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

party submissionOfficial PDF220191001_Operator Response to Notice and Request for Hearing_05312019.pdf#

220191001_NOPV PCP PCO_03192019_text.pdf, page 1Official PDFNOTICE 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#

220191001_NOPV PCP PCO_03192019_text.pdf, page 2welding 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#

220191001_NOPV PCP PCO_03192019_text.pdf, page 3into 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#

220191001_NOPV PCP PCO_03192019_text.pdf, page 4With 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#

220191001_NOPV PCP PCO_03192019_text.pdf, page 5PROPOSED 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#

220191001_NOPV PCP PCO_03192019_text.pdf, page 63. 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, page 1Official PDFVIA 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#

220191001_Final Order_04102020_text.pdf, page 2U.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).#

220191001_Final Order_04102020_text.pdf, page 3CPF 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.#

220191001_Final Order_04102020_text.pdf, page 4CPF 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.#

220191001_Final Order_04102020_text.pdf, page 5CPF 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.#

220191001_Final Order_04102020_text.pdf, page 6CPF 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#

220191001_Final Order_04102020_text.pdf, page 7CPF 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).#

220191001_Final Order_04102020_text.pdf, page 8CPF 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, page 1Official PDFVIA 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.#

220191001_Closure Letter_09022021_(16-153225S)_text.pdf, page 2Please 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 2#