# SABAL TRAIL TRANSMISSION, LLC (SPECTRA ENERGY PARTNERS, LP) — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 220191001
- **title:** SABAL TRAIL TRANSMISSION, LLC (SPECTRA ENERGY PARTNERS, LP) — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-03-19
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.225(a), 192.235, 192.505(d).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220191001.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220191001.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220191001
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220191001
**body:**

Notice of Probable Violation involving SABAL TRAIL TRANSMISSION, LLC (SPECTRA ENERGY PARTNERS, LP). PHMSA's enforcement data identifies the cited regulations as 192.225(a),  192.235,  192.505(d). The case was opened on 2019-03-19 and is reported as closed as of 2021-09-02. Proposed civil penalty: $52,500. Assessed civil penalty: $19,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220191001_Closure Letter_09022021_(16-153225S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_Closure%20Letter_09022021_(16-153225S).pdf

220191001_Closure Letter_09022021_(16-153225S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_Closure%20Letter_09022021_(16-153225S)_text.pdf

220191001_Final Order_04102020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_Final%20Order_04102020.pdf

220191001_Final Order_04102020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_Final%20Order_04102020_text.pdf

220191001_NOPV PCP PCO_03192019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_NOPV%20PCP%20PCO_03192019.pdf

220191001_NOPV PCP PCO_03192019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_NOPV%20PCP%20PCO_03192019_text.pdf

220191001_Operator Response to Notice and Request for Hearing_05312019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220191001/220191001_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing_05312019.pdf

220191001_NOPV PCP PCO_03192019_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 19, 2019
Ms. Michele Harradence
Vice President
Gas Transmission & Midstream Operations
Sabal Trail Transmission, LLC
5400 Westheimer Court
Houston, Texas 77056
CPF 2-2019-1001
Dear Ms. Harradence:
From October 16, 2016 through April 7, 2017, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected construction activities and records related to Sabal Trail Transmission
(STT) pipeline construction project in Alabama, Georgia, and Florida.
As a result of the inspection, it is alleged that STT has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:
1. §192.225 Welding procedures.
(a) Welding must be performed by a qualified welder in accordance with welding
procedures qualified under section 5 of API 1104.
STT failed to comply with the regulation because welding was not performed in
accordance with procedures qualified under Section 5 of API 1104 on at least 2 welds.
Specifically, STT did not adhere to the pre-heat requirements specified in the procedure
qualification record throughout the welding process, as required under Section 5 of
API 1104. API Standard 1104, titled “Welding of Pipelines and Related Facilities,”
20th Edition, is incorporated by reference in § 192.7.
Section 5 of API 1104 prescribes the required parameters and variables to be considered
when qualifying a welding procedure. Section 5.4.2.13, titled “Pre-heat,” states that “A
decrease in the specified minimum pre-heat temperature constitutes an essential variable.”
STT Welding Procedure Specifications (WPS) BCS-422.1 and BCS-122.2 (the primary



welding procedures for main line welding and station piping, respectively), were
developed in accordance with API 1104. These welding procedures were qualified using a
minimum preheat and interpass temperature of 250° F. A decrease in the minimum
preheat temperature from the original welding qualification during production requires
requalification of the welding procedure.
Representatives of PHMSA observed construction activity at STT’s Hildreth Compressor
Station on December 5, 2016, and Spread 3 of the main line construction on
February 1, 2017. PHMSA representatives observed welding being performed in
accordance with STT’s WPS BCS-122.2 and WPS BCS-422.1, respectively. During these
site visits, the PHMSA representatives observed pre-heat temperatures for at least two
welds that were not maintained at a minimum of 250° F immediately prior to welding, as
required by the above-referenced welding procedures.
2. §192.235 Preparation for welding.
Before beginning any welding, the welding surfaces must be clean and free of any
material that may be detrimental to the weld, and the pipe or component must be
aligned to provide the most favorable condition for depositing the root bead. This
alignment must be preserved while the root bead is being deposited.
STT failed to comply with the regulation because the alignment of the pipe or component
being welded was not preserved while the root bead was being deposited.
As documented in STT reports, titled “Delayed Weld Examination (ML)” and “Welding
Preheat Report,” dated March 28, 2017, and January 18, 2018, respectively, STT
identified and cut out thirty (30) cracks during construction. Thirteen (13) of these cracks
were described as longitudinal crack defects. Per STT’s “Crack Cut Out and Repair Log,”
dated March 7, 2017, the probable cause was the pipe was moved “before sufficient weld
metal was deposited” for several of these welds, refer to the descriptions listed in the
column labeled, “Comments.”
3. §192.505 Strength test requirements for steel pipeline to operate at a hoop stress of
30 percent or more of SMYS.
(a) …
(d) For fabricated units and short sections of pipe, for which a post installation test is
impractical, a preinstallation strength test must be conducted by maintaining the
pressure for at least 4 hours.
STT failed to comply with the regulation because it did not demonstrate that it was
impractical to conduct post installation tests for fabricated units and short sections of pipe.
Specifically, STT did not demonstrate the impracticality of post installation tests for
prefabricated main line valve assemblies.
In its report, titled “Mainline Valve Hydrostatic Test Assessment Report,” dated January
18, 2018, the justification provided as to why it was impractical to perform post
installation hydrostatic testing of the mainline valves was that STT wanted to minimize
the possibility of damaging the valve seats caused by dirt, debris and weld slag getting
2



into the seats during filling, hydrostatic testing, dewatering and drying of the pipeline.
Upon PHMSA’s request, however, STT was unable to provide any evidence, historical or
otherwise, of valve seats damaged during a post installation hydrostatic pressure test on
any previous pipeline construction project. STT also failed to provide any evidence that
its own valves had been damaged due to dirt, debris and weld slag entering the valve seats
during filling, hydrostatic testing, dewatering and drying of the pipeline.
It should be noted that PHMSA representatives confirmed that STT complied with the
requirements of §§192.503(b)(2) and 192.517(a)(7) which require that dirt, debris and/or
weld slag be removed during the construction. §192.503(b)(2) states, in part, that, “…The
test medium must be liquid…relatively free of sedimentary materials,” and §192.517(a)(7)
states, in part, that, “…Each operator shall make, and retain for the useful life of the
pipeline, a record of each test performed under §§192.505 and 192.507. The record must
contain at least the following information…Leaks and failures noted and their
disposition.” Furthermore, STT Construction Specifications (CS) CSPL1.8 and CS1.5,
titled “Onshore Pipeline and Meter Stations,” and “Onshore Compressor Stations,”
respectively, state, in part, “Prior to being aligned and welded into the line, each pipe
joint shall be thoroughly inspected for presence of debris. If debris is visible, each joint
shall be swabbed to remove all debris to the satisfaction of the Engineer.”
Proposed Civil Penalty
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 violations 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. The
Compliance Officer has reviewed the circumstances and supporting documentation involved
in the above probable violation(s) and has recommended that you be preliminarily assessed a
civil penalty of $52,500 as follows:
Item number PENALTY
1 $52,500
Warning Items
With respect to Items 2 and 3, we 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 promptly correct these items.
Failure to do so may result in additional enforcement action.
Proposed Compliance Order
3



With respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials
Safety Administration proposes to issue a Compliance Order to Sabal Trail Transmission,
LLC. Please refer to the Proposed Compliance Order, which is enclosed and made a part of
this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the response
options. All material you submit in response to this enforcement action may be 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).
Following the receipt of this Notice, you have 30 days to submit written comments, or request
a hearing under 49 CFR § 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 a Final Order. If you are responding to this
Notice, we propose that you submit your correspondence to my office within 30 days from
receipt of this Notice. This period may be extended by written request for good cause.
In your correspondence on this matter, please refer to CPF 2-2019-1001 and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
4



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Sabal Trail Transmission, LLC (STT) a
Compliance Order incorporating the following remedial requirements to ensure the
compliance of STT with the pipeline safety regulations:
1. In regard to Item Number 1 of the Notice pertaining to STT’s failure to ensure that welding
processes followed established welding procedures qualified in accordance with API 1104,
STT must:
a. Perform an in-line inspection to specifically detect and evaluate cracks in girth welds
for the entire pipeline, including laterals. 30 days prior to each run, STT must notify
the Director, Office of Pipeline Safety (OPS), PHMSA Southern Region, of the
planned start and completion date(s) of all inspection tool runs.
b. Provide a written report to the Director, OPS, PHMSA Southern Region, describing
the tool or tools to be used. This report shall include the validation for the selected
tool(s), the tool or tools’ performance specifications, and a detailed description of the
criteria to be used for the verification, evaluation, prioritization and corrective action
of any identified integrity threats.
c. Perform an analysis of the data returned from the inspection required by 1a. The
results shall be evaluated per a performance specification specific to girth weld
anomalies by qualified individual(s).
d. e. Excavate a minimum of two girth welds to verify the tool or tools’ performance.
Take corrective action based the prioritization of any integrity threats and anomalies
that are identified. STT shall provide OPS Southern Region written quarterly status
reports summarizing the integrity threats and anomalies identified and the corrective
action taken to date.
f. Make available for OPS inspection all records and documentation showing the
completion of ILI assessment and any corrective actions.
2. STT must complete the above items within the following time requirements:
a. b. c. Within 60 days of receipt of the Final Order, complete the requirements of Item 1b.
Within 180 days of receipt of the Final Order, complete the requirements of Item 1a.
Within 30 days of the completion of each run conducted per Item 1a, make available
for OPS inspection all records and documentation of completion of the run.
d. Within 60 days of the successful completion of the ILI run required by Item 1a,
complete the data analysis required by Item 1c.
e. Within 30 days of the successful completion of the data analysis required by 1c,
complete the excavations required by Item 1d.
f. Within 30 days of completion of the last corrective action taken per Item 1f, comply
with Item 1g.
5



3. It is requested (not mandated) that STT maintain documentation of the safety improvement
costs associated with fulfilling this Compliance Order and submit the total to the Director,
OPS, PHMSA Southern Region. It is requested that these costs be reported in two
categories: 1) total cost associated with preparation/revision of plans, procedures, studies
and analyses, and 2) total cost associated with replacements, additions and other changes to
pipeline infrastructure.
6

220191001_Final Order_04102020_text.pdf

VIA EMAIL TO: al.monaco@enbridge.com, rick.kivela@enbridge.com, and
michele.harradence@enbridge.com
Mr. Al Monaco
President and Chief Executive Officer
Enbridge, Inc.
200, Fifth Avenue Place
425 - 1st Street S.W.
Calgary, Alberta, Canada T2P 3L8
Re: CPF No. 2-2019-1001
Dear Mr. Monaco:
Enclosed please find the Final Order issued in the above-referenced case to your subsidiary,
Sabal Trail Transmission, LLC. It makes one finding of violation, assesses a reduced civil
penalty of $19,000, and specifies actions that need to be taken by Sabal Trail Transmission,
LLC, to comply with the pipeline safety regulations. The penalty payment terms are set forth in
the Final Order. When the civil penalty has been paid and the terms of the compliance order
completed, as determined by the Director, Southern Region, this enforcement action will be
closed. Service of the Final Order by e-mail is effective upon the date of mailing as provided
under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA
Mr. Rick Kivela, Manager, Operational Compliance, Enbridge, Inc.
Ms. Michele Harradence, Vice President, Gas Transmission & Midstream Operations,
Sabal Trail Transmission, LL
VIA EMAIL – CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Sabal Trail Transmission, LLC, ) CPF No. 2-2019-1001
a subsidiary of Enbridge, Inc., )
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From October 16, 2016, through April 7, 2017, pursuant to 49 U.S.C. § 60117, representatives of
the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Sabal Trail
Transmission, LLC (STT or Respondent), in Alabama, Georgia, and Florida. STT, a subsidiary
of Enbridge, Inc., operates a 517-mile interstate natural gas transmission pipeline running
through Alabama, Georgia, and Florida.1
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to
Respondent, by letter dated March 19, 2019, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice), which also included warnings pursuant to
49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that
STT had violated 49 C.F.R. § 192.225(a) and proposed assessing a civil penalty of $52,500 for
the alleged violation. The Notice also proposed ordering Respondent to take certain measures to
correct the alleged violation. The warning items required no further action but warned the
operator to correct the probable violations or face possible future enforcement action.
After requesting and receiving an extension of time to respond, Enbridge, Inc., responded to the
Notice on behalf of STT, by letter dated May 31, 2019 (Response). The company contested one
of the instances of alleged violation, provided an explanation of its actions, and requested that
the proposed civil penalty be reduced or eliminated. The company also contested one of the
warning items set forth in the Notice, and requested a hearing if the warning item were not
withdrawn. However, in accordance with 49 C.F.R. § 190.205, warning items are not
adjudicated so therefore a hearing is unavailable.
1 STT’s website, available at http://sabaltrailtransmission.com/ (last accessed March 13, 2020).



CPF No. 2-2019-1001
Page 2
FINDING OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 192, as follows::
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.225(a) which states:
§ 192.225 Welding procedures.
(a) Welding must be performed by a qualified welder or welding operator
in accordance with welding procedures qualified under section 5, section 12,
Appendix A or Appendix B of API Std 1104 (incorporated by reference, see §
192.7), or section IX of the ASME Boiler and Pressure Vessel Code (ASME
BPVC) (incorporated by reference, see § 192.7) to produce welds meeting the
requirements of this subpart. The quality of the test welds used to qualify welding
procedures must be determined by destructive testing in accordance with the
applicable welding standard(s).
The Notice alleged that Respondent violated 49 C.F.R. § 192.225(a) by failing to perform
welding in accordance with procedures qualified under Section 5 of API Standard 1104.
Specifically, the Notice alleged that PHMSA representatives observed pre-heat temperatures for
at least two welds that were not maintained at a minimum of 250° F immediately prior to
welding, as required by API Standard 1104, Section 5.4.2.13, during construction activity at the
Hildreth Compressor Station in December 2016 and on Spread 3 of the main line construction in
February 2017. The two allegations are discussed below separately.
Hildreth Compressor Station
The Notice alleged that the PHMSA representatives observed construction activity at the
Hildreth Compressor Station being performed under STT’s Welding Procedure Specification
BCS-122.2 (Specification 122.2) and that STT failed to maintain the required pre-heat
temperature of 250° F immediately prior to welding.
In its Response, STT contested the allegation on several grounds. First, it contended that
PHMSA did not actually observe inadequate pre-heating at the Hildreth Compressor Station
during the inspection but merely expressed “a concern about possible confusion in the pre-heat
language” in Specification 122.2 regarding preheat requirements.2 Second, it argued that the
weld was properly made under Specification 122.2 because it provided that the welder must
preheat to 100º F prior to welding, unless any of five conditions were met, in which case the pre-
heat temperature had to be 250º F. According to STT, one of those five conditions was whether
the ambient temperature was less than or equal to 50º F,3 in which case the pre-heating
2 Response, at 2.
3 The other conditions that require a preheat to 250ºF are set forth in the “PREHEATING” section on page 2 of
STT’s WPS, BCS-122.2. Pipeline Safety Violation Report (Violation Report), (April 1, 2019) (on file with
PHMSA), Exhibit A.



CPF No. 2-2019-1001
Page 3
temperature had to be 250° F. The company argued that on this particular occasion, the ambient
temperature was above 50° F and therefore the pre-heating temperature only needed to be 100°.4
Upon review of the record, I find that certain information needed to make a finding of violation
is missing from the record and that PHMSA therefore failed to meet its burden of proving that
STT failed to perform welding at the Hildreth Compressor Station in accordance with API 1104.
First, the Notice alleged that the PHMSA representatives actually observed inadequate pre-
heating immediately prior to welding, but STT claims that they did not. Neither side provided
any documentation or other evidence to support its position.
Second, PHMSA has not provided any evidence to prove that none of the five exceptions to the
100° pre-heat requirement in Specification 122.2 applied here and that the higher pre-heat
temperature of 250° had to be met. Specifically, I cannot find anything in the record that
documented either the actual pre-heat temperature immediately prior to welding or a record of
the ambient temperature immediately prior to welding at that location.
Third, the Region Recommendation stated that the operator did not contest this allegation of
violation. This is not accurate. As I read the Response, STT contested this allegation regarding
the Hildreth Compressor Station but not the one discussed below. Furthermore, the
Recommendation failed to address the defenses laid out in the Response and are therefore
unrefuted.
For these reasons, I find that PHMSA has failed to meet its burden of proof in regard to this
instance of violation at the Hildreth Compressor Station and therefore order that this allegation of
violation be withdrawn.
Spread 3 of the Main Line
In its Response, STT did not contest the allegation of violation that it failed to adhere to pre-heat
temperature requirements for welding set forth in API Standard 1104, Section 5.4.2.13 on Spread
3 of the main line construction in February 2017. Accordingly, based upon a review of all of the
evidence, I find that Respondent violated 49 C.F.R. § 192.225(a) by failing to perform welding
in accordance with welding procedures qualified under Section 5 of API Standard 1104 on
Spread 3 of the main line construction.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
4 Response, at 2.



CPF No. 2-2019-1001
Page 4
related series of violations.5 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; any effect that
the penalty may have on its ability to continue doing business; and the good faith of Respondent
in attempting to comply with the pipeline safety regulations. In addition, I may consider the
economic benefit gained from the violation without any reduction because of subsequent
damages, and such other matters as justice may require. The Notice proposed a total civil
penalty of $52,500 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $52,500 for Respondent’s violation of 49 C.F.R.
§ 192.225(a), for failing to perform welding in accordance with welding procedures qualified
under Section 5 of API Std 1104. In its Response, STT requested a reduction in or elimination of
the proposed civil penalty. STT alleged that the violation was a single isolated occurrence,
occurring only on Spread 3 of the mainline construction and not at its Hildreth Compressor
Station, and that there was a lack of evidence of the potential for hydrogen-assisted cracking
(HAC) to remain in the girth welds on the STT pipeline and, implicitly, that there was a minimal
safety risk.6 STT also noted that it did not gain economic benefit from this violation. I will
address each of these arguments below.
First, the one allegation of violation relating to the Hildreth Compressor Station in December
2016 has been withdrawn. Therefore, I am reducing the number of instances of violation in this
case from two to one and lowering the proposed penalty amount accordingly.
Second, STT alleged that there is a lack of evidence of the potential for HAC to remain in the
girth welds on the STT pipeline. In its Response, the operator noted that modern pipelines do
not have a prevalent history of HAC with cellulosic welding, and its pipelines follow this
historical trend due to the use of low-carbon-equivalent pipe under conditions with a low risk of
HAC. After the PHMSA inspection, STT conducted radiographic testing of all the girth welds to
determine if HAC was a systemic issue on its pipeline, and determined it was not. Part E6 of the
Violation Report provides that the lowest level of gravity should be attributed to this violation
since there was minimal impact on pipeline safety, despite occurring within a high consequence
area (HCA) or an HCA could-affect area. Accordingly, I find that the penalty assessment
criterion for gravity should be reduced from Category 3 to Category 5, thus justifying a
substantial penalty reduction.
Finally, STT alleged that it did not gain an economic benefit from its non-compliance. However,
the proposed civil penalty was not increased based on this assessment criterion. Therefore, I do
not find any reason to reduce it based on this factor alone.
In summary, having reviewed the record and considered the assessment criteria for the Item cited
above, I assess Respondent a reduced total civil penalty of $19,000.
5 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.
6 Response, at 2.



CPF No. 2-2019-1001
Page 5
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $19,000 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49
C.F.R. §§ 192.225(a). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.
§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to
ensure compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 192.225(a) (Item 1), Respondent must:
a. Within 180 days of receipt of the Final Order, perform an in-line
inspection to specifically detect and evaluate cracks in girth welds for the
entire pipeline, including laterals. Thirty days prior to each run, STT must
notify the Director of the planned start date(s) and completion date(s) of
all inspection tool runs, and 30 days after each tool run, must make
available for inspection all records and documentation of completion of
the run;
b. Within 60 days of receipt of the Final Order, provide a written report to
the Director describing the tool or tools to be used. This report shall
include the validation for the selected tool(s), the tool or tools’
performance specifications, and a detailed description of the criteria to be
used for verification, evaluation, prioritization and corrective action of any
identified integrity threats;
c. Within 90 days of each tool run required under 1(a), perform an analysis
of the data returned from the inspection. The results shall be evaluated per
a performance specification specific to girth weld anomalies by qualified
individual(s);
d. Within 60 days of completion of 1(c), excavate a minimum of two girth



CPF No. 2-2019-1001
Page 6
e. f. welds to verity the tool or tools’ performance;7
Take corrective action(s) based on the prioritization of any integrity
threats and anomalies that are identified. STT shall provide the Director
written quarterly status reports summarizing he integrity threats and
anomalies identified and the corrective action(s) taken to date; and
Make available for OPS inspection all records and documentation showing
the completion of ILI assessment and any corrective actions within 30
days of completion of the last corrective action under 1(e).
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
It is requested (not mandated) that Respondent maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the total to the
Director. It is requested that these costs be reported in two categories: (1) total cost associated
with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated
with replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for
each day the violation continues or in referral to the Attorney General for appropriate relief in a
district court of the United States.
WARNING ITEMS
With respect to Items 2 and 3, the Notice alleged probable violations of Part 192 but did not
propose a civil penalty or compliance order for these items. Therefore, these are considered to
be warning items. The warnings were for:
49 C.F.R. § 192.235 (Item 2) ─ Respondent’s alleged failure to preserve the
alignment of the pipe or component being welded while the root bead was being
deposited;8 and
49 C.F.R. § 192.505(d) (Item 3) ─ Respondent’s alleged failure to conduct a pre-
installation strength test by maintaining the pressure for at least four hours for
fabricated units and short sections of pipe.
7 This requires excavation of a minimum of two girth welds if the same ILI tool is utilized for multiple segments. If
STT requires longer than 60 days to perform the excavations, it must request an extension as set forth in the Final
Order.
8 In its Response, STT contested this item and requested a hearing if the item were not withdrawn. In accordance
with § 190.205, an operator may submit a response to a warning, but is not required to do so. An adjudication under
Part 190 to determine whether a violation occurred therefore is not conducted for warning items. In the Matter of
Enterprise Products Mid-America Pipeline Company, CPF No. 4-2017-5019, 2018 WL 7350936, at *7 (Oct. 15,
2018).



CPF No. 2-2019-1001
Page 7
If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be
subject to future enforcement action.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this
Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and
meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays
the payment of any civil penalty assessed. The other terms of the order, including corrective
action, remain in effect unless the Associate Administrator, upon request, grants a stay.
The terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
April 10, 2020
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

220191001_Closure Letter_09022021_(16-153225S)_text.pdf

VIA ELECTRONIC MAIL TO: al.monaco@enbridge.com
September 2, 2021
Mr. Al Monaco
President and Chief Executive Officer
Enbridge, Inc.
200, Fifth Avenue Place
425 – 1st Street S.W.
Calgary, Alberta, Canada T2P 3L8
Re: CPF No. 2-2019-1001
Dear Mr. Monaco:
On April 8, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to your subsidiary, Sabal Trail Transmission, LLC (STT) a Final Order in the above-referenced
case. The Final Order included a Compliance Order (CO) which required STT to undertake
certain actions to ensure compliance with the federal pipeline safety regulations. The required
actions were directly related to the potential threat of cracks at girth welds throughout significant
portions of the STT system. The Final Order also assessed a civil penalty of $19,000.
STT provided all required items, including multiple quarterly status reports, within the
timeframes specified in the CO. The third and final quarterly status report was received by
PHMSA on December 7, 2020. The report indicated that all portions of the in-line inspection
(ILI) assessment intended to capture the cracking threat were completed on or before June 25,
2020, and STT paid the civil penalty by September 1, 2020.
It should be noted that following STT’s identification of an ILI-based approach to the cracking
threat, PHMSA expressed concern with STT’s reliance on solely ILI tools to find/identify cracks
in girth welds. STT confirmed in the above-referenced final quarterly status report that an
Enhanced Survey Analysis (ESA) was completed on the tool run for the referenced assessment to
“…provide a thorough inspection of all Girth Welds that might be in question on the STT
Pipeline.”
Based upon review of documentation of actions taken, PHMSA has determined that STT has
complied with the terms of the CO and the Final Order. This case is now closed, and no further
action is necessary with respect to the matters involved in this case.



Please be advised that this letter refers only to the above referenced order (CPF 2-2019-1001)
and not to any other PHMSA cases, if any.
Sincerely,
James A. Urisko
Director, Southern Region
Pipeline and Hazardous Materials Safety Administration
Cc: Mr. Bill Yardley, President and Chief Executive Officer, Sabal Trail Transmission, LLC,
bill.yardley@enbridge.com
Mr. Nathan Atanu, Manager, Operational Compliance,
Enbridge, Nathan.Atanu@enbridge.com
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