.01 was\nnot indicated on drawings TEPPCO Southern--P74--PAL_001 and _ 002 dated\n08/20/2010.\n− A Line P74 main line valve was indicated on drawing TEPPCO Southern--P74--\nPAL_009 dated 08/20/2010 at MP52-44+70. This valve had been previously\nremoved and a valve no longer existed at this location.\n− A Line P74 main line valve was indicated on drawing TEPPCO Southern--P74--\nPAL_015 dated 08/20/2010 at MP89-06+16. A valve did not exist at this\nlocation.\n− A Line P2 main line valve was indicated at station 18378+67 (MP 348.08) on\ndrawing TEPPCO ML-P2-PAL_107 dated 08/20/2010. Although a valve\nexisted on Line P62 at this location, a valve did not exist on Line P2 at this\nlocation.\n− A Line P2 main line valve located at approximately MP 441.04 was not\nindicated on drawing TEPPCO ML-P2-PAL_132 dated 08/20/2010.\n4. § 195.452 Pipeline integrity management in high consequence areas.\n. . . (g) What is an information analysis? In periodically evaluating the integrity of\neach pipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the consequences\nof a failure. This information includes:\nEnterprise did not follow its IMP process for performing the periodic evaluation of the\nintegrity of its pipeline.\nEnterprise’s procedure IMP SEC6-01 Information Analysis - Line Pipe required Enterprise\nto perform an information analysis (IA) for its pipeline segments within 2 years of the\ncompletion of the integrity assessment. Four of the IAs the PHMSA inspectors reviewed\nduring the inspection did not meet Enterprise’s required 2-year timeframe. PHMSA later\nrecognized that Enterprise had significantly reduced the backlog of IAs that had not been\ncompleted within 2 years of the integrity assessment, but as of August 25, 2010, there\nwere still five backlogged IAs.\n5. § 195.452 Pipeline integrity management in high consequence areas.\n. . . (i) What preventative and mitigative measures must an operator take to protect the\nhigh consequence area?\n… (4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an\nEFRD is needed on a pipeline segment to protect a high consequence area in the\nevent of a hazardous liquid pipeline release, an operator must install the EFRD. In\nmaking this determination, an operator must, at least, consider the following\nfactors—the swiftness of leak detection and pipeline shutdown capabilities, the type\nof commodity carried, the rate of potential leakage, the volume that can be released,\ntopography or pipeline profile, the potential for ignition, proximity to power sources,\nlocation of nearest response personnel, specific terrain between the pipeline segment\nand the high consequence area, and benefits expected by reducing the spill size.\n4\n\n\n\nEnterprise excessively delayed its process to determine if EFRDs were needed on certain\npipeline segments to protect high consequence areas in the event of a hazardous liquid\npipeline release.\nEnterprise’s IMP procedure Emergency Flow Restricting Devices (EFRD) Analysis\nProcess, rev.0 was initially approved on June 14, 2010. Based on data provided by\nEnterprise dated August 27, 2010, however, recommendations to perform evaluations for\ninstalling additional EFRDs on many pipeline segments dated back to 2007. The EFRD\nRecommendation Status remained open as of August 27, 2010.\nFor example, Enterprise’s records showed recommendations were made for an EFRD\nreview of Line P62 AID Segment 496, based on an October 1, 2007, information analysis.\nYet, the scheduled completion date for the EFRD feasibility study for this AID was not\nuntil the 4th quarter of 2010. Moreover, once Enterprise completes the feasibility study\nand recommends installation of an EFRD, time is still required for installation. It was\nnoted that all of the “open” recommended EFRD studies were scheduled for feasibility\nstudy completion by the end of the 4th quarter of 2010.\nUnder 49 United States Code, §60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Enterprise Products\nOperating LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 2-2012-5008W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n5","truncated":false,"body_characters":14117}